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Charlie Gagen:

Dear Interim Director Morris,

Thank you for the opportunity to provide comments on the proposed rule amendments implementing Medicaid work reporting requirements under H.R. 1. The American Lung Association represents thousands of patients and families with lung disease in Oklahoma and strongly supports policies that protect and expand access to quality, affordable healthcare coverage.

The implementation of H.R. 1 is estimated to result in approximately 110,000 people in Oklahoma losing Medicaid coverage. While we cannot shield all patients from the impact of these devastating cuts, the Lung Association and 38 other patient advocacy organizations have released principles for implementation of H.R. 1 at the state level to protect patients’ access to Medicaid as much as possible. These principles include strengthening eligibility and enrollment processes, broadly defining health-related exemptions for patients and caregivers, minimizing red tape, and conducting robust outreach to educate patients about new requirements.

For people with lung diseases, continuous coverage is essential. Patients cannot afford gaps due to extra paperwork and red tape. There will be real consequences if patients lose coverage or experience gaps in care. For example, people with COPD could experience exacerbations that do irreversible damage to their lungs, and people with lung cancer could face delays in treatment that decrease their chances of survival.

Careful implementation of H.R. 1 will be critical to ensure Oklahomans do not inappropriately lose their healthcare coverage. We appreciate that the state has elected to adopt a one-month lookback period, as well as the optional short-term hardship exemptions. However, a recent analysis by the Georgetown Center for Children and Families found that Oklahoma’s eligibility and enrollment systems already face significant administrative challenges and may be unprepared to deal with the new administrative hurdles required under H.R. 1. The report found that in the first quarter of 2025, Oklahoma ranked in the bottom quartile nationally for average call center wait times, with an average wait time of 18 minutes compared to the national average of 7 minutes. Long wait times mean enrollees and applicants who need assistance may have difficulty getting the help they need to stay enrolled.

Oklahoma also ranked poorly in overall renewal rate, ex parte renewals and disenrollment rate at renewal, indicating many people are losing coverage because of missing paperwork and other administrative barriers, not because they were actually ineligible for coverage. High rates of procedural disenrollments lead to churn and gaps in coverage, disrupting patients’ access to care while also increasing administrative costs for the state. Data shows that most people enrolled in Medicaid expansion coverage are already engaged in the kinds of activities required under the proposed rule. More than 90 percent of Medicaid expansion enrollees are currently working, studying, providing supportive care, or are ill or disabled. Improving data systems and ex parte renewals will help proactively identify eligible individuals who meet the requirements or qualify for an exemption and ensure they do not lose their healthcare coverage.

Moving forward, the Lung Association encourages Oklahoma to adopt a broad definition of medical frailty, as well as a comprehensive diagnostic code list that includes chronic lung diseases, nicotine dependence and tobacco use disorder, and accounts for episodic or acute health conditions such as severe asthma exacerbation that may require emergency treatment, hospitalization and recovery time. Finally, the Lung Association urges DHS to conduct proactive outreach and education to patients about policy changes and qualifying exemptions. This includes setting up robust, accessible consumer assistance support to help people navigate new requirements.

We appreciate the opportunity to provide comments on this proposed rule. As OHCA implements these new requirements, we urge the agency to prioritize policies that reduce administrative barriers, streamline eligibility and enrollment processes and prevent eligible Oklahomans from losing critical healthcare coverage. We remain committed to working with the OHCA to protect access to Medicaid for individuals with lung disease in the implementation of work reporting requirements and other elements of H.R. 1.

Sincerely,

Charlie Gagen

Director, Advocacy

American Lung Association

Kati Malincoate (Oklahoma Policy Institute):

We appreciate the opportunity to comment on the proposed rules for SoonerCare work requirements. While these requirements are federally mandated, Oklahoma has a responsibility to implement them in ways that minimize unnecessary coverage losses and protect access to health care.

Experience in other states has shown that work requirements can create significant administrative barriers, putting eligible individuals at risk of losing coverage simply because they struggle to navigate reporting requirements. With nearly 250,000 Oklahomans enrolled through Medicaid expansion, the state must take every available step to prevent unnecessary coverage losses.

