Medicaid work requirements during the Trump administrations

• Work requirements
  • Index of articles related to work requirements
  • Work requirements for public assistance in the states
  • Medicaid work requirements
  • Public housing work requirements
  • Supplemental Nutrition Assistance Program (SNAP) work requirements
  • Child care subsidy work requirements
• Major arguments
  • Arguments against work requirements for public assistance programs
  • Arguments in favor of work requirements for public assistance programs
• Reform proposals
  • Reform proposals related to Medicaid work requirements
  • Reform proposals related to Supplemental Nutrition Assistance Program work requirements
  • Reform proposals related to public housing work requirements
  • Reform proposals related to child care subsidy work requirements
• Laws
• Court cases
• Scholarly work
• Related federal agencies
  • Centers for Medicare and Medicaid Services
  • U.S. Department of Agriculture
  • U.S. Department of Housing and Urban Development

What are Medicaid work requirements?
Medicaid work requirements are policies that condition eligibility for Medicaid benefits on participation in work or related activities for certain adult enrollees. These activities may include employment, job training, education, or community service. In 2025, Congress passed the One Big Beautiful Bill Act (OBBBA), which created the first federally mandated Medicaid work requirements. The law requires states to implement a monthly 80-hour community engagement requirement for adults in the Affordable Care Act’s Medicaid expansion group by January 1, 2027, though states may apply for a good-faith delay until December 31, 2028. As of 2025, Georgia was the only state with an active state-level Medicaid work requirement.

Why does it matter?
Medicaid provides health coverage to more than 70 million low-income individuals and families. The enactment of a federal work requirement marks a major shift in how eligibility is determined—replacing a state-by-state waiver process with a national mandate. It highlights ongoing tensions between state autonomy and federal oversight of public assistance—raising questions about how much flexibility states should have in administering federally funded benefit programs. The policy has become a flashpoint between presidential administrations, with the first Trump administration encouraging state adoption and the Biden administration reversing course before Congress established a nationwide standard in 2025.

What is the background?
Before the enactment of the OBBBA in 2025, there were no federally mandated work requirements for Medicaid. States could only implement such policies by applying for a Section 1115 waiver from the Centers for Medicare and Medicaid Services (CMS). During the first Trump administration, 13 states received approval to implement work requirements, but most efforts were blocked by legal challenges. Courts in several states ruled that CMS had not adequately considered the risk of coverage loss, and the Biden administration later withdrew all 13 waivers. Georgia was the only state to successfully defend its waiver in court, and it implemented work requirements in 2023.

What are states doing?
Under the OBBBA, all states must implement work requirements by January 1, 2027, but may apply for early implementation or request a delay through 2029. As of October 7, 2025, seven states, Arizona, Arkansas, Iowa, Ohio, South Carolina, Utah, and Montana, had submitted waiver requests to CMS to implement Medicaid work requirements. Georgia remained the only state with an active Medicaid work requirement as of that date and had submitted a waiver renewal request to CMS.

What are the arguments?
Proponents of Medicaid work requirements argue that they improve recipient health, ensure benefits are reserved for the truly needy, and help reduce poverty by encouraging employment.

Opponents of Medicaid work requirements argue that they worsen health and employment outcomes, cause people to lose coverage due to administrative burdens, and make it harder for those truly in need to access care.

This page features information about Medicaid work requirements during the Trump administrations.

President Donald Trump's (R) first presidential term began on January 20, 2017, and ended on January 20, 2021. His second term began on January 20, 2025.

HIGHLIGHTS

CMS approved Medicaid work requirement waivers in 13 states during the Trump administration. Of these waivers, only Arkansas fully implemented its program before the Biden administration directed the agency to withdraw all approved waivers.

The 2025 budget reconciliation bill included Medicaid work requirements provisions and changes to the SNAP work requirements. The law requires states to adopt policies that require certain recipients to work or complete other work-related activities for 80 hours a month to maintain eligibility.

