The Centers for Medicare and Medicaid Services (CMS) recently released the Interim Final Rule on Medicaid work requirements (or “community engagement”). The CMS regulatory impact analysis claims that the new policy will bolster the economy, incentivizing employment and resulting in 5 million Medicaid beneficiaries gaining work.
In a new “Notes from Washington” commentary, Dr. Leighton Ku, Professor of Health Policy and Management and Director of the Center for Health Policy Research, addresses the significant limitations of the Administration’s analysis. For example, he notes that how unrealistic it is to claim that 5 million Medicaid beneficiaries will find work due to the rule, given that the United States only created a total of 181,000 jobs in 2025.
He summarizes well-documented evidence on the economic, employment and health care costs of work requirements. CMS greatly overstates the benefits and undercounts or ignores the costs of Medicaid work requirements. In addition to the effects on health insurance coverage and access to care, Ku probes the significant impact on state economies, the labor market, community health centers and other safety net providers. The potential employment gains and spending cuts are overshadowed by the mounting costs of health care job losses, hits to state incomes, burdensome requirements for provider documentation, and declining population health. Contrary to CMS’ assertions in the regulation, evidence indicates the rule will have substantial harmful consequences, threatening but reaching well beyond community health and health care.
Read, Commentary: The Administration’s Flawed and Misleading Claims About Medicaid Work Requirements