CF Foundation Opposes Medicaid Work Requirements in New Hampshire

CF Foundation Opposes Medicaid Work Requirements in New Hampshire

In a letter to the New Hampshire Senate, the Cystic Fibrosis Foundation expressed opposition to SB 134, which would implement work requirements as a condition for eligibility.

Feb. 5, 2025 | 6 min read

Dear Honorable Members of the Senate Health and Human Services Committee:

On behalf of the nearly 240 people with cystic fibrosis living in New Hampshire, the Cystic Fibrosis Foundation writes in opposition of SB 134, which directs the state to resubmit their 1115 waiver to CMS regarding community engagement and work requirements under the state Medicaid program. We are committed to ensuring that the state’s Medicaid program provides critical healthcare coverage for those who qualify. Based on experience with similar policies in other states, we fear these requirements will lead thousands of people to lose coverage and jeopardize the healthcare of people with CF and other serious and chronic conditions.

About Cystic Fibrosis and the Cystic Fibrosis Foundation
Cystic fibrosis is a progressive, genetic disease that affects the lungs, pancreas, and other organs. There are close to 40,000 children and adults living with cystic fibrosis in the United States, and CF can affect people of every racial and ethnic group. CF causes the body to produce thick, sticky mucus that clogs the lungs and digestive system, which can lead to life-threatening infections. As a complex, multi-system condition, CF requires targeted, specialized treatment and medications. For those with CF, health care coverage is a necessity, and interruptions in care can lead to irreversible lung damage and costly hospitalizations — compromising the health and well-being of those with the disease. Over half of children and nearly one in four adults living with CF in New Hampshire rely on Medicaid for some or all of their health care coverage.

As the world’s leader in the search for a cure for CF and an organization dedicated to ensuring access to high-quality, specialized CF care, the Cystic Fibrosis Foundation accredits more than 130 care centers nationally — including one in New Hampshire — that provide multidisciplinary, specialized care in accordance with clinical practice guidelines. As experts in CF care, the CF Foundation and our care centers understand the critical role of adequate, affordable health coverage, including through programs like Medicaid.

Medicaid Work Requirements Jeopardize Access to Care
Work requirements threaten access to high-quality, specialized CF care for people with cystic fibrosis. Based on New Hampshire’s previous approved 1115 waiver requesting authority to implement work requirements, adults under 65 must be engaged in qualifying activities for at least 100 hours per month and report them to the state to maintain Medicaid eligibility. One major consequence of this proposal will be to increase the administrative burden on individuals in the Medicaid program, which could lead to significant coverage losses. When Arkansas implemented a similar policy requiring Medicaid enrollees to report their hours worked or their exemption, the state terminated coverage for over 18,000 individuals before a federal court halted the policy. Similarly, Georgia’s Pathways to Coverage Program, which includes work requirements, enrolled fewer than 5,000 individuals in its first year, instead of the projected 31,000-100,000 beneficiaries originally estimated to be eligible. This policy contradicts the goals of the Medicaid program and jeopardizes access to care for thousands of New Hampshirites.

Consistent care and access to specialized therapies are necessary for people with cystic fibrosis, and any loss or gap in coverage — even for as little as one month — may put people with CF at risk of declining health. As CF is a progressive disease, delaying or forgoing daily therapies has serious implications, including increased risk of lung exacerbations, irreversible lung damage, and costly hospitalizations. We fear that people with CF who may lose coverage under this policy could see alarming declines in their health as a result.

Additionally, the Foundation is concerned by the cost of implementing work requirements in Medicaid. A similar work reporting requirements proposal in Michigan had estimated administrative costs between $17.5 million and $70 million. In Georgia, over $26 million has been spent within a year of implementing the Georgia Pathways to Coverage Program, despite the low enrollment, and it is estimated that 90% of this was for administrative and consulting costs. Taxpayer dollars should focus on providing quality, affordable healthcare coverage, not cutting it.

Ultimately, these requirements do not further the goals of the Medicaid program or help low-income individuals find work. Most people on Medicaid who can work already do so. According to the Kaiser Family Foundation, more than 90% of adults with Medicaid coverage are either workers, caregivers, students, or unable to work due to illness. And continuous Medicaid coverage can actually help people find and sustain employment. In a report looking at the impact of Medicaid expansion in Ohio, the majority of enrollees reported that being enrolled in Medicaid made it easier to work or look for work (83.5 percent and 60 percent, respectively). That report also found that many enrollees were able to get treatment for previously untreated health conditions, which made finding work easier. Additionally, a study in The New England Journal of Medicine found that Arkansas’s work requirement was associated with a significant loss of Medicaid coverage, but no corresponding increase in employment. Terminating individuals’ Medicaid coverage for non-compliance with these requirements will hurt rather than help New Hampshirites search for and obtain employment.

The Cystic Fibrosis Foundation urges you to oppose SB 134, as this policy does not further the goals of the Medicaid program. We appreciate your attention to this important issue.

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