Background of Medicaid work requirements

See also: Centers for Medicare and Medicaid Services

Medicaid, established by the Social Security Act of 1965, is a nationwide program that provides health coverage for qualifying individuals. The program is jointly funded by the federal government and the states. The states manage Medicaid eligibility, benefits, and administration within federal guidelines.

Medicaid work requirements are mandated work-related activities that Medicaid recipients must complete to qualify for benefits, such as working, pursuing education, participating in a work program, or volunteer activities. As of 2025, Georgia was the only state with active Medicaid work requirements. The One Big Beautiful Bill Act, which was signed into law on July 4, 2025, requires states to implement a work requirement of at least 80 hours per month by January 1, 2027.

Section 1115 waivers

Section 1115 of the Social Security Act gives the secretary of Health and Human Services (HHS) authority to approve any "experimental, pilot, or demonstration project which, in the judgment of the Secretary, is likely to assist in promoting the objectives of public assistance programs in a State or States." The Centers for Medicare and Medicaid Services (CMS) performs a case-by-case review of Section 1115 applications to determine whether the stated goals are aligned with Medicaid objectives. State applications for Section 1115 waivers must be budget neutral to the federal government, meaning that a state’s experimental project cannot increase federal Medicaid expenditures.

Section 1115 waivers give states flexibility to design and improve programs by implementing state-specific policies to serve Medicaid recipients at the state level. Before the One Big Beautiful Bill Act (OBBB Act) mandated Medicaid work requirements for all states, Section 1115 waivers were the only way states could implement these requirements. The OBBB Act allows states to apply for Section 1115 waivers to implement work requirements for Medicaid ahead of the January 2027 deadline, but does not allow states to use these waivers to waive the work requirements.

CMS approved Medicaid work requirement waivers in 13 of the 22 states that applied during the first Trump administration. Of these waivers, only Arkansas fully implemented its program before the Biden administration directed the agency to withdraw all approved waivers. Georgia implemented Medicaid work requirements on July 1, 2023, through the Georgia Pathways program. Click here to learn more.

Medicaid work requirements during the Trump administrations

See also: Medicaid work requirements during the Biden administration

This section includes information on activities affecting Medicaid work requirements during the Trump administrations.

CMS approval of Medicaid work requirements during the first Trump administration (2017-2021)

HHS first approved state-based work requirement policies for Medicaid under Section 1115 of the Social Security Act during the Trump administration.

CMS in January 2018, issued guidance documents inviting states to request Section 1115 waivers to create work requirements, reporting requirements, and community engagement conditions for Medicaid eligibility for non-elderly, non-pregnant, adult beneficiaries without disabilities. CMS guidance documents stated that work requirement provisions would promote the objectives of Medicaid by assisting states "in their efforts to improve Medicaid enrollee health and well-being through incentivizing work and community engagement."

CMS approved Section 1115 waivers that conditioned Medicaid coverage on meeting work requirements and reporting requirements in the following 13 states from 2018 to 2020:

• Arizona
• Arkansas
• Georgia
• Indiana
• Kentucky
• Maine
• Michigan
• Nebraska
• New Hampshire
• Ohio
• South Carolina
• Utah
• Wisconsin

Medicaid work requirements in the One Big Beautiful Bill Act (2025)

See also: Work requirements policies in the 2025 budget reconciliation bill (One Big Beautiful Bill Act)

The 2025 budget reconciliation bill that was signed into law on July 4 requires states to adopt community engagement requirements for able-bodied adults without dependents in the Affordable Care Act’s Medicaid expansion group by January 1, 2027. These community engagement requirements can be met by doing any of the following for 80 hours a month:

• working,
• doing community service,
• participating in a work program, or
• doing a combination of these activities.

An individual could also meet the requirements by enrolling at least part-time in an educational program or by making a monthly income of at least 80 times the federal hourly minimum wage. Failure to comply with the community engagement requirement would result in the denial of an application for Medicaid or disenrollment from the program.

See also

• Arguments about work requirements for public assistance programs
• Court cases related to work requirements for public assistance programs
• Scholarly work related to work requirements for public assistance programs
• Work requirements policies in the 2025 budget reconciliation bill (One Big Beautiful Bill Act)

External links

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