Biden Administration Should Withdraw All Approvals of Medicaid Work Requirements

The Trump Administration approved policies in 13 state demonstration projects (or “waivers”) that take Medicaid coverage away from people who don’t comply with stringent work requirements. Implementation of all these policies is on hold due to litigation and the pandemic. Taking coverage away from enrollees or otherwise conditioning coverage on meeting a work requirement doesn’t further Medicaid’s purposes — which demonstrations must do — and accordingly, the Biden Administration should now withdraw all of the previous approvals.

The Biden Administration recently withdrew Arkansas’ and New Hampshire’s authority to continue these policies. It had previously notified all states with work requirement policies that it was considering withdrawing their demonstration approvals based on evidence that these restrictive policies cause significant harm to Medicaid enrollees and because the COVID-19 pandemic has “greatly increased the risk” of unintended coverage loss. Georgia, Indiana, Nebraska, Ohio, South Carolina, and Utah have objected to the Administration’s planned action, but the Administration should nevertheless continue with its plan.

The Trump Administration claimed that requiring work or other activities as a condition of coverage would “improve beneficiaries’ health,” ignoring evidence from other programs suggesting these restrictions would significantly harm Medicaid enrollees. After states began implementing these policies, their experiences confirmed the harmful effects of work requirements.

The evidence shows that these policies are deeply harmful to Medicaid enrollees and confirms that they don’t promote Medicaid’s objectives, a new analysis from the Department of Health and Human Services Assistant Secretary for Planning and Evaluation confirms.

In Arkansas, where 18,000 enrollees lost coverage while the policy was in place, uninsurance rates among people subject to the work requirement rose, but their employment rates didn’t. Those who lost coverage were more likely to have chronic conditions, and many had difficulty paying their medical bills and accessing health care and medications. Data from New Hampshire and Michigan also show a significant loss of coverage would have occurred if the states’ work requirement policies had been implemented, largely due to enrollees’ limited awareness of the policies and challenges in reporting compliance.

The evidence of the detrimental impact of work requirements from Arkansas, New Hampshire, and Michigan demonstrates that other state policies would face the same challenges and harmful consequences. All policies that take away coverage from people not meeting work requirements are marred by complex rules about who is exempt and what activities count, challenges communicating with enrollees, and burdensome paperwork and reporting requirements. These policies inevitably lead to eligible enrollees losing coverage — work requirements can’t be fixed.

There’s nothing left to demonstrate by letting more states take risks with Medicaid enrollees’ health. The Centers for Medicare & Medicaid Services should withdraw all waiver authority for policies that take coverage away from people not meeting work requirements or otherwise condition coverage or benefits on meeting them and make clear that these policies won’t be allowed in Medicaid.