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5 Facts About Medicaid Work Requirements

Medicaid work reporting requirements do not promote employment; they create red tape that takes health care away from eligible people, leaving them uninsured.

A hospital employee gives a tour of a patient room in Hugo, Colorado.
A hospital employee gives a tour of a patient room in Hugo, Colorado, on October 23, 2024. (Getty/The Denver Post/AAron Ontiveroz)

Congressional Republicans are once again pushing Medicaid work reporting requirements, this time as part of broader efforts to reduce federal Medicaid spending. As Congress decides on a budget reconciliation package that would amount to the largest cut to Medicaid in the program’s history, work reporting requirements have reemerged as a strategy to reduce enrollment without explicitly cutting eligibility or benefits.

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Conservative lawmakers and the first Trump administration have positioned work reporting requirements as a way to encourage employment and self-sufficiency, but every implementation attempt has found them to be a complete policy failure. Evidence from states shows work reporting requirements do nothing to help people with Medicaid find jobs, access training, or overcome barriers to employment. Instead, they create numerous bureaucratic obstacles that are expensive and cumbersome for the government to administer and that disproportionately harm the very people Medicaid serves. By requiring enrollees to regularly report their work hours or qualifying activities, often through unreliable digital systems or complicated paperwork, these policies primarily cause eligible people to lose coverage simply because they cannot make it through the red tape.

As Congress debates how to achieve the historically large Medicaid spending cuts called for by congressional Republicans, it is essential that policymakers understand what work reporting requirements do and the consequences they have for low-income people and families. Below are five key facts policymakers should know.

1. Medicaid work reporting requirements are unnecessary, as nearly every Medicaid enrollee who can work does

KFF reported that 92 percent of nondisabled Medicaid enrollees under the age of 65 were already employed in 2023, making work reporting requirements at best redundant. Working Medicaid enrollees are most likely employed in the manufacturing, agriculture, service, and health industries, largely working low-wage, seasonal, or hourly jobs that either don’t offer employer-sponsored health insurance or offer coverage that is unaffordable on a limited income. Medicaid is an insurance lifeline for these workers that actually supports employment by providing the health coverage people need to stay well and work.

2. Medicaid work reporting requirements are paperwork requirements, not actual work requirements

“Work requirement” policies do not mandate employment; instead, they are work reporting requirements that force people to regularly prove that they are already working or completing other approved activities, such as job training or volunteering to maintain their Medicaid coverage. To comply, individuals must log into online systems, upload documents, or respond to notices under tight deadlines. In practice, work requirements only measure a person’s ability to navigate administrative red tape, not whether they are actually working or looking for a job.

Work requirements only measure a person’s ability to navigate administrative red tape, not whether they are actually working or looking for a job.

The consequences of not being able to cut through the red tape can be significant; failing to meet a deadline or submitting paperwork incorrectly can lead to an automatic loss of coverage. For example, when Arkansas became the first state to implement Medicaid work reporting requirements in 2018, more than 18,000 people lost their Medicaid coverage within seven months. That represents 1 in every 4 individuals who were subject to the requirement. By 2019, only 11 percent of those who lost their coverage had managed to regain it. Accordingly, in March of that year, a U.S. District Court in the District of Columbia ruling blocked Arkansas’ work requirement on the basis that adding work requirements did not advance Medicaid’s purpose of providing coverage.

3. Medicaid work reporting requirements save money only by kicking people off coverage for which they are eligible

The work reporting requirements being considered by Republicans in Congress would not reduce federal Medicaid expenses by improving health outcomes or even spurring more people into the workforce. If the true intent behind work reporting requirements were to move all eligible Medicaid enrollees into the workforce, and if those requirements were actually effective in doing so, they wouldn’t produce any federal savings at all. Work requirements “save” money only by cutting otherwise eligible people from the program. A 2019 New England Journal of Medicine study found that more than 95 percent of Arkansans who lost Medicaid coverage either already met the work reporting requirement or should have qualified for an exemption, meaning their disenrollment was not due to ineligibility or failure to work.

