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.

Do Medicaid work requirements result in more people working?

No, Medicaid and SNAP work requirements do not result in more people working. This is due in large part to the fact that most people with Medicaid are either already working, would qualify for an exemption from a work requirement, or face various barriers to employment.¹

Medicaid work requirements result in fewer people with Medicaid, most of whom become uninsured after losing Medicaid. And they result in significant administrative expenses for a state's Medicaid program.²

Is there a federal Medicaid work requirement?

No, there has never been a federal Medicaid work requirement, and that's still true as of 2025. But a federal Medicaid work requirement is one of the possible ways Congress could reduce federal Medicaid spending.³ And significant federal Medicaid funding cuts would almost certainly be necessary to comply with the blueprint budget bill that Congress agreed upon in April 2025.⁴

Various federal bills introduced in early 2025 call for a nationwide work requirement for non-disabled adult Medicaid enrollees, but none had advanced out of committee by mid-April.⁵

According to a 2025 analysis by the Robert Wood Johnson Foundation, between 4.6 and 5.2 million adults in states that have expanded Medicaid would lose their coverage if a federal Medicaid work requirement were to be implemented for the Medicaid expansion population. Even though at least 91% of Medicaid expansion enrollees either have a job, are looking for a job, are students, are caring for family members, or are in fair/poor health or disabled, coverage losses would include some of those people due to failure to obtain exemptions or comply with reporting requirements.⁶

But the analysis notes that there is a lot of uncertainty given that no details had been put forth in terms of what eligibility groups might be subject to a work requirement, and what criteria would make a person eligible for an exemption. If a work requirement were to apply to other Medicaid populations in addition to the expansion group, the coverage losses would be considerably higher.

Do any states currently have Medicaid work requirements?

As of April 2025, Georgia is the only state in the country with a Medicaid work requirement. It took effect in July 2023, for people who want to enroll in the state's partial Medicaid expansion, which is called Georgia Pathways to Coverage. This program is available to adults under age 65 with household income below the poverty level, but only if they're working at least 80 hours per month and reporting their work to the state.

But by March 2025, nearly two years after the program began, only 7,000 people were enrolled in Georgia Pathways.⁷ This extremely low enrollment is due in large part to the work requirement and associated paperwork.⁸

The Trump administration approved Georgia's Medicaid work requirement in 2020, but the Biden administration subsequently revoked the approval. In 2022, however, 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, starting in mid-2023.

What states are considering new Medicaid work requirements?

Several states are considering Medicaid work requirements or moving forward with the process of seeking approval for them:

