Court/Government

Federal appeals court strikes down Arkansas Medicaid ‘work requirement’ approved by Trump administration

A federal appeals court has struck down the Trump administration’s approval of a work requirement provision the state of Arkansas added to recipients of Medicaid a healthcare program for poor Americans.

A three-judge panel of the U.S. Court of Appeals for the D.C. Circuit upheld a lower federal court’s ruling that Department of Health and Human Services Secretary Alex Azar behaved in an “arbitrary and capricious manner” for approving an Arkansas plan to add the work and community engagement requirements to Medicaid program recipients.



Under the program, states can deviate from minimum coverage requirements if they are first approved by the HHS secretary.

The secretary can authorize “any experimental, pilot, or demonstration project which, in the judgment of the secretary, is likely to assist in promoting the objectives” of Medicaid, according to the law.

Several states including Arkansas and Kentucky, have requested HHS approval to impose some work and community engagement requirements to qualify for Medicaid eligibility.




Under the plan, enrollees must work or begin educational or job training activities, or look for work for at least 80 hours per month.

The appeals case did not center on the work requirements contained in the law but rather Azar’s approval of the Arkansas plan.

Opponents argued that the plan would have led thousands to lose healthcare coverage.

Kentucky elected a Democratic governor in 2018, who then dumped the work requirements, thus ending the case against his state.

Judge David Sentelle, an appointee of President Reagan, wrote in the opinion that Azar didn’t appropriately consider the statutory purpose if Medicaid, which is to provide medical coverage to the needy. Rather, Sentelle said, Azar focused primarily on alternative objectives such as improving health outcomes and encouraging beneficiaries of the program to obtain and maintain employment or undertake community engagement.



“The Secretary’s approval of the Arkansas Works Amendments is arbitrary and capricious because it did not address—despite receiving substantial comments on the matter—whether and how the project would implicate the ‘core’ objective of Medicaid: the provision of medical coverage to the needy,” he wrote.

“We agree with the district court that the alternative objectives of better health outcomes and beneficiary independence are not consistent with Medicaid. The text of the statute includes one primary purpose, which is providing health care coverage without any restriction geared to healthy outcomes, financial independence or transition to commercial coverage,” Sentelle wrote.

It’s not clear how the ruling will affect other states that reimposed work requirements, which were originally part of “Workfare” legislation signed into law by President Bill Clinton in the 1990s. It’s also unclear if the administration will appeal the ruling to the Supreme Court.


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