Utah News Dispatch
Advocates sound alarm as Utah looks to impose work requirements on Medicaid expansion
Marcella Patino gives a customer a pedicure while working at a salon in Holladay, Utah on April 30, 2025. (Courtesy of Marcella Patino)
Marcella Patino, 34, knows the difficulties of navigating work requirements.
Patino, who works full time as a nail technician and esthetician at a salon in Holladay, is a single mother of three. She relies on financial assistance for child care — $600 a month for day care — so she can keep working full time, and Supplemental Nutrition Assistance Program (SNAP) benefits — around $400 a month — to keep food on the table for her family.
To receive that financial assistance, she and her employer must already prove to state officials that she’s working. Lately, Patino said it’s been easier to produce the required documentation and jump through the administrative hoops. But she said that’s only because her employer keeps track of her hours and willingly validates them with the government.
That hasn’t always been the case, she said.
“It was a huge issue,” she said, adding that “in the past, it was really hard” because her previous employers did not log her hours on her paychecks. She said she’d been cut off from those benefits multiple times because her previous bosses wouldn’t fill out the required paperwork or would drag their feet to prove she indeed worked the required hours.
Luckily, she said now her current employer cooperates. So balancing her job, taking care of kids and making ends meet has been easier than it has been in the past, but Patino said the work requirements still add “constant” stress and uncertainty to daily life.
“I still worry about my hours,” she said.
Child care assistance and SNAP benefits already have work requirements. But there’s another crucial program for low-income Utahns that state officials are looking to re-impose that requirement on — after more than five years of it being suspended amid the COVID-19 pandemic.
And it could put thousands of Utahns at risk of losing their medical coverage.
Utah is the next state in a national movement looking to impose work requirements on certain Medicaid recipients under a Republican-controlled Congress and President Donald Trump.
Leaders of the Utah Department of Health and Human Services (DHHS) intend to submit for a new federal waiver to re-implement work requirements on the state’s Medicaid expansion program, with a list of allowable exemptions. That list excludes those working at least 30 hours a week, those who are 60 or older, pregnant, physically or mentally unable to meet the requirements, parents with a child dependent under the age of 6, among others.
Currently, about 75,000 adult Utahns are enrolled in the state’s expansion program, which allows Medicaid eligibility to Utahns whose annual income is up to 133% of the federal poverty level (roughly $20,800 for an individual or $42,760 for a family of four, according to national thresholds). The federal government covers $90% of the cost of the medical coverage, while the state pays for the remaining 10%.
Of those 75,000 adults enrolled, an estimated 7,900 (or 10%) would not fall under an exemption and be subject to work requirements if the state submits the waiver and it’s approved by federal officials under President Donald Trump’s administration, according to state Medicaid officials.
More than 5M could lose Medicaid coverage if feds impose work requirements
That means 7,900 Utahns — if they don’t start working or submit documentation showing they’re applying for at least 48 jobs during a three-month period, along with completing required online job training with the state — could lose their Medicaid coverage.
That’s according to Jennifer Strohecker, the state’s Medicaid director, who this week confirmed to Utah News Dispatch that leaders of DHHS intend to re-submit the work requirement waiver to the federal Centers for Medicare and Medicaid Services (CMS) “sometime in June.”
But first, state officials must hold a 30-day public comment period to field input on the proposed waiver. Friday, the DHHS will be holding the first of two public hearings. It’s scheduled to take place at 12:30 p.m., at the Multi-Agency State Office Building, at 195 N. 1950 West in Salt Lake City. The state will also be offering a virtual option to join the meeting.
“I can say now the intent is to submit (the waiver), but we will evaluate all the public comments that we receive … and take that into consideration as we evaluate the proposal that’s been drafted and consider what the next steps are,” Strohecker said. “But at this point, yes, the intent is to submit the waiver.”
‘Inefficiency and cruelty,’ advocates say of work requirements
Low-income, disability and health advocates are sounding alarms about state officials’ decision to pursue that work requirement again, raising concerns that it will impose administrative burdens on an already vulnerable population of Utahns and will inevitably result in loss of medical benefits for many.
