WASHINGTON (April 8, 2025)--A group of public health scholars have filed public comments urging the US Department of Health and Human Services (HHS) to turn down Ohio’s request for a Medicaid work requirement waiver. The waiver would require people in the state’s Medicaid expansion group to prove they are working, engaged in another approved activity, or exempt –or risk losing health coverage.

The comments were filed with HHS April 7 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 result in measurable increases in employment. Furthermore, most Medicaid recipients already are working and those that are not often have a chronic illness or caregiving responsibilities that make it difficult or impossible for them to work.

The scholars also note that the evidence suggests that imposing work requirements on Medicaid beneficiaries would result in substantial coverage loss among low income people, a loss that can lead to a lapse or delay in crucial health care.

The comments also cite research showing that work requirements would lead to a chilling effect–and tens of thousands of people in Ohio would lose coverage if the state goes ahead with the plan, according to the state’s own estimate. Many people who currently rely on Medicaid in the past would lose coverage due to burdensome red tape and paperwork requirements, the comments say.

Arkansas, Georgia and Arizona also are expected to submit Medicaid work requirement waiver proposals to HHS, and other states may follow Ohio’s lead if the waiver is approved.

GW experts are available to comment on the public health consequences of work requirements for Medicaid recipients. To schedule an interview with one of the GW health policy and law experts, please contact Kathy Fackelmann, [email protected] or Katelyn Deckelbaum, [email protected].

a teaching associate professor of health policy and management at GW Milken Institute School of Public Health, is an expert on Medicaid, including 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.

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.

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.

The  on Ohio’s request for a Medicaid waiver were filed April 7 by the APHA and 65 public health scholars and deans.