Public Comment Letters on Section 1115 Medicaid Demonstration Waivers
Public Comment Letters on Section 1115 Medicaid Demonstration Waivers
Public comment letter in response to Iowa's request to amend the Iowa Health and Wellness Plan Section 1115 demonstration project — July 3, 2025*
The American Public Health Association and 66 public health deans and scholars recommended that CMS reject Iowa’s request to require individuals to meet a work reporting requirement as a condition of Medicaid eligibility. The public comment letter amassed social science research demonstrating that work requirements in any form substantially depress enrollment among eligible people, which directly contravenes Medicaid’s primary purpose of providing coverage to low-income people. Research shows that work requirements do not result in measurable increases in employment, and instead result in a “chilling” effect on Medicaid enrollment due to administrative burdens and red tape.
Public comment letter in response to Arkansas's request to amend the Arkansas Health and Opportunity for ME Section 1115 demonstration project — May 7, 2025*
The American Public Health Association and 65 public health deans and scholars recommended that CMS reject Arkansas' request to require Medicaid expansion adults to meet a work or community engagement requirement as a condition of eligibility. Work requirements in any form result in substantial numbers of eligible people losing health coverage, which directly contravenes the purpose of Medicaid. Research shows that work requirements do not result in measurable increases in employment and instead result in coverage loss, increases in the number of uninsured, and a “chilling” effect on Medicaid enrollment due to administrative burdens and red tape. While Arkansas claims that its new proposal differs from its previous work requirement, the proposal contains the same fundamental flaws, including data matching that risks eligible people losing coverage and inadequate protections for people with disabilities.
Related resources:
GW Media Relations. Medicaid work requirements would result in coverage loss, more paperwork and no employment boost. May 12, 2025. https://mediarelations.gwu.edu/medicaid-work-requirements-would-result-coverage-loss-more-paperwork-no-employment-boost
Public comment letter in response to Arizona's request to amend the Arizona Health Care Cost Containment System Works Section 1115 demonstration project — May 7, 2025*
The American Public Health Association and 65 public health deans and scholars recommended that CMS reject Arizona’s request to require individuals to work in order to qualify for and maintain eligibility in the Medicaid expansion group, to impose a five year lifetime limit on Medicaid benefits, to lock certain expansion adults out of coverage for 12 months, and to impose cost-sharing on non-emergency use of emergency department and ambulance services. Work requirements result in substantial coverage loss, do not increase employment, and do not improve health outcomes. Imposing lifetime limits and locking people out of coverage is contrary to the purpose of Medicaid, and imposing copays on non-emergency use of the emergency department and ambulance transport is harmful to low-income populations.
Related resources:
GW Media Relations. Medicaid work requirements would result in coverage loss, more paperwork and no employment boost. May 12, 2025. https://mediarelations.gwu.edu/medicaid-work-requirements-would-result-coverage-loss-more-paperwork-no-employment-boost
Public comment letter in response to Georgia's request to amend the Georgia Pathways to Coverage Section 1115 demonstration project — May 29, 2025*
The American Public Health Association and 65 public health deans and scholars recommended that CMS reject Georgia’s request to extend the Georgia Pathways to Coverage program, which requires individuals to meet a work or community engagement requirement to qualify for and maintain Medicaid coverage. Work requirements result in substantial coverage loss contrary to the goals of Medicaid, do not increase employment, and do not improve health outcomes. Work requirements will result in substantial state administrative burdens and procedural disenrollments. Georgia’s proposal creates barriers to obtaining coverage for people with disabilities, and the pre-enrollment requirement prevents eligible people from accessing coverage.
Related resources:
GW Media Relations. Georgia wants to continue Medicaid work requirements. June 4, 2025. https://mediarelations.gwu.edu/georgia-wants-continue-medicaid-work-requirements
Public comment letter in response to Ohio's proposed Group VIII Work Requirement and Community Engagement Section 1115 demonstration project — April 7, 2025*
The American Public Health Association and 65 public health deans and scholars recommended that CMS reject Ohio’s request to require individuals to work in order to qualify for and maintain eligibility in the Medicaid expansion group. Work requirements result in substantial numbers of eligible people losing health coverage, which directly contravenes the purpose of Medicaid. Research shows that work requirements do not result in measurable increases in employment, and instead result in coverage loss among low-income working people, increases in the number of uninsured, and a “chilling” effect on Medicaid enrollment due to administrative burdens and red tape.
Related resources:
GW Media Relations. Tens of thousands would lose coverage if Ohio’s Medicaid work requirement is approved. April 7, 2025. https://mediarelations.gwu.edu/tens-thousands-would-lose-coverage-if-ohios-medicaid-work-requirement-approved
Funding Acknowledgement
*Indicates public comments supported by the Commonwealth Fund, a national, private foundation based in New York City that supports independent research on health care issues and makes grants to improve health care practice and policy. The views presented here are those of the authors and not necessarily those of the Commonwealth Fund, its directors, officers, or staff.