New Waiver Proposal for Oklahoma Medicaid Beneficiaries Would Harm Low-Income Families With Children

In This Report:

Key Findings

  • Oklahoma’s proposed Medicaid waiver is incomplete and internally inconsistent on the most important question: how many parents and children may lose coverage. Despite the fact that one of the stated goals is to reduce Medicaid enrollment, the proposal projects there will be no impact on enrollment.
  • The new work rules would predominantly affect Oklahoma’s poorest mothers. The impact could hit hardest in Oklahoma’s small towns and rural communities, where parents are more likely to receive Medicaid and where jobs are harder to find.
  • Even if these parents work more hours, they are unlikely to have an affordable offer of health coverage from their employers, so will likely become uninsured. Only 11 percent of Oklahoma adults living in poverty receive employer sponsored insurance.
  • The loss of coverage for parents would affect their children, creating more financial hardship for families and risking children’s access to health care. Oklahoma already has the 5th highest rate of uninsured children in the nation, and the rate is even higher among American Indian children.


Oklahoma is planning to ask federal permission to impose a work requirement on very low-income parents and caregivers receiving health coverage through Medicaid. Under the proposal, these beneficiaries would have to document that they are working at least 20 hours a week or participating in job-training or volunteer activities in order to maintain their SoonerCare coverage.  The impact of the Oklahoma Health Care Authority’s proposal could mean some of the state’s poorest parents would lose health coverage altogether. And that loss of coverage would affect their children, who may lose coverage, as well.

Oklahoma’s proposal asserts that there will be no impact on Medicaid spending or enrollment if the Centers for Medicare and Medicaid Services (CMS) approve the request to amend the state’s Section 1115 demonstration waiver.1 This contradicts assertions made elsewhere in the proposal that the goal is to reduce Medicaid enrollment.2 Moreover, it is clear from research based on the experience of work requirements in other programs and other states that significant coverage losses are likely. Nationally, an analysis by the Kaiser Family Foundation found that work rules could cause an estimated 1.4 million to 4 million adults to lose Medicaid coverage. Many of these adults are already working and meet the requirements, but would lose access to health care because of “administrative burdens or red tape.”3 In Arkansas, for instance, 72 percent of the people expected to log into the state’s web portal and report their work did not take action in the first month.4

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  1. P. 15 of OHCA SoonerCare 1115(a) Research and Demonstration Waiver
    Amendment Request, accessed on July 10, 2018 at
  2. See for example p. 14, ibid.
  3. Garfield, Rachel, Robin Rudowitz and MaryBeth Musumeci. “Implications of a Medicaid Work Requirement: National Estimates of Potential Coverage Losses.” (Washington: Kaiser Family Foundation, June 2018) accessed at a-medicaid-work-requirement-national-estimates-of-potential-coverage-losses/.
  4. Alker, Joan and Maggie Clark, “One Month into Medicaid Work Requirement in Arkansas, Warning Lights are Already Flashing,” (Washington: Center for Children and Families, July
    20, 2018) accessed at medicaid-work-requirement-the-warning-lights-are-already-flashing/.