Skip to main content

New Medicaid work rules could lead to greater-than-expected coverage losses, administrative hurdles

Closeup hands writing application papers on desk. Patient signing insurance form filling personal information at reception. Unknown African American visiting doctor in clinic. Medical system concept.
stockbusters / iStock

Strict new Medicaid work rules issued by the Trump administration could make it harder for people to qualify and push a greater-than-expected number of current enrollees off the rolls, according to experts. The new rules also pose administrative challenges for beneficiaries, health providers, and states, they say.

Harvard T.H. Chan School of Public Health’s Adrianna McIntyre and Benjamin Sommers spoke to the media about the directives, which were issued by the Centers for Medicare and Medicaid Services (CMS) in a 400-page document on June 1.

Under the H.R. 1 statute (also known as the One Big Beautiful Bill) passed last year, recipients of Medicaid—the public health plan for low-income individuals— will either be required to work or prove that they’re unable to. These changes were already projected to result in millions losing coverage. Until now it had been expected that medically frail people would be exempt from work requirements. But under the new rules, it will be harder for them to get an exemption—which could lead to greater coverage losses among people who are sick and disabled, according to McIntyre, Sommers, and other experts.

Noted McIntyre, assistant professor of health policy and politics, in a June 2 NPR article, “What the rule says is that the disease needs to be actively interfering with your ability to work. So people with early-stage cancer who are in radiation treatment but still have the capacity to work or people who have HIV but can still technically work are not exempted.”

“This is where we’ll see large and harmful coverage losses,” said Sommers, Huntley Quelch Professor of Health Care Economics, in a June 3 STAT article. “This is a population that has high medical needs and is at major risk for harm if they lose coverage. That is the headline implication of the new rule.”

McIntyre and Sommers also highlighted the administrative hurdles posed by the new rules.

McIntyre pointed out that the deadline for implementing the rules is Jan. 1, but “it takes states literally months, usually years, to make the types of changes to their systems that they needed to make for this new rule.”

Sommers noted that the new rules will burden already overworked health providers with additional paperwork aimed at proving that certain patients have conditions that make them unable to work and who therefore should be exempt from work requirements. “It is not a realistic and successful strategy to expect that doctors and nurses are going to fill out the paperwork to keep people on Medicaid,” Sommers said. “It’s not going to work.”

Sommers added that the new rules regarding what defines medical frailty differ from what’s outlined in H.R. 1, setting CMS up for a potential legal challenge.

Read or listen to the NPR article: Trump administration puts out strict Medicaid work rules

Read the STAT article: Trump’s Medicaid work requirements have an unwelcome surprise for some states and patients

Learn more

Medicaid work requirements begin in Nebraska amid fears that many will lose coverage (Harvard Chan School news)

Previous Medicaid coverage losses related to ‘unwinding’ shed light on what to expect from future cuts (Harvard Chan School news)

About The Author

Related Topics


Last Updated

Featured in this article

Get the latest public health news

Stay connected with Harvard Chan School