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Questionnaire NameHealthy Michigan - Amendment Request
DescriptionMichigan proposes to amend its demonstration, "Healthy Michigan Plan." The state is requesting that in order for beneficiaries with income between 100 percent and 133 percent of the federal poverty level (FPL) to maintain eligibility after 48 months of cumulative enrollment, they must engage in annual healthy behaviors and non-exempt beneficiaries must pay a monthly 5 percent of income premium as a condition of continued Medicaid eligibility. The state is also requesting the authority to require beneficiaries to participate in community engagement requirements as a condition of continued Medicaid eligibility. Michigan is no longer seeking to implement the "Marketplace Option" and is no longer seeking continuation of the corresponding authorities. The federal comment period will be open from September 26, 2018 through October 26, 2018.
Response FromID: #383905 on Oct 10th 2018 9:52 am
Healthy Michigan - Amendment Request

Healthy Michigan - Amendment Request

We encourage the public to submit their comments on Medicaid.gov as they relate to demonstrations open for public comments. In support of transparency and open government, all public comments received are immediately posted and are in the public domain. Center for Medicaid and CHIP Services staff will review all public comments posted and we reserve the discretion to delete comments that are generally understood as any of the following: obscene, profane, threatening, or otherwise inappropriate.

Refer to the Application

Open for Public Comment – 9/26/18 – 10/26/18

Please provide your comments here and/or attach below:

Thank you for the opportunity to submit comments on this issue. I am an individual who works in public health, and I see firsthand in my work how a strong Medicaid program can promote healthy families and overall community wellness. The proposed work requirement and healthy behavior and premium requirements in Michigan, all of which include disenrollment and coverage lock-out for noncompliance, are inconsistent with Medicaid’s objective under the law. Under the Medicaid statute, the Secretary of Health and Human Services (HHS) can only approve 1115 waivers that promote Medicaid’s objectives, which are to furnish medical assistance. Michigan’s request to disenroll and lock individuals out of Medicaid coverage if they do not comply with requirements to work, pay premiums or complete healthy behaviors is not in any way related to Medicaid’s objectives. In fact, if approved the program would reduce coverage, and make it harder for people to access health care, stay healthy, and even to work.

Taking Medicaid health insurance away from otherwise eligible Michigan residents will not promote Medicaid’s objectives under any analysis. Michigan asserts that it will make all efforts to ensure that enrollment is not negatively affected by the proposed programs. However, a hallmark of the requested work, healthy behavior and premium requirements is disenrollment of individuals who do not meet those requirements. Given that, it is difficult to imagine that the programs will not result in substantial disenrollment. Arkansas’s recent roll out of its work requirement resulted in large coverage losses.

I support programs that truly help get people back to work, and Medicaid is one of those programs. Threatening people with loss of health insurance, and cutting people off health insurance, will not promote work. Whether the impact of work on health is positive or not depends on the type of job and low-wage jobs are much less likely to promote health.

Additionally, the Secretary cannot simply add eligibility requirements to Medicaid because an activity might be related to health. Medicaid’s purpose is to furnish medical assistance; it is not to require enrollees to engage in any activity that might improve health. It is regulatory overreach for this or any other administration to start adding required activities to Medicaid eligibility because there is some data showing that the activity improves health.
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