“No one really anticipated this,” said Victoria Pross, a senior health attorney at the Massachusetts Law Reform Institute. She pointed out that low-income families, elderly individuals, and those with disabilities are often included in cash assistance programs, leading to the question of who might be capable of work. “That’s why the whole group has to follow these work requirements,” she added.
Pross expressed her concerns, saying, “At best, it might just delay care, but at worst, eligible individuals could lose their benefits due to administrative issues.”
The Centers for Medicare and Medicaid Services did not provide any comments when asked.
For years, Massachusetts’ MassHealth program has automatically enrolled recipients in financial assistance programs like Transition Assistance for Families with Dependent Children and Emergency Assistance for Elderly, Disabled Persons, and Children. These programs focus on providing support for children, caregivers, and seniors who have limited income. To qualify for TAFDC, a family of four must earn less than $1,043 a month or $12,500 a year. Both programs require verification through interviews with state officials.
“This is probably the gold standard for benefit programs,” Pross noted. “Rather than navigating through extensive red tape, another agency could easily determine eligibility.”
MassHealth quietly revealed changes in early June, right after states received new guidance from the Centers for Medicare and Medicaid Services about determining exemptions from proving work or volunteer hours for health insurance. These new guidelines seem to be more challenging than expected, according to various officials and policy experts.
A spokesperson for MassHealth stated, “The changes allow members to deal with complexities to keep their health coverage. We will make our best efforts to communicate these changes and support our members through the application process to ensure they maintain the coverage they need for their health and well-being.”
Many individuals in financial assistance programs already qualify for work requirement exemptions—this includes those who are pregnant, caring for young children, over 65, or medically frail.
This fall, MassHealth will cease automatic enrollment for new recipients in its cash assistance program. Starting in 2027, current beneficiaries will be required to complete an application to verify their eligibility to keep their coverage.
The program intends to reach out to affected members late this summer or early fall to explain the process for keeping their coverage. Members who haven’t applied yet will receive an application in 2027, according to a MassHealth representative.
However, it might be particularly tough to prove someone is medically frail. Individuals aged 19 to 64, who mostly obtained Medicaid benefits through the Affordable Care Act expansion, will need a qualifying diagnosis and verification from their healthcare provider that they are unable to work. This could create additional burdens for both applicants and healthcare professionals.
“We’re not set up for employability assessments. That’s not our usual role,” noted Dr. Benjamin Somers, a health economist and primary care doctor at Harvard University, following the release of the CMS guidelines. “This takes up valuable staff time, and we’re just not trained for it.”
MassHealth needs federal approval to phase out the automatic enrollment process. As part of this requirement, state officials are accepting public feedback until July 6, based on MassHealth documents.
Pross said that her organization and other advocacy groups plan to suggest ways for MassHealth and the state Office of Transition Assistance to help minimize the risk of individuals losing coverage, such as providing direct support from staff to assist with applications.
Yet, implementing these suggestions may be overwhelming for state governments already handling significant changes federally. The Department of Transitional Assistance has recently experienced challenges in effectively responding to high call volumes linked to the Supplemental Nutrition Assistance Program, causing a decline in enrollment.
Cecile Avila, a spokesperson for the Ministry of Transition Support, noted that they’re closely collaborating with MassHealth to ensure financial assistance recipients receive the necessary help during this transition.
Pross hopes the state will be receptive to public input, remarking, “Expectations shifted rapidly in a very short time.” He expressed doubt over whether large institutions like MassHealth and DTA have fully accounted for the consequences of these changes.
