Medicaid Work Requirements



On January 11th, the Centers for Medicare & Medicaid Services (CMS), which is a part of the Department of Health and Human Services (HHS), issued new guidelines in a State Medicaid Director Letter allowing states to require certain individuals to work in order to qualify for Medicaid health insurance coverage.  

Under this new policy, “able-bodied” people will lose their health insurance if they do not work, seek employment, engage in training or similar activities, or if they simply fail to complete the processes required to document their work-related actions.

These work requirements will hurt people with disabilities. They are not about assisting individuals with finding employment opportunities. Instead, they will create barriers for people with disabilities trying to access Medicaid services, will further perpetuate the poverty cycle, and will lead to an increase in the uninsured population. 

Our biggest concerns with these guidelines:

  • Most nonelderly Medicaid adults are already working or face significant barriers to work. Of those that do not work, more than 1/3 are ill or disabled. [learn more here]
  • Who is considered “able-bodied” and what qualifies as a disability? Many people are too sick to work but have not met the formal definition of disabled. The way this guidance is written means that their Medicaid eligibility and compliance with the work requirements could differ by state.
  • Existing research has not made clear whether tying eligibility to work actually promotes health. While increased income or employment is associated with improved health outcomes, it is difficult to determine whether income and work lead to better health, or whether better health facilitates work and income.
  • It is unclear how states will help enrollees find jobs. It is also doubtful that they will address other barriers to employments, such as childcare, transportation, job skills, etc.
  • Working at minimum wage could make some people financially ineligible for Medicaid in certain states.
  • These policies could disproportionally impact family caregivers. The guidelines say that caregivers are exempt if they are caring for a “dependent.” However, the definition used for dependent is complicated for older adults, who are subjected to a seven-part test to qualify as a non-child dependent.
  • The new guidelines will create a complex documentation and administrative system where recipients must prove that they are in compliance with the work requirement or must obtain an exemption.
  • People with disabilities, especially cognitive and developmental disabilities, will have significant difficulties navigating these bureaucratic systems requiring them to constantly re-verify their disability status. This could end up leading to an unnecessary and avoidable loss of coverage for people with disabilities.
  • We already know from programs like SNAP and TANF that work requirements do not lead to increased employment.

What does this mean for your state?

CMS has already approved a work requirement waiver in one state: Kentucky [learn more here]

  • Nine other states have filed applications with CMS to add work requirements to their Medicaid programs: Arizona, Arkansas, Indiana, Kansas, Kentucky, Maine, New Hampshire, North Carolina, Utah, and Wisconsin
    • Other states, like Louisiana, have made it clear they intend to apply for the waiver or are considering doing so.

What Can You Do?

  • Call your Governor’s office and let them know that you oppose Medicaid work requirements.
    • Governors decide to submit the work requirement waivers. If you live in one of the 10 states where these waivers have been submitted or approved, call your Governor to tell them how disappointed you are.
    • If you live in a state that has not yet requested this waiver, urge your Governor to issue a statement explicitly saying that they will not pursue Medicaid work requirements.
  • Call your representatives and urge them to oppose Medicaid work requirements.
    • If your member of Congress already has opposed them, thank them for their support and ask them to remain vocal in their opposition.
  • CMS is required to hold a public comment period for each waiver that is requested. Make your voice heard and submit your comment today!

Resources on Work Requirements

Medicaid and Work Requirements: New Guidance, State Waiver Details and Key Issues, Kaiser Family Foundation 01/16/18

Trump’s Medicaid Work Requirements Could Put At Least 6.3 Million Americans at Risk of Losing Health Care, Center for American Progress 01/12/18

What Medicaid’s Work Requirement Means For Seniors, People With Disabilities, And Their Caregivers, Forbes 01/19/18

Medicaid ‘work requirements’ won’t improve health outcomes, The Hill 01/18/18


ASAN Statement on Medicaid Work Requirements (01/11/18)

CPSD & APSE Statement (02/08/18) 

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