As Congress considers imposing a mandatory work reporting requirement (WRR) on adults in Medicaid as part of their drive to impose large federal cuts to Medicaid, Ohio is the first state during the second Trump Administration to request Section 1115 demonstration authority to impose a WRR on its ACA Medicaid expansion group. Ohioans are speaking up to explain why this is a terrible idea – that does not promote work but rather will result in people losing their health insurance.
Other states are in the queue with Arizona and Arkansas having just gone up for federal public comment last week. Approving work reporting requirements was a hallmark of the first Trump Administration’s although only Arkansas ended up implementing this policy where 18,000 people lost Medicaid in short order and there was no impact on workforce participation. Courts fortunately stepped in to stop this harmful policy which does not support work, but has led to a great deal of taxpayer money being spent on corporate consultants.
Because so much important policy in Medicaid happens through Section 1115 demonstrations, Congress established strong statutory transparency requirements for public notice and comment. The federal comment period for Ohio’s Group VIII 1115 Demonstration waiver recently closed on April 7, 2025. We took a look at the public comments submitted on Ohio’s proposed work reporting requirements during the federal 30-day comment period, and it was absolutely heart-wrenching. Virtually all commenters (98% of 254 comments submitted) oppose the approval of this demonstration.
Individuals shared numerous stories of Medicaid’s importance for people with disabilities, people with cancer and other chronic illnesses, single parents, people in caregiving roles, those facing unexpected job losses, and many others. Commentors highlighted that work requirements would create unnecessary administrative burden for accessing Medicaid and lead to wrongful terminations of coverage. Commentors also pointed to the ineffectiveness of work requirements to improve employment rates – in fact the opposite can be true as Medicaid supports people’s ability to work. At the same time, many people who are covered by Medicaid emphasized that they already work, yet rely on Medicaid due to a lack of insurance through their employment. Those who do not currently work spoke to ongoing barriers to regular employment, such as illnesses, disabilities, or caregiving responsibilities. Physicians and other providers echoed how Medicaid serves as a lifeline for many patients, attesting to the quality of life improvements evident from patients enrolled in Medicaid and the importance of Medicaid to keep their doors open. Eligibility workers attested to the inability of the system to implement such a requirement in a way that will ensure that many mistakes are not made leading the loss of coverage for people who desperately need it.
Below is a selection of quotes from the submitted comments to highlight the range of stories shared and the strong and widespread opposition to Ohio’s proposed work requirements. The full list of comments is available here.
People covered by Medicaid:
[Medicaid] has been a lifeline for me, and let me tell you how work requirements would have made it impossible for me to obtain coverage. My cancer diagnosis and treatment caused me to have multiple surgeries – 6 in 2.5 years, in fact, along with 5 weeks of radiation treatment … I would not have been able to get the medical treatment I needed to restore my health so that I can get back to work.
My children were enrolled in Medicaid for many years while I was working full-time and going to college. My son had a disability, and we were able to access many services for him through Medicaid. My daughter had a lot of health issues, and we relied on Medicaid to get her the proper testing and diagnosis to properly treat her conditions. I was able to obtain my Master’s degree and give back to my community since I had adequate resources like Medicaid to help ensure that my children were healthy during a time when I could not afford health insurance for my family.
Most people who are on Medicaid DO work. I have a disability, and thus have a part time job to do as much as I can, but I don’t qualify for disability benefits since they determined that I was able to work. Work requirements with a certain amount of hours required would strip my healthcare from me, and thus make it so I wouldn’t be able to work at all since I’d be without my medications.
Healthcare Providers:
It is well documented that the maternal and fetal outcomes in Ohio are already abysmal. Making access to support for single mothers more difficult will undoubtedly translate to poor health outcomes and it is unlikely to promote financial independence, furthering generational poverty and racial disparities.
This proposal may be veiled as an effort to encourage work, but the consequences are clear and dangerous. It’s about cutting off access to primary care, dental, vision, and the basic human necessities required to sustain a healthy life, a strong workforce, and thriving communities. When people lose access to Medicaid, they don’t stop needing care—they just lose the ability to afford it.
I do not depend on Medicaid for my medical care, but I do depend on it for my income. Making Medicaid more difficult to use (and it is already so difficult!) makes it more likely that I and other medical professionals, who would prefer to stay and serve our communities, have to leave for someplace we can actually pay rent.
Eligibility workers:
As a former JFS [Job and Family Services] Medicaid eligibility specialist I can absolutely say this is a terrible idea. The county JFS offices are already overburdened with their current workloads.
I am a county eligibility specialist in Ohio, primarily working with Medicaid…. I have personally seen how work requirements add administrative complexity to processing Medicaid applications, completing renewals, and keeping benefits open….Imposing work requirements will result in many Medicaid recipients being wrongly removed from the rolls, even those who are currently working.
As one commenter put it:
Many people need to get through a challenge or a crisis before they will be able to work. Medicaid coverage will help them recover from these challenges or crises, allowing them to join, or rejoin, the work force. Cutting their Medicaid because they are not ready to work, will delay, or destroy, their capacity to work.