Virginia’s COMPASS Program: A Misguided Solution

This is part of TCI’s report: Virginia COMPASS Program Leading State Down The Wrong Path for Health Care

Virginia is in advanced negotiations with CMS to implement what the state is calling the “Creating Opportunities for Medicaid Participants to Achieve Self-Sufficiency” (COMPASS) program. COMPASS will require some people enrolled in Medicaid between the ages of 19 and 64 to eventually work, volunteer, or engage in other work related activities for 80 hours each month. The program also requires enrollees over 100% of the federal poverty limit ($12,490 for an individual) to make monthly premium payments of either $5 or $10 based on income.¹ People can apply for exemptions to avoid being subject to the work reporting requirement, including being the primary caregiver to a child under age 19, being medically frail, individuals with serious mental illness, or those qualifying for a temporary hardship exemption.²

The reporting and exemption processes alone may be confusing and burdensome. As witnessed in Arkansas, these factors will inevitably lead to people losing coverage even if they are meeting the hourly work threshold or should otherwise be exempt from reporting.³ This coverage loss could lead to avoiding preventative care, relying on emergency room visits, and ultimately burdensome medical debt for families with low incomes. A work reporting requirement would jeopardize both the health and financial security of families across Virginia.

According to the 1115 waiver application for COMPASS, if enrollees do not report the minimum hours required for any three months out of a 12-month period, they will have their health coverage suspended. Enrollees can also be suspended for failing to pay monthly premiums following a three-month grace period. Suspended enrollees may be able to enroll again if they are able to demonstrate compliance for one month, qualify for an exemption, or once the 12-month period of the enrollee’s coverage ends.⁴ However, data from Arkansas indicates that once people lose coverage due to not meeting the work reporting or premium requirement, the overwhelming majority (89%) did not re-enroll once they became eligible again.⁵

While there are some positive components of the COMPASS program, including housing and job supports, the waiver makes clear that these “may be contingent on the appropriation of additional State funding by the State Legislature.”⁶ So far, lawmakers have been resistant to the idea of appropriating additional state dollars for the COMPASS program and some have suggested the program should continue even without new employment supports. This suggests a strong likelihood that supportive features of the program will be under-resourced or not resourced at all.