Medicaid Work Requirements Would Result in Coverage Loss, More Paperwork & No Employment Boost

Public health scholars file comments in response to the proposed Medicaid work requirements put forward by Arizona and Arkansas

May 12, 2025

WASHINGTON (May 13, 2025)--A group of public health scholars have filed public comments urging the US Department of Health and Human Services to turn down Medicaid work requirement waivers submitted by Arizona and Arkansas. These two state’s are following Ohio’s lead in trying to impose work requirements on Medicaid beneficiaries.

The comments were filed with HHS May 7, 2025 on behalf of the American Public Health Association, and 65 public health deans and scholars including experts from the George Washington University.

In their comments, the scholars analyzed the evidence on such policies finding that work requirements do not lead to measurable employment gains and can disproportionately harm vulnerable populations, such as people with disabilities.

The scholars note that the evidence suggests that imposing work requirements on Medicaid beneficiaries would result in substantial health coverage loss, a loss that can lead to delays in crucial health care.

The link to the public health comments filed with HHS for the Arkansas waiver can found here and and for Arizona can be found here,

GW experts are available to discuss the public health consequences of work requirements. To schedule an interview with one of the GW health policy and law experts, please contact Kathy Fackelmann, kfackelmannatgwu [dot] edu (kfackelmann[at]gwu[dot]edu) or Katelyn Deckelbaum, katelyn [dot] deckelbaumatgwu [dot] edu.

MaryBeth Musumeci, a teaching associate professor of health policy and management at GW Milken Institute School of Public Health, is an expert on Medicaid, including for those with disabilities. She is a lawyer trained in health policy and can discuss how  Medicaid work requirements will affect coverage access and other issues.

Alison Barkoff, is the Harold and Jane Hirsh Associate Professor of Health Law and Policy at the GW Milken Institute School of Public Health. She is an expert in health law and policy and can discuss access to healthcare, insurance and other issues.

Sara Rosenbaum, a professor emerita of health law and policy at GW Milken Institute School of Public Health, is a nationally recognized expert on Medicaid, health care access as well as health care for vulnerable populations.

Leighton Ku, a professor of health policy and management and Director of the Center for Health Policy Research at the George Washington University, Is an expert on the Affordable Care Act, access to healthcare and Medicaid. In a report with the Commonwealth Fund, Ku recently did research showing that national Medicaid work requirements could threaten up to half a million jobs and harm state economies.