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.
A dozen 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, a dozen 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.
States that received waiver approval
|State||Year approved||Year implemented||Additional comments||Current status||State expanded Medicaid?|
|Arizona||2019||N/A||Delayed by state; never took effect||Approval withdrawn by HHS (June 2021)||Yes|
|Arkansas||2018||2018||Overturned by a judge in 2019, after 18,000 people lost coverage||Approval withdrawn by HHS (March 2021)||Yes|
|Indiana||2018||Phased in throughout 2018||Coverage losses would have started at end of 2019 but state suspended the program in November 2019||Approval withdrawn by HHS (June 2021)||Yes|
|Kentucky||2018||N/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 office||Withdrawn by the state||Yes|
|Maine||2018||N/A||Gov. Mills withdrew waiver soon after taking office||Withdrawn by the state (2019)||Yes|
|Michigan||2018||2020 (no coverage losses, as it was only in effect briefly)||Overturned by judge (March 2020)||Approval withdrawn by HHS (April 2021)||Yes|
|Nebraska||2020||N/A||Work 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 state||Yes|
|New Hampshire||2018||2019 (no coverage losses as it was in effect briefly)||Overturned by court in March 2020||Approval withdrawn by HHS (April 2021)||Yes|
|Ohio||2019||Implementation delayed due to COVID||Overturned by a judge in March 2020||Approval withdrawn by HHS (August 2021)||Yes|
|South Carolina||2019||N/A||Implementation delayed due to COVID||Approval withdrawn by HHS (August 2021)||No|
|Utah||2019||2020 (no coverage losses, as implementation was brief||Suspended 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|
|Virginia||N/A||N/A||Delayed by the state a month before HHS approved the waiver in 2019.||Withdrawn by state (2020)||Yes|
|Wisconsin||2018||N/A||Implementation delayed due to COVID||Approval withdrawn by HHS (April 2021)||No|
Several other states (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.
How the Affordable Care Act's subsidies are calculated, and who is eligible to receive them under the American Rescue Plan.