Official Written Public Comments Submitted for Georgia Pathways Waiver Application
February 20, 2025
VIA Electronic Mail: Pathways.Comments25@dch.ga.gov
Ms. Walker: In response to the virtual meeting host’s feedback during the Georgia Pathways Public Hearing #2, regarding potential challenges with oral comments (i.e. oral speed and the need to speak slowly) captured by the court reporter transcribing the hearing, we are providing the written comments below in support of the summary-level public comments provided during the February 10, 2025 hearing. If DCH or CMS prohibits duplicate submissions, please accept my transcribed oral comments and disregard this written submission. If not prohibited, I am requesting my official written comments be included in the public record. Thank you.
My name is Natalie Crawford, Founder and Executive Director of Georgia First, a Georgia-based 501(c)(4) nonprofit think tank and policy advocacy organization. One of our three policy priorities is ensuring access to quality, affordable healthcare. In 2023, I established the BRIDGE Georgia healthcare coalition to advocate for closing Georgia’s health insurance coverage gap. Currently, nearly 300,000 Georgians fall in the gap, earning too much for traditional Medicaid but too little to afford private insurance through the open marketplace with Georgia Access. Additionally, these Georgians face barriers to enrollment in the Georgia Pathways Program.
Expanding Georgia’s Medicaid eligibility to 138% of the federal poverty level (FPL), as 40 other states and D.C. have done, is essential for strengthening Georgia’s middle class and economy. Georgia First is disappointed that Georgia’s current 1115 Medicaid waiver application does not include this expansion, despite its cost-effectiveness compared to Pathways at full enrollment. Georgia Pathways remains inefficient, with high administrative and consulting costs.
The Pathways program provides limited Medicaid expansion with work and activity requirements but suffers from low projected enrollment, excessive bureaucracy, and high administrative expenses. A 2024 economic impact study by REMI, commissioned by a BRIDGE Georgia coalition member, projected that full expansion would create over 150,000 jobs within three years, increase economic output by $9.4 billion annually, boost GDP by $5.5 billion per year, and raise Georgians’ aggregate personal income by $3.6 billion annually.
Georgia consistently ranks among the top five states annually for highest uninsured rates, with more than 1.2 million uninsured residents. Over 800,000 Georgians currently receive fully subsidized premiums through Georgia Access marketplace tax credits, but these federal Enhanced Premium Tax Credits (EPTCs) are set to expire in 2025. Without renewal, Georgia’s uninsured rate will increase.
We support the current Pathways waiver application expansion of eligibility to parents and legal guardians of young children (ages 0-6), supporting growing families. However, this does not fully address the 300,000 Georgians left in the coverage gap, including farmers, veterans, older adults (60-64 years), gig workers, and caregivers for family members with chronic illnesses or disabilities. If federal healthcare EPTCs expire, even more Georgians will fall into this gap.
Pathways initially projected 30,000 enrollees in its first year but had only 6,500 by July 2024. Revised estimates now suggest only 30,000 enrollees by 2030—six years after initial implementation.
Georgia First acknowledges the programmatic impacts, including delayed implementation, caused by the litigation between the federal government. However, Georgia taxpayers continue to bear the cost of a hyper partisan healthcare debate, paying with their personal health impacts and their tax dollars going to fund Medicaid expansion in the 40 states and D.C. that have already adopted the 138% FPL threshold. It’s time to prioritize people over politics and make sound fiscal decisions that maximize public benefit.
- Without full expansion, Georgia First recommends key reforms to improve Pathways’ efficiency, reduce bureaucracy, and support family caregivers:
- Expand work exemptions to include caregivers of any child, elderly, or disabled relative—not just children under six.
- Reduce reporting burdens, cut government red tape, and maximize tax dollars by replacing monthly activity verification with annual certification and allowing enrollees to report annualized qualifying hours.
- Expand auto-enrollment for eligible populations, including automatic transition to Pathways for postpartum Medicaid recipients and low-income caregivers above 35% FPL, and by using SNAP, TANF, or workforce program data for auto-enrollment.
- Support older workers (ages 60-64) by exempting them from qualifying activity requirements, recognizing their employment barriers.
Expanding Medicaid without unnecessary restrictions is a strategic investment in Georgia’s healthcare system, workforce, and economy. We cannot continue applying short-term fixes to a long-term problem. It is time to close Georgia’s healthcare coverage gap and fully utilize available federal tax dollars, regardless of anticipated or future changes to Medicaid under a new administration.
Thank you for the opportunity to provide public comment at today’s final hearing.
Sincerely,
Natalie Crawford, Executive Director Georgia First
0 Comments