We’ve been talking a lot about work reporting requirements in Medicaid for the past year. We had raised concerns about our state’s “Pathway to Prosperity” waiver request since it was proposed in January. Then, with the passage of H.R. 1 (the “One Big Beautiful Bill”), things became more complicated. Here’s what I’m worried about:

First, Arkansas’s proposal has some big differences from the federal work reporting requirements passed by Congress in July. This is a problem. It means there are two different processes with different requirements for Arkansans covered through our Medicaid expansion program, ARHOME. How will Arkansans know if they’re following the rules? If Arkansas’s proposal doesn’t comply with federal law, changes will need to be made to our proposal. But we haven’t heard anything new in months about the status of our waiver proposal. It’s still listed as pending on the CMS website.

If any changes are made to the ARHOME work reporting requirements outlined in our waiver request, the public needs to be part of this process. That’s why we have public comment periods. DHS held public hearings in February and requested feedback on the Pathway to Prosperity proposal. If the state now plans to do something different, it should follow its own processes for new waiver proposals by showing its plan to the public and taking new public comments. This shouldn’t be optional. This is a process that will impact the health care of thousands of Arkansans. The bare minimum is to bring the public into the process.

The bigger picture question I have is: is our state anywhere close to ready to implement the provisions of H.R. 1 and any version of work reporting requirements?

A report from Georgetown’s Center for Children and Families shows that states, including Arkansas, are not ready to implement the new federal work reporting requirements under H.R. 1. A key takeaway from the report is that we are poised to spend more money while covering fewer people. Many eligible individuals may lose coverage not because they don’t qualify, but because of delays, red tape, or system errors. The report highlights three key indicators that show where Arkansas is struggling, and why these challenges will make any new work requirement even harder to manage.

1. Average call wait times: The report looks at how long people are kept on hold when they call their state Medicaid office or whether they hang up before getting help. Long waits or high abandonment rates mean people who are eligible may not get the assistance they need in time. That increases the risk of losing coverage just for missing a form or deadline. If a work reporting requirement is added on top of the regular eligibility process, timely help becomes even more important. Low call center capacity will become a major barrier. Arkansas was in the third quarter for wait times at an average of 11 minutes.

2. Application processing time: Many applications are already taking longer than 30 days to process. When states are struggling to keep up with regular applications, adding a new layer of verification for work hours, school, or community service makes it even more likely that people will wait longer or lose coverage while waiting. Delayed processing means delayed care. On average, 22.4%, more than 1 in 5 applications, took more than 30 days to process in Arkansas.

3. Procedural disenrollment rates: This is when people lose coverage not because they are ineligible, but because the state doesn’t have enough information to confirm eligibility. That could mean missing paperwork, mismatched records, or confusing notices. In many states, more than two-thirds of disenrollments are procedural. In Arkansas, it’s more than 72%. Adding work reporting requirements could make the problem much worse. Even one missing form could cause someone who meets the requirements to lose coverage.

When you look at all of this together, it’s clear that even before we get to the question of which version of work reporting requirements Arkansas might implement, the foundation is shaky. If call centers, renewal systems, and application processing are already under strain, adding a new and complex requirement only increases the risk of coverage losses, confusion, and higher costs for the state. And even though work reporting requirements only apply to adults who receive coverage through ARHOME, if the state’s administrative capacity is strained, all enrollees – including children – are impacted. When parents are insured, their kids are more likely to be insured. Losing that progress means losing more progress on keeping kids insured, too.

Before moving forward, Arkansas should focus on fixing these underlying problems. That means improving call center staffing, increasing automatic renewal rates, reducing procedural disenrollments, and communicating quickly with enrollees. And most importantly, the public deserves transparency about the Pathway to Prosperity waiver. People’s health coverage is at stake, and the public has a right to know about any planned changes and when they will happen.