Almost one-third of Arkansas Works beneficiaries who today hold a job may still fail to consistently meet the state’s new work requirements after the mandate goes into effect, according to a study released by the Urban Institute, a liberal-leaning think tank based in Washington D.C.

That’s because Arkansas Works — the Obamacare-funded expansion of Medicaid that now provides health insurance to some 280,000 low-income adults statewide — will soon define compliance as working for at least 80 hours each month for 10 months annually. For the working poor, however, jobs often come in fits and starts throughout the year. Among low-income, employed Arkansans who don’t meet an exemption from the work requirements, 32 percent of beneficiaries wouldn’t meet the 80 hour threshold for at least one month out of the year, the Urban Institute study suggests. That figure and others are derived from an analysis of 2016 data from the U.S. Census Bureau’s American Community Survey, or ACS.

Anuj Gangopadhyaya, the lead author of the study, explained that beneficiaries who “work in high turnover occupations or jobs with high seasonality could have their coverage jeopardized.”

The ACS data also indicates that “in the weeks that they work, they’re working way above the minimum threshold of 20 hours per week,” Gangopadhyaya added. “We found they’re averaging about 35 hours per week. So it’s not that they’re opting to not work; they’re working practically full time when they do have work. It’s more a matter of whether they have consistent work or not.”

Beneficiaries won’t lose coverage due to a single month of noncompliance. However, if a beneficiary fails to meet the requirement for any three months in a calendar year, he or she would not only lose coverage but also be locked out of the program for the remainder of the year, the Arkansas Department of Human Services has said. DHS won’t allow “surplus” hours accrued in one month to be applied to later months that same year. (Certain other activities, such as education, community service and substance abuse counseling, will also count toward the requirement.)

Yet most Arkansas Works recipients — a full three-quarters — will qualify for an exemption from the work requirement once it’s fully in effect, the study finds. That’s consistent with DHS’ own projected numbers.

“Arkansas actually has quite broad exemption criteria compared to other states trying to implement work requirements,” Gangopadhyaya said.

Kentucky, Indiana and New Hampshire have also received approval from the Trump administration to impose work requirements, though Arkansas will be the first to get its system off the ground. Arkansas beneficiaries can get an exemption if they are caring for a minor child or a disabled family member, if they attend school full-time, if they’re pregnant or suffer from a chronic medical condition or if they meet various other criteria. And crucially, the requirement only applies to those beneficiaries between ages 19 and 49. In 2018, it will only apply to the 30-49 age group; it will extend to 19- to 29-year-olds in 2019. (Some exemption categories will require regular verification from the beneficiary, so it’s unlikely everyone who qualifies for an exemption will receive one.)

The Urban Institute used the ACS data to sort non-elderly, non-disabled, adult Medicaid beneficiaries into three groups. Group 1 — by far the largest — is composed of those who qualify for an exemption, regardless of whether they are working. The study indicates that most of these beneficiaries are workers, too, though. About 47 percent reported being employed at the time they responded to the 2016 survey, and 58 percent said they worked 48 weeks or more in the previous year.

Group 2 is composed of those who don’t meet an exemption but who reported being employed at the time of the survey. It is members of this second group who could be in danger of losing coverage as they cycle in and out of employment, Gangopadhyaya said.

Group 3 is the cohort that work requirements in general seem to be targeting: those beneficiaries who appear to not qualify for an exemption yet who are also not working. The Urban Institute study cautions, however, that some exemption categories found in Arkansas — such as pregnancy — don’t show up in the ACS data and could not be modeled. The researchers estimated that about 17,000 enrollees, or 6 percent, would fall in Group 2 in 2018, and about 22,000 enrollees, or 8 percent, would fall in Group 3. Those numbers would rise to 31,000, or 12 percent, and 39,0000, or 15 percent, in 2019.

For this last group, the researchers focused on five potential barriers to employment: lack of internet access, lack of a vehicle, lack of a high school education, possessing a serious health limitation and living with a person with a serious health limitation. Among the Group 3 cohort, 78 percent met one of these five criteria. Lacking internet access or transportation makes it “more difficult … to obtain employment, participate in other work-related activities, meet with caseworkers [and] otherwise receive assistance to obtain exemptions,” the report notes.

Gangopadhyaya said the lack of internet access is particularly a problem because Arkansas will require beneficiaries to use the internet to report their work hours. Reporting by mail or phone will not be allowed, DHS Director Cindy Gillespie said in March. Instead, beneficiaries will be required to create an account via a web portal and log their hours each month. “Our goal, long range, is hopefully to begin to move to where more and more communication between us and all of our Medicaid population can take place online,” Gillespie said at the time.

Yet the Urban Institute study found 31 percent of those people in Group 3 had no home internet access in 2016. Among those beneficiaries who were working and were not exempt — that is, those in Group 2 — 25 percent did not have internet at home. Over half of both groups lacked broadband access.

The online-only requirement, Gangopadhyaya said, is “a curious thing to do in Arkansas, which has the second-lowest internet access [rate] in the entire nation.” The other states implementing a work requirement have no such restriction.

This reporting is made possible in part by a yearlong fellowship sponsored by the Association of Health Care Journalists and supported by The Commonwealth Fund.

This reporting is courtesy of the Arkansas Nonprofit News Network, an independent, nonpartisan project dedicated to producing journalism that matters to Arkansans.