“It’s forcing red tape upon people that will ultimately just act like scissors because it’s going to cut so much coverage,” said Stephanie Burdick, consumer representative on the state’s Medical Care Advisory Committee.
Evan Done, advocacy and public policy director for USARA, a nonprofit serving Utahns recovering from the effects of substance use disorders, said implementing the work requirements would be a cut to Medicaid, plain and simple.
It’s forcing red tape upon people that will ultimately just act like scissors because it’s going to cut so much coverage.
– Stephanie Burdick, consumer representative on the state’s Medical Care Advisory Committee
“A cut by any other name is still a cut,” Done said. “Medicaid serves as a vital lifeline for many Utahns. Evidence shows work requirements often cause people to lose healthcare coverage due to the administrative complexity of navigating the system, rather than an unwillingness to work. Utah’s attempt to implement a work requirement for Medicaid beneficiaries aims to save money by cutting otherwise deserving recipients from care.”
Nate Crippes with the Disability Law Center, an organization that advocates for Utahns with disabilities, also described the proposed work requirement as “nothing more than a cut to (Medicaid) services.”
“While the state has exempted people with disabilities, we know the paperwork required will also lead to numerous individuals with disabilities, especially those with mental illness, being kicked off of Medicaid,” Crippes said. “We are working hard to oppose cuts at the federal level, and we would encourage our state leaders to rescind this proposal and help us ensure that Medicaid is protected.”
Of the 75,000 enrolled in Utah’s Medicaid expansion program, 22,000 were homeless last year, according to DHHS estimates, and many have substance use or mental health conditions that they receive treatment for, Burdick said.
Burdick acknowledged that yes, 90% of Utahns enrolled in the state’s Medicaid expansion program would be exempt, “but how they prove that they’re exempt is where it becomes an administrative burden.”
Bill Tibbitts, deputy executive director of the Crossroads Urban Center, an advocacy group for low-income Utahns, encouraged state leaders to instead create a voluntary program to help people working low-wage jobs without healthcare benefits to get better jobs.
“People who are homeless and working out of their car do not need extra negative incentives to want to find a better job,” Tibbitts said. “Threatening to take away people’s healthcare if they do not do a bunch of busywork is not really helpful – especially if most of the 48 jobs people are being forced to apply for do not have better pay or provide health insurance benefits.”
Burdick urged state leaders to take a different route, not resort to requirements that will only create a “vicious cycle of inefficiency and cruelty.”
“(These people) deserve to be treated with dignity,” she said. “They don’t deserve to be stacked with paperwork that could lead to them losing coverage and potentially losing their life or having severely more negative health outcomes.”
Strohecker stressed that Utah’s yet-to-be filed waiver is not yet final, and state officials welcome feedback.
“This is a proposal. It can be modified, we can make adjustments based on the feedback that we get,” she said.
SUBSCRIBE: GET THE MORNING HEADLINES DELIVERED TO YOUR INBOX
Addressing advocates’ concerns, Strohecker said “there’s also opportunities to build good supports that will help people actually connect to training or education or even employment services. And what do those support services look like?”
Strohecker also pointed out some details that differentiate Utah’s proposed waiver. She noted that previously, if a person did not fulfill requirements for Medicaid coverage within the first three months, their coverage would be terminated.
“But in this iteration we’re actually suspending coverage, giving them additional opportunity to fulfill those requirements for an additional three months,” she said.
Strohecker also said in their proposal, state officials have “built in something that we’re calling member supports, and that’s to be defined as we work with CMS and work with our partners to really consider what are the opportunities that we have to really connect a person to job training to employment opportunities, to really fulfill some of the community engagement requirements that are outlined, and how do we support the individual along that pathway of compliance?”
That’s a “key piece that would be really helpful,” Strohecker said, to have partnership with our advocates and community stakeholders to really envision the array of services that we could build to assist the person in fulfilling community engagement and actually truly getting connected to job training, employment supports … that we could actually help facilitate that in a meaningful way.”
Why is Utah looking to re-impose work requirements on Medicaid expansion?
Strohecker said there’s important historical context that precedes state agency leaders’ decision to resubmit the waiver.
