Last month, federal CMS reopened the public comment period on Mississippi’s proposed Section 1115 Medicaid work requirements waiver at the same time as Kentucky’s comment period was reopened. Mississippi’s proposal has not garnered as much attention as Kentucky’s,  which as regular readers of SayAhhh! know, is currently on hold due to a federal court decision. But if approved by the Trump Administration, there is a good chance that Mississippi will become the first non-expansion state to apply work requirements – an even harsher decision that will harm families with children.

We’ve written a report about the deeply flawed Mississippi waiver. Because the state has not expanded Medicaid, the only adults that would be subject to the new rules are very poor parents (mostly women) with incomes below 28% of the poverty line (just $468 a month for a family of three). And these mothers would face a “Catch-22” if the policy goes forward. If they work 20 hours a week, as the proposal requires, they would lose Medicaid as a result of being over the income limit, however, they would also lose Medicaid if they don’t due to a failure to comply with the new rules. The state’s purported remedy for this problem is really no fix at all – as I blogged about before, it only offers a temporary fix for a measly 2% of those subject to the new rules.

The state’s own numbers project that 5,000 parents would lose coverage in the first year and approximately 20,000 would lose coverage by the end of the five year waiver period. This estimate is likely too low and it does not include any possible coverage losses among children. While children are exempted on paper, plenty of research shows that uninsured parents are more likely to have uninsured children – so we would expect some coverage losses for children as well.

While Kentucky’s comment period resulted in an astounding 9,397 comments being submitted, the second round of federal comments on Mississippi saw a sharp increase in public response. We have taken a close look at the comments and found 320 unduplicated submissions. (By comparison, the first federal comment period generated just 24 submissions.)

Of the 320 public comments submitted on Mississippi’s proposal, 319 were in opposition to the state’s waiver request.

Doctors, clinics and other health care providers such as the American Academy of Pediatrics, the American College of Obstetricians and Gynecologists, the Mississippi Public Health Association, the National Association of Community Health Centers as well as those representing patients and consumers like the American Cancer Society, the American Diabetes Association, the Mississippi Health Advocacy Program, the Mississippi Center for Justice all explained why the waiver should not be approved. You can see our comments here.

Many commenters also noted the disparate racial impact of the state’s plans. As our paper found, 71% of those impacted would be African-American. Families living in rural areas, such as the Mississippi Delta, would be harder hit as well. This is especially troubling because maternal mortality is already higher in the Delta region.

Ordinary citizens commented as well – here’s one mother who articulated very poignantly just how high the stakes are:

“I raised my sons for many years before I married again. We lived in poverty and without health insurance of any kind. I had to pay out of my small paycheck for all medical services for my sons and myself and this forced us into living in poverty with little chance to better our financial position. We could not afford any expensive procedures and I was forced to put off any procedures I may have needed for myself to recover from the effects of two difficult pregnancies. By the time I gained health insurance through my new husband’s policy, I learned that I had a serious condition and was operated on immediately. The surgeon said one more month and I might have died. No one should live with that sort of threat. Don’t adopt this policy.”