• Arkansas submitted a work requirement proposal, dubbed "Pathway to Prosperity" to the federal government in April 2025,¹¹ as an amendment to the state's existing Medicaid expansion waiver (ARHOME).¹² Notably, Arkansas was the only state that disenrolled people from Medicaid due to a work requirement implemented during the first Trump administration. As described below, about 18,000 people lost coverage in Arkansas in 2018 as a result of the state's short-lived work requirement.
  However, the Pathway to Prosperity waiver amendment proposal calls for a different work requirement approach, and notes that it "reflects lessons learned" from the 2018-2019 efforts to implement a Medicaid expansion work requirement. The new proposal calls for data matching to be used, instead of requiring enrollees to report information to the state. If data matching identifies the person as "not on track" to meet personal health and economic goals, the state will coordinate with the person's qualified health plan (QHP; Arkansas purchases private QHPs in the Marketplace to cover the Medicaid expansion population) to "provide focused care coordination services to eligible individuals," including "the establishment and monitoring of a Personal Development Plan (PDP)," with workforce development. If the person declines to participate, their QHP benefits will be suspended. They can restore their benefits by notifying the state that they intend to cooperate with the PDP requirements, but they will not need to complete a new Medicaid application unless their annual renewal date has passed.¹³
  Arkansas lawmakers passed legislation in April 2025 (not yet signed into law) that calls for an expansion of the available exemptions from the Medicaid work requirement.¹⁴
• Ohio submitted a work requirement proposal to the federal government in Feb. 2025,¹⁵ after accepting public comments on the proposal until January 21, 2025.¹⁶ This stems from the budget legislation the state enacted in 2023.¹⁷ (As described below, Ohio previously received approval for a work requirement, but it was never implemented.)
• South Carolina Governor Henry McMaster has asked the U.S. Department of Health & Human Services to work with South Carolina to help them reinstate the work requirement that was previously approved by the first Trump administration in 2019.¹⁸ Notably, South Carolina has not yet expanded Medicaid, so the only people enrolled in Medicaid in the state are (low-income) parents of minor children, pregnant women, children, disabled people, and elderly people.
• Kentucky lawmakers passed legislation in 2025 that calls for the state to seek federal approval for a Medicaid work requirement for non-disabled adults who have been enrolled in Medicaid for more than a year. The governor vetoed it, but the legislature overrode the veto in late March 2025, and the legislation was enacted.¹⁹ The legislation directs the state to submit a work requirement waiver proposal to the federal government within 90 days.
• South Dakota voters approved a ballot measure in 2024 that allows the South Dakota legislature to impose a work requirement for the Medicaid expansion population. The state would also need federal approval to implement a work requirement (either via federal legislation that creates a blanket approval, or a state-specific 1115 waiver).²⁰
• North Carolina expanded Medicaid eligibility in December 2023, under the terms of legislation enacted earlier that year. The 2023 legislation directs the state to seek federal approval for a work requirement in the future "if there is any indication that work requirements as a condition of participation in the Medicaid program may be authorized" by CMS.²¹ Under the second Trump administration, North Carolina may pursue a work requirement for its Medicaid expansion enrollees, and GOP lawmakers in the state have expressed interest in doing so. In addition, legislation specifically directing the state to seek federal approval for a Medicaid work requirement was introduced in the North Carolina legislature in March 2025.²²
• Indiana lawmakers passed legislation calling for a Medicaid work requirement in April 2025, although it had not yet been signed into law by mid-April.²³
• Montana lawmakers passed legislation in April 2025 (not yet signed into law) that would require a Medicaid expansion work requirement for those up to age 62,²⁴ as opposed to the current age-55 limit that exists in Montana statute but was never approved by the federal government.²⁵
• In Arizona,²⁶ New Hampshire,²⁷ Connecticut,²⁸ New York,²⁹ Iowa,³⁰ and Idaho,³¹ lawmakers are considering legislation in 2025 that would call for Medicaid work requirements, although there's varying support for those bills in their respective state legislatures.
  

Which states previously implemented Medicaid work requirements?

In addition to Georgia, five other states previously implemented Medicaid work requirements, although none of them are currently in effect. Arkansas, Indiana, Michigan, New Hampshire, and Utah implemented Medicaid work requirements between 2018 and 2020.

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. And in 2021, the Biden administration officially withdrew federal approval for all of the previously-approved Medicaid work requirement waivers.

How do states get approval for Medicaid work requirements?

Medicaid work requirements need approval from HHS under an 1115 waiver. Legislation introduced in Congress in September 2024 would have allowed states to implement Medicaid work requirements for adult enrollees who aren't pregnant, disabled, or elderly, without the need to obtain specific federal permission, although it did not advance.³² But until if and when this sort of legislation — including a budget-based legislative requirement designed to cut federal Medicaid funding via a work requirement — is enacted, a state has to obtain an approved 1115 waiver from CMS to implement a Medicaid work requirement.

The concept of a work requirement had previously been a non-starter throughout the Medicaid program’s history, but the first Trump administration encouraged states to submit waiver proposals for work requirements. Numerous states submitted waiver proposals. Ultimately, 13 states received approval from the first Trump administration to implement Medicaid work requirements for at least some of their adult Medicaid enrollees (see chart below).