We urge the Oklahoma Health Care Authority to prioritize three things.

First, maximize automatic verification. While we appreciate that OHCA has already identified this as a priority, it is critical that all administrative system changes are in place before work requirements take effect. Doing so will help minimize unnecessary paperwork and prevent eligible Oklahomans from experiencing avoidable disruptions in coverage.

Second, make exemptions accessible. Individuals with disabilities, chronic health conditions, caregiving responsibilities, and other qualifying circumstances must have clear, straightforward ways to establish their exemptions without burdensome documentation requirements.

Third, prioritize meaningful outreach and transparency. Notices should be easy to understand, available through multiple communication channels, and accompanied by accessible assistance. OHCA should also publicly report coverage losses, procedural terminations, and exemption determinations so policymakers can identify and address implementation problems.

We recognize the challenges OHCA faces in implementing these federal requirements, but urge the agency to prioritize policies and systems that minimize administrative burdens and prevent eligible Oklahomans from losing coverage. Meeting federal deadlines is only one part of successful implementation. The true measure of success will be whether Oklahoma can meet these requirements without creating unnecessary barriers to health care for the people who depend on it.

Thank you for your time and consideration.

Meske Owens:

I submit this comment in my individual capacity as a MATF member. I learned about this hearing without sufficient preparation time and am concerned that MATF members were not adequately engaged. Please document the notice provided to MATF, extend or reopen comments where legally permissible, and provide a dedicated opportunity for member input before final Board action.

More frequent renewals and shorter retroactive coverage make administrative errors more consequential. Please address the following:

1. PREVENT CLOSURES WHILE TIMELY DOCUMENTS AWAIT REVIEW.
   OHCA’s self-service page states that documents take at least 21 business days to process and acknowledges processing delays. How will OHCA ensure that a timely renewal is not closed while submitted documents await agency review? Distinguish the member’s submission deadline from the agency’s processing time. Check for pending submissions and unresolved agency tasks before closure, and apply all legally available protections to maintain coverage.

2. EXPLAIN THE CHANGE TO COVERAGE RESTORATION.
   The draft removes explicit language stating that benefits reopen effective on the closure date when an eligible member completes an unfinished renewal within 90 days. It substitutes a reference to applicable retroactive-eligibility requirements.

Does this change mean that an otherwise eligible person who completes renewal within that period could be left with unpaid medical bills or a gap in coverage? Please explain the legal basis, distinguish renewal reconsideration from a new application, and preserve coverage back to the closure date wherever federal law requires or permits it. Agency-caused errors and delays need a clear correction process.

3. USE EXISTING INFORMATION FIRST.
   Complete renewals using reliable information already available whenever possible. Do not repeatedly request documents OHCA already has. Provide practical income-verification options for self-employed people and people with fluctuating income, including those without a completed business tax return.

4. PROTECT MEMBERS ON DIFFERENT RENEWAL SCHEDULES.
   Ensure eligible American Indian and Alaska Native members retain annual renewals and that established status is not repeatedly reverified. Notices must clearly identify which household member needs to act and must not suggest that one adult’s renewal closes coverage for everyone.

5. EXPLAIN RETROACTIVE COVERAGE ACCURATELY.
   Clearly explain the shorter coverage periods, their effective dates, and how calendar months are counted. Do not describe one calendar month simply as 30 days. Explain that exemption from six-month renewals does not itself exempt someone from reduced retroactive coverage.

Provide application assistance during hospitalization, disability-related crises, and behavioral health emergencies. Explain how timely application dates are preserved during processing and how agency errors are corrected.

6. ACCOUNT FOR THE FULL COST.
   Compare preventing an avoidable closure with closing and reopening the same case. Include staffing, notices, postage, calls, appeals, and reprocessing. Separately assess medical debt, interrupted treatment, and costs shifted to providers and families.

Publish procedural closure and reinstatement data, including how many returning members remained eligible throughout. Please provide written responses identifying the safeguards OHCA will adopt and the legal basis for those it declines.