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Which states received approval for Medicaid work requirements under Trump?

Checked on November 19, 2025
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Executive summary

The Trump administration approved Section 1115 Medicaid waivers that conditioned coverage on work or reporting requirements for 13 states during his first term; of those, only Arkansas fully implemented a program before courts or later administrations halted most approvals, and Georgia later implemented a program that states have been able to scale back or revise [1] [2] [3]. Reporting and analyses emphasize that these experiments were costly to build, legally contested, and produced coverage losses in Arkansas and operational problems in Georgia [2] [4] [3].

1. What the Trump administration actually approved — thirteen state waivers

During President Trump’s first term, the Centers for Medicare & Medicaid Services (CMS) approved Section 1115 demonstration waivers that would impose work or reporting requirements for Medicaid beneficiaries in 13 states; CMS’s waiver authority allows experimental state projects that the HHS secretary judges likely to “assist in promoting” program objectives [1]. Multiple retrospective summaries and policy pieces repeat the figure “13 states” as the number of approvals granted under the Trump administration’s waiver program [5] [6] [7].

2. Implementation versus approval — only a few programs went live

Approval is not the same as an implemented program. Journalistic and policy accounts note that although waivers were approved for 13 states, only Arkansas fully implemented a program prior to legal challenges and administrative reversals; Georgia later implemented a program as well, and those two states are commonly cited as the only ones to have operational experience with work requirements [2] [3]. Courts and subsequent administrations rescinded or blocked many approvals, meaning most states never put requirements into practice [1] [3].

3. Outcomes we can document from those implementations

KFF and other analysts found that implementing work requirements was administratively expensive and led to coverage losses where programs ran: Arkansas’s program resulted in more than 18,000 people losing coverage in one account, and research suggested many enrollees were either unaware of requirements or found reporting too onerous [4] [3]. The Congressional Budget Office and KFF cite high administrative burdens and limited evidence that mandates increased employment among enrollees in prior pilots [4].

4. Why states sought waivers and why opponents objected

Proponents framed waivers as promoting work, personal responsibility, and lower federal outlays; critics — including health policy groups and civil‑rights advocates — argued that waivers could strip low‑income people of coverage, increase complexity, and conflict with Medicaid’s core objective of providing medical coverage to the needy [8] [4] [3]. Families USA and other advocacy organizations warned that conditioning Medicaid on work would threaten coverage for many enrollees [8].

5. Legal and operational barriers that limited spread

Courts blocked or vacated some approvals on administrative-law grounds; judges questioned whether waivers were consistent with Medicaid’s statutory purpose, and practical difficulties — building reporting systems, integrating data, and handling appeals — made implementation costly. KFF and news outlets documented states spending tens of millions to design systems that proved fragile or confusing for beneficiaries [4] [2] [9].

6. How later federal policy changed the landscape

When the Biden administration took office it withdrew or rescinded many of the prior work‑requirement approvals, halting implementation in most states [1]. Later federal legislation and policy developments in 2025 changed the rules again: the 2025 budget reconciliation law (described in reporting) requires states to adopt community‑engagement requirements by 2027, effectively re‑opening a national pathway for work requirements under new standards — and prompting renewed state interest [1] [4] [9].

7. Takeaway for readers seeking a list of states

Available sources consistently say 13 states received approvals for Medicaid work‑requirement waivers under the Trump administration, but they do not provide a single, fully enumerated list of those 13 in the materials you provided; reporting repeatedly names Arkansas and Georgia as the two states that actually implemented programs and flags that most other approvals were never operational because of legal and administrative reversals [1] [2] [3]. If you want the exact names of all 13 states, current reporting in your set does not list them all explicitly — that specific roster is not found in the provided excerpts (not found in current reporting).

Limitations: This summary relies strictly on the supplied search results; more detailed state‑by‑state lists and the legal timelines exist in public records and full CMS and KFF reports but were not included among the excerpts provided here (not found in current reporting).

Want to dive deeper?
Which states had Medicaid work requirement waivers approved during the Trump administration and when?
What legal challenges affected Medicaid work requirements after federal approvals under Trump?
How did approved Medicaid work requirements change eligibility and coverage in each state?
Which federal policies under the Biden administration altered or reversed Trump's Medicaid work requirement approvals?
What evidence exists on the impact of Medicaid work requirements on enrollment, health outcomes, and employment?