Medicaid work requirements in the states

• 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

See also: Medicaid work requirements

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.

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 in the states. Georgia was the only state with an effective Medicaid work requirement as of October 2025.

Background

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 under Section 1115 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.

State Medicaid work requirement policies

Before the One Big Beautiful Bill Act (OBBB Act) was enacted on July 4, 2025, states could only implement Medicaid work requirements by obtaining a Section 1115 waiver. As of 2025, Georgia was the only state with active work requirements or an approved Section 1115 waiver.

The OBBB Act requires states to implement Medicaid work requirements by January 2027. The act allows states to apply for Section 1115 waivers in order to implement work requirements prior to this deadline, but does not allow states to use this type of waiver to waive the work requirements.

The following table features past and current information about state activity related to Medicaid work requirements, including links to Section 1115 waivers.

State Medicaid work requirements
State	Work requirement	Section 1115 waivers	Status
Alabama	No work requirement
Alaska	No work requirement
Arizona	No work requirement	Arizona Section 1115 Waiver Amendment Request AHCCCS Works (2025) Arizona Section 1115 Waiver Amendment Request (2018)	Submitted (2025), Withdrawn (2019)
Arkansas	No work requirement	Pathway to Prosperity Section 1115 Waiver Request (2025) Arkansas Works Eligibility and Enrollment Monitoring Plan (2018)	Submitted (2025), Withdrawn (2019)
California	No work requirement
Colorado	No work requirement
Connecticut	No work requirement
Delaware	No work requirement
Florida	No work requirement
Georgia	80 hours per month	Georgia Pathways to Coverage	Renewed (2025), Approved 2022
Hawaii	No work requirement
Idaho	No work requirement
Illinois	No work requirement
Indiana	No work requirement	Health Indian Plan Seciotn 115 Demonstration Waiver Amendment to Extentions	Withdrawn (2019)
Iowa	No work requirement	Iowa Health and Wellness Plan (2025)	Submitted (2025)
Kansas	No work requirement
Kentucky	No work requirement	Kentucky Health (Helping to Engage and Achieve Long Term Health	Withdrawn (2019)
Louisiana	No work requirement
Maine	No work requirement	MaineCare 1115 Demonstration Project Application	Withdrawn (2019)
Maryland	No work requirement
Massachusetts	No work requirement
Michigan	No work requirement	Healthy Michigan Plan: Medicaid Section 1115 Eligibility and Coverage Demonstration Monitoring Report	Withdrawn (2020)
Minnesota	No work requirement
Mississippi	No work requirement
Missouri	No work requirement
Montana	No work requirement	Health and Economic Livelihood Partnership (HELP) Section 1115 Demonstration Waiver Application - Public notice version	Submitted (2025)
Nebraska	No work requirement	Nebraska Medicaid Section 1115 Heritage Health Adult Expansion Demonstration	Terminated (2021)
Nevada	No work requirement
New Hampshire	No work requirement	New Hampshire Health Protection Program (NHHPP) demonstration waiver	Withdrawn (2019)
New Jersey	No work requirement
New Mexico	No work requirement
New York	No work requirement
North Carolina	No work requirement
North Dakota	No work requirement
Ohio	No work requirement	Group VIII 1115 Demonstration Waiver (2025) Ohio Group VIII Work Requirement and Community Engagement Section 1115 Demonstration (2018)	Submitted (2025), Withdrawn (2021)
Oklahoma	No work requirement
Oregon	No work requirement
Pennsylvania	No work requirement
Rhode Island	No work requirement
South Carolina	No work requirement	Palmetto Pathways to Independence Demonstration Waiver (2025) South Carolina Palmetto Pathways to Independence (2019)	Submitted (2025) Withdrawn (2021)
South Dakota	No work requirement	South Dakota Career Link 1115 Waiver Application	Withdrawn (2025)
Tennessee	No work requirement
Texas	No work requirement
Utah	No work requirement	State of Utah Section 1115 Demonstration Amendment Community Engagement (2025) Utah Medicaid Reform 1115 Demonstration; formerly “Utah Primary Care Network”(2019)	Submitted (2025) Withdrawn (2021)
Vermont	No work requirement
Virginia	No work requirement
Washington	No work requirement
West Virginia	No work requirement
Wisconsin	No work requirement	BadgerCare Reform Demonstration Project 1115 Waiver Extension Application	Withdrawn (2021)
Wyoming	No work requirement

State section 1115 governing Medicaid work requirements

This section below features selected text from effective Section 1115 waivers governing state work requirement policies for Medicaid.

