Two months ago, South Carolina followed the example of five other non-expansion states and submitted a proposal to CMS to impose work reporting requirements targeted at low-income parents. Unlike the other non-expansion states, however, South Carolina’s waiver does propose an expansion of coverage from 67% FPL to 100% FPL. CCF recently updated our analysis of the state’s proposal and found that the work reporting requirements would have a disproportionate impact on African Americans and mothers, risking the coverage of parents and their children. Public comments submitted to CMS regarding South Carolina’s Community Engagement 1115 waiver largely express concerns over these potential coverage losses and reflect widespread opposition to the work reporting requirement.

Of the thirty-nine comments posted in response to the proposal, thirty-six were strongly opposed to the proposed work reporting requirements. Only two comments were unambiguously in support of the waiver, and both were from individuals not organizations.

Many organizations, including Georgetown University CCF, submitted comments raising concerns about administrative burdens from reporting requirements resulting in coverage losses and the volatility and lack of stability linked to low-wage jobs. Several comments from organizations such as United Way Worldwide, the American Academy of Pediatrics, and the National Center for Law and Economic Justice, cited evidence from Arkansas’ work requirement showing that the policy is not incentivizing work; instead, it has decreased employment and increased uninsurance rates. The comments also stressed that getting a job, particularly for seasonal employees and low-wage workers, does not come with the guarantee of getting employer sponsored coverage.

In its application, the state estimates 7,100 beneficiaries will lose coverage in the first year due to failure to meet the work hours threshold or reporting requirements. Commenters disputed this figure, arguing that the state undercounts the expected coverage losses by only estimating losses for the first year and failing to include parents that would gain eligibility through the state’s proposed eligibility expansion (up to 100% FPL). Comments also highlighted the likelihood of increased coverage losses for children whose parents would be affected by the requirements.

Another theme that emerged throughout the comments was support for the proposed eligibility expansions. South Carolina is proposing to increase parent and CHIP eligibility levels as well as expand coverage for pregnant women. A dozen comments expressed support for at least one, if not all, of these expansions. However, the call to expand Medicaid in South Carolina was just as dominant, noting that the state would be better served by providing coverage to low-income adults and families with incomes up to 138% FPL.