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What changes to Medicaid did the Trump administration propose or approve, including work requirements, between 2017 and 2020?
Executive Summary
The Trump administration between 2017 and 2020 pursued a multifaceted push to reshape Medicaid by approving state waiver requests that allowed work requirements, premiums, and other eligibility restrictions, while also promoting broader financing flexibilities and emergency waivers during COVID-19. Those actions produced a patchwork of state-level policies, produced measurable enrollment losses in early implementations, provoked litigation that blocked some approvals, and set the stage for the Biden administration to rescind several approvals after 2020 [1] [2] [3].
1. What advocates and critics both said — the headline claims that drove action and controversy
Advocates for the Trump administration’s approach framed the changes as restoring “personal responsibility” and state flexibility, enabling states to tailor Medicaid to local labor markets and budget constraints. Critics said the policies would reduce coverage for low-income adults, people with disabilities, and older adults by imposing work rules, premiums, and lockouts that interrupt continuous coverage and create administrative barriers. Families USA and other advocates warned that approvals shifted Medicaid away from decades-long federal norms and risked millions losing coverage; KFF and Stateline also summarized both the approvals and the concerns about coverage losses and state fiscal pressure [4] [1] [5]. Those competing frames shaped litigation and later federal policy reversals.
2. The concrete actions the administration approved — waivers, work requirements, and financing changes
Between 2017 and 2020 the Centers for Medicare & Medicaid Services approved multiple Section 1115 demonstration waivers and related authorities that permitted work and community engagement requirements for some adult Medicaid enrollees, allowed states to add premiums and lock-outs for noncompliance, and offered other financing and eligibility flexibilities including changes to matching funds and state program designs. At least 13 states received approval to pursue work rules and other restrictions, while additional states sought permissions; Arkansas became the first state to implement such a requirement in June 2018 [1] [2] [3]. CMS also issued emergency and programmatic waivers during the COVID-19 public health emergency that adjusted operations and funding temporarily [6].
3. The real-world results — enrollment effects, administrative churn, and early data
Early implementations produced measurable coverage losses and administrative churn. Arkansas’s program led to tens of thousands losing coverage before a federal judge halted the policy, and evaluations and reports flagged increased uninsured rates and coverage interruptions where restrictions took effect. Researchers and policy analysts concluded that work requirements and new administrative conditions imposed verification burdens that disproportionately affected vulnerable enrollees, including people with intermittent work histories and those with disabilities, while offering limited evidence of increased sustained employment tied to the rules [1] [5] [3]. The cumulative picture showed real enrollment impacts rather than only symbolic policy shifts.
4. The legal and regulatory pushback that unraveled some approvals
Multiple federal courts found that several approved work-requirement waivers conflicted with Medicaid’s statutory objective of providing medical assistance, leading judges to block implementations and ultimately prompting policy reversals. The Biden administration later rescinded many of the prior approvals, arguing that they reduced coverage and did not advance Medicaid’s objectives; KFF documented this reversal of waiver priorities and CMS withdrew certain approvals after litigation and administrative review [2] [5]. The litigation record underscores that administrative approvals do not guarantee lasting policy, particularly when courts interpret statutory standards differently than the approving agency.
5. Broader financing and program changes beyond work rules that attracted attention
Beyond work requirements, the Trump administration pursued changes affecting Medicaid financing and state flexibility, such as waiving federal matching funds rules for certain state programs, proposing tighter conditions on how states could finance services, and endorsing demonstration models including block-grant-like arrangements. Critics argued these changes could weaken long-term federal support, complicate funding for rural health and home- and community-based services, and make enrollment and maintenance harder through premium requirements and eligibility tests. CMS actions to narrow some funding pathways and encourage state-level financing innovations drew scrutiny from health policy analysts and state officials concerned about coverage impacts [7] [3].
6. Two competing policy lenses and what to watch next
One lens treats the 2017–2020 actions as legitimate federalism and fiscal reform measures that restore state discretion and promote work; the other treats them as policy changes that intentionally or inadvertently restrict access to care and shift costs. KFF and other neutral analysts documented both what was approved and the Biden administration’s subsequent rescissions, while advocacy groups emphasized coverage harms [5] [4]. Future developments depend on litigation, federal administration priorities, and state decisions to reapply for waivers; the same waiver authority that produced controversial approvals under the Trump administration remains the mechanism by which states may again attempt similar changes. [1] [2]