Georgia

Georgia "Pathways to Coverage" section 1115 demonstration waiver application

“

In order to be eligible for coverage under Georgia Pathways, an individual must meet an hours and activities threshold of 80 hours per month of engagement in a qualifying activity (or combination of activities) such as employment, community service, or education, and have an income up to 100% of FPL.

”

Noteworthy events

Noteworthy events at the federal level

This section provides an overview of noteworthy events related to Medicaid work requirements at the federal level.

Federal noteworthy events

Medicaid work requirement provisions included in the One Big Beautiful Bill Act (2025): 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.

Robert F. Kennedy Jr., Mehmet Oz, Brooke Rollins, and Scott Turner on work requirements for public assistance programs (2025): Secretary of Health and Human Services Robert F. Kennedy Jr., Administrator of the Centers for Medicare & Medicaid Services, Mehmet Oz, Secretary of Agriculture Brooke Rollins, and Secretary of Housing and Urban Development Scott Turner cowrote a New York Times opinion piece, that was published on May 14, 2025. The secretaries and administrator expressed their opinions on work requirements for public assistance and support for a 20 hour/week work requirement across programs.

They wrote:

“

Establishing universal work requirements for able-bodied adults across the welfare programs we manage will prioritize the vulnerable, empower able-bodied individuals, help rebuild thriving communities and protect the taxpayers.

”

“

Our agencies are united in a very straightforward policy approach: Able-bodied adults receiving benefits must work, participate in job training or volunteer in their communities at least 20 hours a week. Limited exceptions will be made for good cause, like caring for young children and health issues, but the principle is clear — those who can work, should.

”

Medicaid work requirements proposal included in debt ceiling bill (2023):The U.S. House of Representatives on April 26, 2023, voted 219-210 to pass H.R. 2811, the Limit, Save, Grow Act of 2023, which aims to raise the federal government’s debt ceiling and includes provisions related to work requirements for certain able-bodied adults receiving Medicaid, Temporary Assistance for Needy Families (TANF) and Supplemental Nutrition Assistance Program (SNAP) assistance.

The proposal would require applicable Medicaid and SNAP recipients to complete 80 hours a month of community engagement or work-related activity. Applicable individuals under the proposal generally include adults between the ages of 19 and 55 who are physically able to work, not pregnant, and not serving as a caregiver to a dependent or incapacitated person. The proposal also includes provisions aimed at reducing TANF caseloads by modifying certain reporting and performance measures for the program’s existing work requirements.

In his April 19 remarks on the House floor, Speaker Kevin McCarthy (R-Calif.) argued, "Our plan ensures adults without dependents earn a paycheck and learn new skills. By restoring these commonsense measures, we can help more Americans earn a paycheck, learn new skills, reduce childhood poverty and rebuild the workforce."

Democrats, including House Agriculture Committee ranking member David Scott (D-Ga.), have argued against the work requirements. Scott stated in a press release, “Holding food assistance hostage for those who depend on it—including 15.3 million of our children, 5.8 million of our seniors and 1.2 million of our veterans—in exchange for increasing the debt limit is a nonstarter.” President Joe Biden (D) stated that he would veto the legislation if reached his desk.

President Joe Biden (D) signed the final version of the debt ceiling legislation—the Fiscal Responsibility Act of 2023—on June 3, 2023. The bill included modified SNAP and TANF work requirements but did not include Medicaid work requirements.

Noteworthy events at the state level

This section provides an overview of noteworthy events related to Medicaid work requirements at the state level.

State noteworthy events

Georgia Pathways program extended until December 2026 (2025): Georgia's section 1115 waiver, which allowed for the state's implementation of work requirements, was originally set to expire at the end of September 2025. The federal CMS granted the state's request to extend the waiver until December 2026.

South Dakota Health and Human Services to revoke section 1115 waiver amendment request for work requirements (2025): South Dakota Health and Human Services applied to CMS for a section 1115 demonstration waiver to implement work requirements for Medicaid. The proposal would have made it necessary for individuals to be employed, to be meeting other public assistance work requirements, to be pursuing education, or to be caring for a child, elderly person, or a disabled person in order to maintain eligibility, but did not set a specific number of hours that would have to met to maintain eligiblity. The state announced its intention to withdraw the application in late July after the passage of the 2025 budget reconciliation bill, which requires states to enact more stringent Medicaid work requirements by 2027.

