Cancer Nation Statement: Medicaid Work Requirements Will Unfairly Burden Cancer Survivors
Cancer Nation strongly supports a health care system free of waste, fraud, and abuse. Health care resources must be directed to delivery of reasonable and necessary care at an affordable cost. Such a system is critical to ensuring that people with cancer have access to high quality, affordable care from diagnosis and across the continuum of their disease. In our decades of service to people with cancer, we have observed their grace, grit, and determination. They are not fraudsters; they also want a system that is honorable and free of fraud and abuse.
In our most recent Survivorship Survey, Cancer Nation asked cancer survivors about their employment status and attitudes toward work. Most respondents said they either must work or want to work after diagnosis and during treatment. Those who cannot work are physically unable to do so, not unwilling. This week, the Centers for Medicare & Medicaid Services (CMS) issued an Interim Final Rule setting the standards for Medicaid expansion states to implement Medicaid work requirements. The rule would set an unreasonably burdensome standard for cancer survivors to prove they are medically frail and that their disease or condition prevents them from working. This standard is also unnecessary because cancer patients are not defrauding the system. Instead, they are working, if at all possible, out of necessity or preference.
The Interim Final Rule ignores the needs of people with cancer and other serious and complex illnesses and puts many of them at risk of losing their Medicaid coverage at a time when they need it most.
CMS established a definition of medical frailty that is at odds with states’ initial expectations and we believe at odds with the law. Under the rule, individuals would be required to prove that they are medically frail and then that their condition prevents them from working. In addition, self-declaration would be permitted only for one year.
Beginning in 2028, states would be limited in accepting self-attestation. At that time, people with cancer would be confronted with serious challenges of documenting their condition and inability to work. They would also be asking overburdened clinicians to assist them in the documentation effort instead of relying on their care teams for life-saving care.
Cancer care must be delivered without delay. We do not believe that policymakers intended work requirements to deprive cancer patients of the care they need because they lose Medicaid coverage or to force serious delays in care because of an overly burdensome documentation process.
We will be directing our attention and energy to explaining to policymakers the harm that the interim final rule may cause families, given that 1 in 3 American children with cancer and 1 in 10 Americans with cancer overall depend on Medicaid for their cancer care. We will also convey what we know – cancer patients are not defrauding the health care system. We look forward to changes in this rule that are responsive to the needs of people with cancer and other serious diseases and that give states more flexibility in implementing work requirements.
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