15,400

Avoidable deaths each year that would result from coverage losses due to work reporting requirements

According to the Urban Institute, implementing federal work reporting requirements for Medicaid expansion enrollees ages 19 to 55 could result in 4.6 million to 5.2 million people losing coverage. These cuts would come with significant real-world costs—more barriers to care, increased financial burdens on hospitals and providers, and massive budget holes for states to fill. In addition to the economic consequences, the human toll would be severe: The Center for American Progress estimates that coverage losses from work reporting requirements would lead to roughly 15,400 avoidable deaths each year.

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4. The federal government has found that Medicaid work reporting requirements conflict with Medicaid’s purpose

Federal policymakers and oversight bodies have raised serious concerns about the harms of Medicaid work reporting requirements. Citing Arkansas’ implementation experience, the U.S. Department of Health and Human Services’ (HHS) Office of the General Counsel (OGC) went as far as issuing an advisory opinion in 2024 that concluded that imposing work requirements is fundamentally inconsistent with Medicaid’s core mission of providing health coverage to those who qualify and, therefore, HHS lacks the authority to implement them. The OGC emphasized that tying coverage to employment creates barriers that prevent eligible individuals from accessing care, undermining the very purpose of the program.

5. Medicaid work reporting requirements waste millions of taxpayers dollars

States that have attempted to implement Medicaid work reporting requirements have spent millions of dollars to operationalize them, with little to show for those investments. In 2024, Georgia reportedly spent more than $86 million to administer its work requirement-based Medicaid waiver: Georgia Pathways to Coverage. Yet by 2025, only 7,000 out of an estimated 345,000 eligible people had been able to enroll in the program. Furthermore, a ProPublica investigation found that three-quarters of that $86 million went to private consultants, including more than $50 million to Deloitte, for developing eligibility and reporting systems. According to a 2019 Government Accountability Office report, the projected costs of implementing work reporting requirements were also more than $270 million in Kentucky and $69 million in Wisconsin, with the federal government expected to fund 87 percent and 55 percent of those costs, respectively.

These examples underscore how work requirements generate administrative waste without expanding access to care.

See also

Several states are pursuing Medicaid work reporting requirements

Alongside federal efforts to impose work reporting requirements on Medicaid enrollees, several states are advancing their own proposals to do so through federal waiver applications and state legislation.

Since January 2025, Arizona, Arkansas, and Ohio have submitted Section 1115 waiver applications to the Centers for Medicare and Medicaid Services seeking approval to implement work reporting requirements for their Medicaid expansion populations. And in a letter to HHS, South Carolina outlined plans to pursue a Section 1115 waiver for a limited Medicaid expansion to parents earning up to 100 percent of the federal poverty level—tied to work requirements and requested expedited application review. Meanwhile, Idaho, Kentucky, and Indiana passed legislation this state legislative session that would impose work or community engagement requirements for Medicaid enrollees.

As more states pursue these harmful policies, millions of low-income individuals risk losing Medicaid coverage.

Conclusion

Medicaid work reporting requirements do not promote work. Rather, they erect barriers to care at significant taxpayer expense, resulting in significant coverage losses that jeopardize the health and financial security of Medicaid enrollees who are already working. Indeed, the only way for work reporting requirements to deliver Medicaid savings is by kicking people off the program. Instead of imposing burdensome paperwork requirements and bureaucratic hurdles on low-income people, policymakers should focus on strengthening the Medicaid program.

The positions of American Progress, and our policy experts, are independent, and the findings and conclusions presented are those of American Progress alone. American Progress would like to acknowledge the many generous supporters who make our work possible.

Author

Natasha Murphy

Director, Health Policy

Team

Health Policy

The Health Policy team advances health coverage, health care access and affordability, public health and equity, social determinants of health, and quality and efficiency in health care payment and delivery.

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