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.
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. 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.)
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.
(As discussed below, Georgia plans to implement a Medicaid work requirement in mid-2023 to go along with the state’s new partial expansion of Medicaid.)
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.
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 in conjunction with a partial expansion of Medicaid.
States cannot disenroll anyone from Medicaid prior to April 2023, due to pandemic-related rules. But Georgia’s planned implementation of a work requirement is slated for mid-2023, after states resume regular Medicaid eligibility redeterminations and resulting disenrollments for people who are no longer eligible.
Notably, Georgia’s approved work requirement does not include an exemption for a person who is caring for a minor child. This could be changed before the program is implemented, and most of the other states that received approval for Medicaid work requirements did include such an exemption.
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.
