Comment Opposing the Georgia Department of Community Health’s Proposed Medicaid Waiver Plans

On December 3, 2019, NAPAWF submitted a comment to the Georgia Department of Community Health (DCH) opposing proposed 1115 and 1332 Medicaid waivers and advocating for full Medicaid expansion. Both of these proposed waivers would be inadequate to cover the needs of Georgians. The waivers would expend $215 million to cover only 80,000 Georgians, while full Medicaid expansion would expend $213 million to cover 490,000 Georgians.

Additionally, the 1115 waiver would impose work and reporting requirements on Medicaid beneficiaries. In our comment, we highlighted the impact this would have on AAPI communities. Medicaid work requirements disproportionately harm communities of color, who are more likely to face long-term unemployment and thus will struggle to meet these standards. Additionally, the burdensome documentation requirements to demonstrate participation in qualifying activities will be harder to meet for individuals with limited English proficiency, those working in informal jobs, and those who work as caretakers, disproportionately impacting AAPI communities.

We also commented on harm to AAPI communities of numerous aspects of the 1332 waiver, including its elimination of the requirement that insurers cover mental health services in the same way as physical health services. Mental health coverage is vital to AAPI communities, who already face challenges such as language access, lack of cultural competency among service providers, and the stigma of the model minority myth in accessing mental health services.