States unprepared to implement Medicaid work requirements: report

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Dive Brief:

  • More than half of states may be ill prepared to enact Medicaid work requirements as required by the One Big Beautiful Bill Act, according to a new analysis published by the Georgetown McCourt School of Public Policy.
  • Researchers analyzed eight Medicaid performance indicators to assess how states are currently serving beneficiaries. They found lengthy call center waits and long processing timelines for applications, as well as low rates of automatic renewals — all signs that states may be administratively stretched thin even prior to taking on the onerous task of checking enrollees’ work status every six months.
  • Twenty-nine states exhibited red flags for at least half of the eight metrics examined by researchers. Illinois, Missouri, Montana, North Dakota, New Mexico, Utah and Wisconsin were deemed most at risk of poorly implementing work requirements, according to the analysis. 

Dive Insight:

President Donald Trump’s massive budget reconciliation bill, signed into law in July, cuts more than $1 trillion from Medicaid and Affordable Care Act health coverage over the next decade.

The cuts include Medicaid work requirements for expansion states, which are set to go into effect for most next year. Republicans say the work requirements will limit abuse of the safety-net program. Millions are expected to lose Medicaid coverage as a result.

Implementing the work requirements within just a few months will also be a significant lift for state health systems, according to the Georgetown analysis.

“Designing, testing and implementing new technology to automatically check for compliance with work requirements or exemptions should be a multi-year project, but states have less than 16 months to prepare,” the report said.

The analysis warns that confusion about the requirements, a rushed implementation timeline and taxing workloads for staff could “overwhelm” states, leading to backlogs and enrollees losing coverage erroneously.

There’s evidence that state Medicaid systems are stretched to their limits as is. The report analyzed eight indicators of Medicaid performance to discern whether states have the bandwidth to tackle the additional burden of checking enrollees’ work status.

The results were largely discouraging.

Several states reported elevated call center wait times and high call abandonment rates for Medicaid enrollees during the first quarter of 2025 — both indicators that state health systems may not be adequately addressing enrollees’ needs and questions, according to the report. 

Meanwhile, a significant share of Medicaid renewals also remained pending at the close of each month during the first quarter, suggesting the possibility of application backlogs. The problem was most acute in Nebraska, which had a 71.4% pending renewal rate.

States also disenrolled many enrollees during the quarter because they lacked necessary information to verify eligibility, a red flag as states look to impose even higher administrative barriers on coverage. Procedural disenrollments accounted for a median of 72.3% of all disenrollments nationwide.

Collectively, the indicators suggest that states may be struggling to keep up with the administrative burden of confirming enrollees’ eligibility in a timely manner. That struggle is likely to worsen with heftier requirements next year.

“Without swift improvements in administrative readiness, [the new requirements] will deepen state challenges, increase costs, and leave millions of children and families at risk of losing health coverage,” the report warned.

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