Medicaid Work Requirements: What Happened under the Trump and Biden Administrations?

In a new brief, KFF analysts explain and summarize the recent history of efforts to make work requirements a condition of eligibility for Medicaid in some states. Following years of administrative, political, and legal activity across two presidential administrations, recent Supreme Court action and skepticism about work requirements by the Biden administration signals a pause in efforts to reshape state Medicaid programs in this fashion.

The Trump Administration opened the door to such efforts by approving Section 1115 demonstration waivers that imposed mandatory work and reporting requirements as a condition of Medicaid eligibility. However, courts struck down many of these approvals. And the Supreme Court recently dismissed pending challenges in these cases, in part due to the Biden Administration’s earlier withdrawals of approved work requirement waivers in several states. Georgia has challenged the withdrawal of its work requirements in court, and an initial decision in the Georgia case is still pending.

Although few Medicaid work and reporting requirements were implemented due to litigation, state withdrawals, and/or pauses during the COVID-19 pandemic, KFF analysts find that available implementation data from Arkansas suggests that these requirements are confusing to enrollees and result in substantial Medicaid coverage losses, including among eligible individuals.

Future presidential administrations could revisit these waiver provisions. However, to survive legal challenges, the federal administrative record in any future approvals would likely have to support the conclusion that such waivers would further Medicaid program objectives, including promoting affordable health coverage for low-income people, our experts conclude.

The full analysis, and other data and analyses about Medicaid work requirements, are available on the Medicaid topic page of kff.org.