Iowa SF615 is signed into law, which would enact work requirements for Medicaid upon federal approval (2025): On June 6, Governor Kim Reynolds (R) signed Iowa SF615. The law would require individuals who do not qualify for exemption to work 80 hours a month to maintain eligibility for Medicaid. As of June 6, Iowa had applied to the federal CMS for permission to implement work requirements.

Indiana SB2, which contains Medicaid work requirement provisions, is signed into law (2025): On May 1, Governor Mike Braun (R) signed SB2 into law. The bill lays out provisions related to the Healthy Indiana Plan, which would require able-bodied adults to attend school full-time or work, volunteer, or participate in a work program for 20 hours a week in order to maintain eligibility. The work requirement cannot be enacted without a section 1115 waiver from the federal CMS. As of May 2, 2025, Indiana had not yet applied for a waiver.

Kentucky legislature overrides governor's veto, enacting HB 695, which requires the state to apply to implement Medicaid work requirements (2025): On March 27th, the Kentucky Legislature voted to override Governor Andy Beshear's(D) veto of House Bill 695, which requires the state to seek work requirements for able-bodied adult Medicaid recipients.

Kentucky is a divided government, with a Republican-controlled legislature and a Democratic governor. The veto was overridden with a 29-7 vote in the Senate and an 80-20 vote in the House. The vote was along party lines in the Senate and almost along party lines in the House, with only one Democrat, Rep. Matthew Lehman (D), voting in favor.

Kentucky's program under HB 695, should CMS approve the waiver, will require able-bodied adults without dependents who have been enrolled in Medicaid for 12 or more months to complete minimum community engagement or work activities that qualify under federal code, including:

• working a job for 20 hours per week,
• participating in a work program for 20 hours per week,
• doing a combination of these for 20 hours per week, and
• participating in a workfare program for 20 hours per week.

Idaho H0345 becomes law, requiring the state to apply to implement Medicaid work requirements (2025): On March 19th, Governor Brad Little (R) of Idaho signed a bill into law that requires the state to submit a waiver request to CMS. Upon approval, the state will institute work requirements for able-bodied adult Medicaid recipients. The bill passed along party lines with a 29-6 vote in the Senate and 61-9 vote in the House. Idaho is a Republican trifecta, meaning that its executive branch and both houses of its legislature are Republican-controlled. Activities that will fulfill the work requirement, should CMS approve the program, include: working a job, participating in a work, doing a combination of these, participating in a workfare program, or volunteering for 20 hours a week.

South Dakota Constitutional Amendment F Ballot Measure (2024): South Dakota Constitutional Amendment F was on the ballot on November 5, 2024 and was approved by voters. The measure amended the South Dakota Constitution to provide that the state may impose a work requirement on eligible individuals in order to receive Medicaid benefits. The state requires a Section 1115 waiver to put any work requirements in place. On January 25, the South Dakota State Senate voted 28-4 to approve Senate Joint Resolution 501 (SJR 501) putting the amendment on the ballot. On February 27, the South Dakota House of Representatives voted 63-7 to pass SJR 501. In both chambers, Republicans were in favor of the amendment, and Democrats were opposed.

Both South Dakota and North Carolina expanded Medicaid in 2023. Neither state implemented work requirements at that time, with Georgia remaining the only state with Medicaid work requirements as of the fourth quarter of 2024.

Georgia implements Medicaid work requirements, Ohio seeks waiver (2023): Georgia and Ohio took action concerning Medicaid work requirements. Georgia became the only state to have Medicaid work requirements in place when the Georgia Pathways program took effect on July 1, 2023. Ohio Governor Mike DeWine (R) later signed a two-year state budget on July 4, 2023, that seeks to implement work requirements for Medicaid recipients.

Georgia lawmakers in 2019 created Georgia Pathways through the passage of Senate Bill 106. The program aims to expand Medicaid coverage to qualifying adults with households below the poverty level who work at least 80 hours per month. The Centers for Medicare and Medicaid Services (CMS) approved Georgia’s plan under the first Trump administration but later rescinded the plan under the Biden administration—resulting in a legal challenge that culminated in favor of Georgia.

The Ohio state budget requires the director of the Ohio Department of Medicaid to apply for a Section 1115 waiver from the Centers for Medicare and Medicaid Services (CMS) in February 2025. The waiver, if approved by CMS, would allow the state to establish Medicaid work requirements for able-bodied residents ages 55 and younger. Able-bodied adults without dependents under the policy would be required to work or study 20 hours per week to qualify for Medicaid benefits.