After Utah voters approved Medicaid expansion by a ballot initiative in 2018, the Republican-controlled Utah Legislature was forced to act. In 2019, the Utah Legislature passed legislation to implement the state’s Medicaid expansion program. Strohecker pointed to that law, which requires state officials to apply to CMS for a waiver that, among other provisions, includes “a path to self-sufficiency, including work activities” as defined by federal law.
In 2020, state officials included a work requirement in their waiver request, and after it was approved by CMS (at the time under Trump’s first administration) that requirement went into effect January that year. However, it only lasted a few months, because by April 2020 it was suspended amid the COVID-19 pandemic.
Then, in 2021, when Utah’s waiver was up for renewal, former President Joe Biden’s administration required the state to remove that work requirement.
Now, with Trump back in the White House and a new administration that’s likely to approve a waiver that includes a work requirement, Utah officials have decided to resubmit it.
“There is historic precedent to this, but also as we consider what’s happening on the federal side of things today, it is our intent to align our program with our current federal initiatives and priorities,” Strohecker said. “Certainly mandated work requirements are considered a top item by Congress as far as looking at the budget reconciliation package. And I think our intent was to align with sort of our past approved waiver, and this administration’s current initiatives.”
Pressed on who specifically made the decision to include the work requirement in the new waiver application, Strohecker said leaders of Utah Department of Health and Human Services ultimately made the decision, but that they also did so based on talks with legislators and Gov. Spencer Cox’s office.
“It’s actually a decision by the department to take this step,” she said. “It was definitely done in consultation with the governor’s office and lawmakers. But I would say it was a decision by the department.”
Advocates say Utah doesn’t need to pursue a new waiver — and shouldn’t
Burdick argues Utah’s Medicaid statute does not explicitly require state officials to submit the waiver again years after it was pulled back. She also contends it’s not needed, pointing out Utah’s Medicaid expansion fund “has gotten quite large,” with more than $300 million available to use.
“It’s not like they’re running out of money,” she said. “There’s definitely people who are eligible and not enrolled in Medicaid expansion right now. … We have a bunch of money, and yet we’re going to implement a work requirement?”
Utah is just the latest state to pursue the work requirement under the new federal landscape. Republicans in Congress and several other states including Ohio, Iowa and Montana are pushing to implement work requirements for nondisabled adults, arguing a mandate would encourage people to find jobs and ultimately reduce their need for public assistance, the health policy outlet KFF Health News reported. But, the outlet also pointed out, few programs actually help enrollees find jobs.
Under Trump, many states might pursue Medicaid work requirements
Last week, Paul Ray — who served as a Republican House lawmaker before resigning in 2021 and taking a position as director of legislative affairs for the DHHS — sent an email to lawmakers notifying them of the looming waiver request.
In that email, Ray said the state aims to implement the requirement (referred to as a “community engagement requirement”) to “increase an individual’s health and wellbeing through incentivizing work and community engagement; increase their sense of purpose; help build a healthy lifestyle; and increase employment and wage earnings of able-bodied adults while focusing funding on the state’s neediest individuals.”
However, Burdick argued states like Arkansas that have tried work requirements for Medicaid have found they were burdensome, led to adverse effects on even working adults, and resulted in loss of coverage for thousands. The Wisconsin Department of Health Services also recently issued a report estimating the financial impact of implementing work requirements, which would result in an increase of up to $6 million a year for administrative costs and $60 million a year for employment and training services.
Burdick said work requirements are actually less fiscally responsible — not more.
“You’re wasting taxpayer dollars by not spending the expansion money,” she said. “Then you’re going to take more taxpayer dollars to deal with the administrative burden.”
Asked about whether state officials have an estimated cost of what it would cost the state to implement its work requirements, Strohecker said given it’s still a proposal that has not yet been formalized, “we don’t have costs estimated.”
In response to calls to implement an employment support program rather than hinging Medicaid coverage on a work requirement, Strohecker said state officials “want that feedback” during the public comment period that’s now open.
“We’d like to hear what the public has to say regarding employment supports and how this could be meaningful for folks, recognizing that we’ll have to work to mitigate what could be an administrative barrier,” she said. “We could work through some of those challenges … to support individuals in achieving our goals.”
Below is a handout Utah’s DHHS provided that includes more details about Utah’s proposed work requirements:
