Information on Medicaid Work Requirements (as of May 2022)

The Trump Administration aimed to reshape the Medicaid program by newly approving Section 1115 demonstration waivers that imposed work and reporting requirements as a condition of Medicaid eligibility. However, courts struck down many of these approvals and in April 2022 the Supreme Court dismissed pending challenges in these cases, in part due to the Biden Administration’s earlier withdrawals of work requirement waivers in all states that had approvals. Although CMS under the Biden Administration has not yet acted on any pending work requirement waivers (as of May 2022), it is expected to reject these requests. For additional context on the history of Medicaid work requirements and research on impacts of such requirements, see issue brief: An Overview of Medicaid Work Requirements: What Happened Under the Trump and Biden Administrations?

Of the 13 states that had approved work requirements, only Arkansas implemented such requirements with consequences for noncompliance. Other states that began implementation (Indiana and Utah) did not disenroll those who did not comply and instead paused implementation due to litigation and/or the COVID-19 pandemic. For state-level detail on approved work requirement waivers as well as additional requests that were not approved by the end of the Trump Administration, see Table 1 below. For more information on work requirement litigation across states, see Table 2 below. For current information on pending and approved work requirement provisions, see Eligibility/Enrollment Restrictions table on waiver tracker.

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