North Carolina's ACA Medicaid expansion includes a section requiring the pursuit of work requirements (2023): North Carolina's HB76, which expanded Medicaid under the Affordable Care Act included a section requiring the Department of Health and Human Services, Division of Health Benefits (DHB) to negotiate with Centers for Medicare and Medicaid Services (CMS) to develop a plan to implement work requirements if there is ever any indication that CMS would approve such a plan.

“

PURSUIT OF MEDICAID WORK REQUIREMENTS SECTION 2.4. If there is any indication that work requirements as a condition of participation in the Medicaid program may be authorized by the Centers for Medicare and Medicaid Services (CMS), then the Department of Health and Human Services, Division of Health Benefits (DHB), shall enter into negotiations with CMS to develop a plan for those work requirements and to obtain approval of that plan...

”

Work requirements implementation waivers (2025)

This section provides details on currently pending section 1115 waivers, which, if approved, will be used to implement the Medicaid work requirements established by the One Big Beautiful Bill Act (2025) ahead of schedule.

Section 1115 waivers

The Montana Department of Public Health and Human Services (DPHHS) submits section 1115 waiver to CMS (2025): On September 3, Montana's DPHHS submitted the state's section 1115 waiver application. The draft of the waiver was made publicly available on July 18. The section 1115 waiver requests permission to implement community engagement and cost-sharing requirements that are required under state and federal law. The community engagement requirement would condition Medicaid benefits on full or part-time work.

Iowa Health and Human Services submits section 1115 waiver amendment request for work requirements (2025): On June 6, Iowa submitted their section 1115 waiver request to implement work requirements to the federal Centers for Medicare and Medicaid Services (CMS). If approved, the Iowa Health and Wellness Plan would require able-bodied adults to work 100 hours per month or prove that they earn 100 times the state hourly minimum wage every month. Iowa Senate File 615, which would institute the work requirement upon CMS approval, was signed into law on June 6.

South Carolina Health and Human Services to submit section 1115 waiver amendment request for work requirements (2025): On April 30, South Carolina Health and Human Services gave public notice of intent to apply to CMS for a section 1115 demonstration waiver to implement work requirements for Medicaid. The community engagement requirement would make it necessary for individuals to be employed 80 hours per month, to be meeting unemployment insurance job search requirements, to be pursuing education, or to be in substance abuse treatment in order to maintain eligibility.

Utah to submit section 1115 waiver amendment request for work requirements (2025): The public comment period for Utah's proposed section 1115 waiver amendment request opened on April 22 and was scheduled to end on May 22, 2025. The amendment proposal would institute a community engagement requirement to maintain eligibility for Medicaid for individuals who aren't granted an exemption. Reasons an individual would be exempt from the requirement include being over the age of 60, being pregnant or 12 months or less postpartum, complying with SNAP work requirements, working 30 hours or more per week, and others.

Arizona applies to CMS for amendment to section 1115 waiver to implement work requirements for Medicaid (2025): On March 28, Arizona submitted a waiver amendment request to implement work requirements for expansion adults aged 19-55. These individuals would be required to work 20 hours a week to maintain eligibility. There would be a 6-month grace period for individuals to seek exemptions or demonstrate compliance.

Ohio applies to CMS for waiver to implement work requirements for Medicaid (2025): On March 7, the state submitted its waiver request to the Centers for Medicare and Medicaid Services. The proposal conditions Medicaid expansion on work requirements. If the waiver is approved, Medicaid recipients in the state will be required to meet at least one of the following criteria:

• be employed,
• be over age 55,
• be enrolled in school or a job training program,
• be participating in alcohol/drug addiction treatment program, or
• have intensive physical health care needs or serious mental illness.

Arkansas Governor applies to CMS for waiver to implement work requirements for Medicaid (2025): On January 28, 2025, Arkansas Governor Sarah Huckabee Sanders (R) submitted a request to the Centers for Medicare and Medicaid Services (CMS) for a section 1115 waiver in order to implement a program that requires able-bodied Medicaid recipients aged 19-64 to work in order to receive benefits. The proposed amendment does not set a minimum number of hours that individuals must work per month in order to receive benefits and instead focuses on personal development plans to increase individuals’ wages and hours worked.

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

External links

• Search Google News for this topic
• Centers for Medicare & Medicaid Services

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