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Medicaid work requirement

What is a Medicaid work requirement?

A Medicaid work requirement is a provision that requires certain Medicaid enrollees to participate in “community engagement” activities (work, school, job training, volunteering, etc.) in order to maintain their health coverage.

Numerous states submitted proposals for Medicaid work requirements

Medicaid work requirements need approval from HHS under an 1115 waiver. This idea had previously been a non-starter throughout the Medicaid program’s history, but the Trump administration encouraged states to submit waiver proposals for work requirements.

Numerous states submitted waiver proposals; you can read more about their proposals here. Ultimately, 13 states received approval from the Trump administration to implement Medicaid work requirements for at least some of their adult Medicaid enrollees.

In some states, the work requirement was designed to apply just to Medicaid expansion enrollees, whereas other states had broader rules. (There were fairly universal exemptions for certain populations, such as pregnant people, older adults, disabled people, etc.)

Only five states actually implemented work requirements

But in most of those states, the work requirements were either overturned by a judge or suspended by the state before they took effect. Only five states actually implemented Medicaid work requirements: Arkansas, Indiana, Michigan, New Hampshire, and Utah.

And Arkansas was the only state in which people lost their coverage as a result of the work requirement. In the other four states where work requirements did become effective, they weren’t in effect long enough to result in coverage losses.

Utah and Michigan were the only states where Medicaid work requirements were in effect as of early 2020, and both had suspended their work requirements by the spring of 2020. (In Michigan, this was due to a court ruling; in Utah, it was due to the COVID pandemic.)

No Medicaid work requirements are currently in effect

There have not been any Medicaid work requirements in effect anywhere in the country since the spring of 2020. And in 2021, the Biden administration officially withdrew federal approval for all of the previously-approved Medicaid work requirement waivers.

In 2022, a U.S. District Judge ruled that HHS acted in an “arbitrary and capricious” manner when they revoked Georgia’s Medicaid work requirement approval, thus clearing the way for Georgia to implement its Medicaid work requirement (once the COVID public health emergency ends; states cannot disenroll anyone from Medicaid during the public health emergency). Georgia had planned to partially expand Medicaid along with the work requirement; without it, the state does not plan to expand Medicaid at all, so the judge noted that Medicaid enrollment would likely be higher with the work requirement and partial expansion in place. HHS is expected to appeal. 

States that received waiver approval
for Medicaid work requirements

StateYear approvedYear implementedAdditional commentsCurrent statusState expanded Medicaid?
Arizona2019N/ADelayed by state; never took effectApproval withdrawn by HHS (June 2021)Yes
Arkansas20182018Overturned by a judge in 2019, after 18,000 people lost coverageApproval withdrawn by HHS (March 2021)Yes
Georgia2020N/AGeorgia sued HHS after approval was revoked, and a U.S.  district judge sided with the state in August 2022. HHS is expected to appeal.Approval withdrawn by HHS (December 2021), but that was overturned by a judge in 2022No (but work requirement would include partial Medicaid expansion)
Indiana2018Phased in throughout 2018Coverage losses would have started at end of 2019 but state suspended the program in November 2019Approval withdrawn by HHS (June 2021)Yes
Kentucky2018N/A (halted twice by a court, both times shortly before it was to take effect)Gov. Beshear withdrew work requirement waiver in late 2019 soon after taking officeWithdrawn by the stateYes
Maine2018N/AGov. Mills withdrew waiver soon after taking officeWithdrawn by the state (2019)Yes
Michigan20182020 (no coverage losses, as it was only in effect briefly)Overturned by judge (March 2020)Approval withdrawn by HHS (April 2021)Yes
Nebraska2020N/AWork requirement wouldn’t have been a condition of eligibility. Instead, it would have granted additional benefits (dental, vision, OTC medications) to Medicaid expansion enrollees.Withdrawn by the stateYes
New Hampshire20182019 (no coverage losses as it was in effect briefly)Overturned by court in March 2020Approval withdrawn by HHS (April 2021)Yes
Ohio2019Implementation delayed due to COVIDOverturned by a judge in March 2020Approval withdrawn by HHS (August 2021)Yes
South Carolina2019N/AImplementation delayed due to COVIDApproval withdrawn by HHS (August 2021)No
Utah20192020 (no coverage losses, as implementation was briefSuspended by state in April 2020 due to COVID. Utah was the last state to have a work requirement in effect.Approval withdrawn by HHS (August 2021)Yes
VirginiaN/AN/ADelayed by the state a month before HHS approved the waiver in 2019.Withdrawn by state (2020)Yes
Wisconsin2018N/AImplementation delayed due to COVIDApproval withdrawn by HHS (April 2021)No

Several other states (Idaho, Mississippi, South Dakota, North Carolina, Alabama, Tennessee, and Oklahoma) had submitted Medicaid work requirement waiver proposals to HHS under the Trump administration, but they were still pending when President Biden took office and were never approved.

You can select a state on this map to learn more about its Medicaid program.

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