Some Congressional Republicans are currently considering statutory changes to Medicaid to allow states to impose work requirements. As many others have noted, work requirements do not actually help people find and keep jobs – they just take away health care.
Despite the serious problems with work requirements, these proposals continue to proliferate. Since 2017, no less than eight federal Medicaid work requirements bills have been introduced. Although many of these bills are just variations on a theme, they can be sorted into two groups: proposals that would impose mandatory work requirements on Medicaid beneficiaries, and those proposals that are “optional” for states. But make no mistake—optional work requirements are not a benign alternative. If Congress creates a state plan option to impose work requirements, many states will quickly pick up these cuts, causing millions to lose health care.
While “optional” work requirements may seem less severe, conservative groups have spent years pushing to cut Medicaid funding, leading many states to pass or introduce laws to impose work requirements. These laws say that states must either impose work requirements through a State Plan Amendment if permitted or apply for a Section 1115 demonstration waiver to impose work requirements.[1]
The Foundation for Government Accountability has been pushing model state-level work requirement legislation since 2018. The American Legislative Exchange Council has promoted similar legislation that would require a state to ask for a state plan amendment or waiver to impose work requirements on a certain date each year.
Some states have also passed or introduced trigger laws to impose work requirements if allowed to do so, either by Congress or by CMS (through Section 1115). These laws say that if Congress green lights the option, states must impose work requirements immediately
For example, in 2023, North Carolina passed a trigger law, automatically imposing work requirements if the federal government allows them. If Congress permits work requirements, North Carolina (and their current residents) will not have a choice—the state has locked itself in to imposing work requirements. This is because North Carolina has a law on the books that would immediately trigger work requirements.
Roughly Half the States Likely Impose Work Requirements
In addition to states that have laws on the books or may adopt them this session, other states have loudly signaled interest in imposing work requirements. In total, we estimate that roughly half of states would be at serious risk of imposing a work requirement. These states include two with trigger laws and eleven states that have active or recent (within the past two years) legislative proposals involving work requirements.[2] Though past is not necessarily prologue, and state elections can change priorities, our estimate of states likely to pursue work requirements also includes 23 states that have applied for waivers to impose work requirements in the past and two additional states that have given some other strong indication of interest in pursuing work requirements.[3]
[1] In several cases, courts have invalidated the approval of Section 1115 projects that have included work requirements.
[2] This category includes states that have legislation authorizing the state to seek a waiver or SPA, legislation expanding Medicaid on condition of seeking a work requirement, and legislation repealing Medicaid Expansion unless a work requirement is imposed by a certain date.
[3] States may have more than one indicator.
| Trigger Law Enacted | Recent Legislative Proposals | Exec. Commit | 1115 Applications | |
| 1. Alabama | 1 | |||
| 2. Arizona | 1 | |||
| 3. Arkansas | 1 | 1 (extension request pending) | ||
| 4. Georgia | 1 (state comment for renewal in progress) | |||
| 5. Idaho | 1 | 1 (pending) | ||
| 6. Indiana | 1 | 1 | ||
| 7. Iowa | 1 | 1 | ||
| 8. Kansas | 1 | 1* | ||
| 9. Kentucky | 1 | |||
| 10. Maine | 1 | 1 | ||
| 11. Michigan | 1 [4] | |||
| 12. Mississippi | 1 | 1 (pending) | ||
| 13. Missouri | 1 (enacted) | |||
| 14. Montana | 1* | |||
| 15. Nebraska | 1 | |||
| 16. New Hampshire | 1 | 1 | ||
| 17. North Carolina | 1 | 1 | ||
| 18. Ohio | 1 (enacted) | 1 (state comment in progress) | ||
| 19. Oklahoma | 1 (pending) | |||
| 20. South Carolina | 1 | 1 | ||
| 21. South Dakota | 1 (enacted) | 1 (pending) | ||
| 22. Tennessee | 1 (pending) | |||
| 23. Utah | 1 | |||
| 24. Virginia | 1 | |||
| 25. West Virginia | 1 | |||
| 26. Wisconsin | 1 | |||
| Totals | 2 | 11 | 2 | 23 |
* State has an application for work requirements moving through the notice and comment process. In addition, GA has approval to impose work requirements through September 30, 2025.
As the table above illustrates, even “optional” Medicaid work requirements stand to strip away health care from millions of people. With the majority of states at risk of imposing these restrictions if allowed, the potential harm to beneficiaries is significant and far-reaching. Congress should think carefully before making changes to Medicaid that will take away health care from millions of people.
Appendix A
Recent Legislative Proposals
H.B. 419, 66th Leg., 2d Reg. Sess. (Idaho 2022).
H.B. 1023, 124th Gen. Assemb., 2d Reg. Sess. (Ind. 2025)
S.F. 363, 91st Gen. Assemb., Reg. Sess. (Iowa 2025)
H.B. 2556, 2024 Leg., Reg. Sess. (Kan. 2024)
L.D. 1194,131st Leg., 1st Reg. Sess. (Me. 2023)
H.B. 1725, 2024 Leg., Reg. Sess. (Miss. 2024).
S.J. Res. 43, 102d Gen. Assemb., Reg. Sess. (Mo. 2025) (A constitutional amendment will appear on the ballot in November 2026).
S.B. 134-FN, 2025 Leg., Reg. Sess. (N.H. 2025).
Ohio Rev. Code § 5166.37 (2023).
S.J. Res. 501, 99th Leg., Reg. Sess. (S.D. 2024).
H.B. 3485, 86th Leg., Reg. Sess. (W. Va. 2023).
Executive Commitments
Stephen Gruber-Miller, Iowa Gov. Kim Reyolds Proposes Classroom Cellphone Ban, Medicaid Changes, Des Moines Reg. (Jan. 14, 2025), available at https://www.desmoinesregister.com/story/news/politics/2025/01/14/iowa-gov-kim-reynolds-proposes-classroom-cellphone-ban-doge-medicaid-condition-of-the-state/77512429007/; McMaster Requests Medicaid Work Requirements, WPDE (Dec. 18, 2024), https://wpde.com/news/local/mcmaster-requests-medicaid-work-requirements-healthy-connections-community-engagement-scdhhs; South Carolina Looks to Impose Medicaid Work Requirement Under Trump Administration, WIS News 10 (Dec. 18, 2024), https://www.wistv.com/2024/12/18/sc-looks-impose-medicaid-work-requirement-under-trump-administration/.