A major emphasis of the current administration is to expand work, education and training to work, or other forms of community engagement requirements as conditions of eligibility for numerous health and human services programs. For the first time it would expand work requirements for Medicaid and strengthen current minimal ones in subsidized public housing. The federal Office of Child Support Enforcement is urging states to use federal incentive funds to finance employment and training efforts for non-custodial parents.
This stronger emphasis on work took off in 1996 with the enactment of the Personal Responsibility and Work Opportunity Reconciliation Act and the creation of the Temporary Assistance for Needy Families Program (TANF).
The concept of work in return for benefits found its way into the Supplemental Nutrition Assistance Program (SNAP) in 1998, when the Employment and Training Program (SNAP E&T) was initiated, and recently passed House legislation would expand SNAP work requirements and make them mandatory in most instances.
Public housing is also in line for expanded work requirements. Programs to promote work at a public housing authority’s discretion have existed for those receiving direct subsidies or housing choice vouchers since 1985, but they have been extremely small and experimental. The administration’s budget proposal for FY19 would require work or other activities as a condition of eligibility for the 26 percent of nonworking, nondisabled residents of public housing.
The inclusion of Medicaid in the panoply of programs with work-community engagement requirements is the newest proposal. States have been given the option to seek waivers to implement work or community engagement requirements in Medicaid as a condition of eligibility for adults without disabilities. A number of states have pending waivers, and CMS has granted waivers to Kentucky, Arkansas and Indiana.
There is a question as to whether allowing states to impose work or other engagement requirements through waivers is legal, because it may exceed administrative authority and possibly violate the Americans with Disabilities Act. Kentucky’s waiver was challenged in court and has been temporarily halted. In response, the administration is reopening public comments on work requirements for Medicaid to address the court concerns and reinstate the program.
Few disagree that employment for those who can work is both economically and socially beneficial. Most work-eligible adults in public benefit programs already work, but there is a troubling percentage of nondisabled, nonworking adults enrolled in public benefit programs. The numbers could be as high as 9 million but estimates tend to be made at a point in time, subject to dispute and likely count duplicate beneficiaries across several programs. Regardless, as a matter of public policy, they need our attention.
The idea of reciprocity, where public agencies provide benefits based on expectations that work-capable adults make reasonable efforts to get training or jobs, has become more widely accepted. Employment not only improves an individual’s economic condition, but it also builds social capital by connecting adults to colleagues and other contacts. It can also prevent social isolation and improve both physical and mental health outcomes.
The nation’s economy has recovered from years of sluggishness and the unemployment rate is at historically low levels. Yet employers need qualified workers and in many sectors, cannot find them. This creates an opportunity for states to ramp up their efforts across health and human services programs to train and place nonworking, nondisabled adults into jobs by working in close partnership with employers, both for- and not-for-profit organizational partners, and the work-capable clients themselves, to accomplish this goal.
Eligible populations now covered by TANF and SNAP E&T work rules already overlap even more so if SNAP rules are greatly expanded and become mandatory. This could lead to confusion and duplicative engagement requirements in other programs. States and localities may currently lack systems and infrastructure to track clients assigned to activities or to enforce requirements.
Meanwhile, preparing and moving eligible adults into employment presents its own set of challenges. Clients often have limited work histories and face multiple difficulties such as child care, transportation, parental responsibilities, child support obligations, previous incarcerations or chronic health conditions. Subsequently, adequate funding and innovative approaches are fundamental to supporting activities that embrace education and sector-based training aligned with available local labor market jobs. Key to the success of any training are employer networks with businesses willing to hire adults with limited skills and experience, and provide on-the-job training through apprenticeships, subsidized employment and other skill development.
Expanding work requirements to multiple programs will be very resource dependent, if the goal is truly to get clients into jobs instead of simply imposing sanctions. Even if work-eligible adults willfully and without good cause fail to comply with work rules and are penalized, the question remains as to whether denying benefits could make the cure worse than the problem.
Proposals in both housing and Medicaid to include compliance requirements could instead of leading to work, block beneficiaries from access to health care or housing, potentially leading to increased health problems, potential homelessness and increased costs of both charity care in health and shelter costs in housing.
The bottom line — states and localities must be both intentional and cautious in properly designing programs to help vulnerable populations achieve success through various approaches that combine expectations and consequences.