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"Efforts to undercut or undermine Medicaid for the children who rely on it are a bet against the future of the country," said the president of the American Academy of Pediatrics.
The American Academy of Pediatrics warned Wednesday that the Trump administration's new rule governing Medicaid work requirements will damage the health of children across the US, as additional bureaucratic barriers make it more difficult for families to access and maintain coverage.
AAP, the largest professional association of pediatricians in the country, said it "strongly opposes" the rule unveiled by the Centers for Medicare and Medicaid Services (CMS) earlier this week, calling it "an intentional policy choice that will harm children’s long-term health and well-being." The group said the rule should be rescinded.
“When parents have healthcare coverage, their children are more likely to be covered and stay covered over time, allowing uninterrupted access to the care they need to grow up healthy," said Andrew Racine, AAP's president. "Work requirements have not been shown to help adults gain employment. Instead, the added red tape makes it more difficult for eligible people to stay enrolled in Medicaid and makes the program less efficient overall. These administrative barriers will disproportionately hurt people with disabilities, and parents of children with special healthcare needs will lose coverage."
"The new burdensome requirements that many parents will face under this rule will ultimately undermine families’ health and financial stability," Racine added. "The policies to narrowly define who qualifies for exemptions will add to the state costs to administer the program, create headaches for families trying to navigate the bureaucracy, and harm the very people that Medicaid is meant to serve. Medicaid is a program designed around the needs of children. Efforts to undercut or undermine Medicaid for the children who rely on it are a bet against the future of the country."
Analysts and advocacy groups have said the Trump administration's rule, which implements work requirements included in a Republican budget law enacted last summer, will likely push millions of people off Medicaid—including many who are eligible but fail to comply with complex new reporting procedures.
The Center on Budget and Policy Priorities (CBPP) noted in Wednesday analysis that state agencies "will have to significantly re-work policy and systems" in light of the new rule, likely resulting in "errors and delays that could affect health coverage and care for the entire Medicaid population—including groups to whom the work requirement doesn’t apply, such as children, seniors, and people with disabilities."
Nearly half of all children in the US are enrolled in Medicaid or the Children's Health Insurance Program (CHIP). A recent analysis by the Center for Children and Families at Georgetown University found that two million fewer children were enrolled in Medicaid in April compared to the start of President Donald Trump's second White House term—and the number of uninsured kids is expected to grow as the GOP budget law's unprecedented Medicaid cuts take hold.
In addition to its impacts on children, critics say the new CMS rule will harm people with serious illnesses such as cancer and HIV/AIDS. The rule does not necessarily exempt such people from the Medicaid work mandates, which require certain program enrollees to document at least 80 hours per week of employment or related activities. The requirement is set to take effect nationwide in January 2027.
Carl Schmid, executive director of the HIV+Hepatitis Policy Institute, said in a statement earlier this week that the Trump administration's new rule appears to run afoul of the law.
"People who have special medical needs, including those with a serious or complex medical condition, are statutorily exempt from the community engagement requirement," said Schmid. "People living with HIV have a lifelong serious and complex medical condition and have special medical needs—they cannot stay healthy without continuous access to lifesaving HIV treatment. Any gap will put them at risk of serious health consequences."
"We are disappointed that the Trump administration ignored the law and, while they agree that HIV/AIDS and viral hepatitis are serious or complex medical conditions, they are proposing that states will have to determine for every individual if their health is impaired and that they can’t comply with the work requirement," Schmid continued. "This added requirement was not in the law and puts the health of people living with HIV and viral hepatitis at risk."
The Trump administration on Monday unveiled a rule that is expected to push millions of low-income people off Medicaid by imposing complex bureaucratic barriers in the form of work reporting requirements, which have proven disastrous at the state level.
The rule, released by the Centers for Medicare and Medicaid Services (CMS), marks a key step toward enacting the Republican budget reconciliation package that President Donald Trump signed into law last summer. That measure included around $900 billion in cuts to Medicaid, with new work requirements projected to account for nearly $330 billion of that total.
The new rule will dictate how states must implement the budget law's Medicaid work mandates and who is exempt from the requirements. States are already spending tens of millions of dollars hiring new staff and upgrading technology in preparation for the mandates taking effect next year.
Broadly, the Trump-GOP law requires adults without disabilities between the ages of 19 and 64 to demonstrate at least 80 hours of work, community service, or other "qualifying activities" per month to keep their Medicaid coverage.
Exemptions to the work reporting requirements include people who are pregnant, caregivers to children under the age of 14, or "medically frail." The CMS rule defines the latter category as those with "physical or behavioral health conditions that significantly impair their ability to consistently work or participate in other community engagement activities."
Advocates warned that the rule will force many sick people off coverage. The rule states that people with HIV/AIDS, end-stage renal disease, and cancer would not necessarily be exempt from the work reporting requirements.
According to The New York Times, "states had expected that people with certain serious diagnoses would qualify for the exception, and they had been developing ways to match applications with existing medical records to identify most such people automatically."
"Nebraska’s Medicaid program, which began enforcing a work requirement last month, developed a list of exempted conditions that is nearly 300 pages long," the Times reported. "The state will now need to adjust."
"When these requirements go into effect at the beginning of next year, it’s going to be a complete train wreck for America."
Anthony Wright, executive director of Families USA, said Monday that "far from protecting the vulnerable, this guidance significantly raises the barrier for demonstrating medical frailty, meaning many patients in the middle of treatment will have the new hassle of proving their condition, over and over, with any mistake or gap being penalized by the loss of their healthcare and coverage."
"Through this rule," said Wright, "CMS is requiring duplicative documentation and prohibiting states from taking full advantage of consumer-friendly tools like self-attestation."
During the first year of the work reporting requirements, which are set to take effect nationwide in January 2027, people will be allowed to attest in Medicaid applications that they meet one of the exemptions, according to administration officials.
"Beginning in 2028, states will be expected to verify the exemptions," NBC News reported. "The temporary flexibility, the officials said, is intended to give states time to build systems that can verify exemptions using claims data and other records."
The advocacy group Protect Our Care warned that the new rule "creates a labyrinth of paperwork, reporting mandates, and rigid eligibility rules designed to ensure people lose healthcare, even when they should qualify to keep it."
“Instead of lowering costs or making care more accessible, Republicans are weaponizing government bureaucracy against the American people," said Brad Woodhouse, the president of Protect Our Care. "They are betting that if they make the process confusing and exhausting enough, millions of people will fall through the cracks and lose the care they depend on to survive. Hospitals will suffer, providers will be pushed further to the brink, and families across the country will pay the price while Republicans once again put wealthy donors and corporate greed ahead of the health and well-being of everyday Americans.”
The nonpartisan Congressional Budget Office has projected that, over the next decade, the Trump-GOP work reporting requirements will push nearly 3 million people off Medicaid.
Sen. Ron Wyden (D-Ore.), the top Democrat on the Senate Finance Committee, said in a statement that the CMS rule "is the dark heart of the Republican plan to kick millions of working Americans and their children off their health insurance by placing a mountain of paperwork in front of them."
"These barriers are designed to prevent Americans from getting affordable healthcare, while providing a profit bonanza for the corporate consultants who get paid millions to build bureaucratic booby traps," Wyden added. "The Republican plan for healthcare is to kick people when they are down, making sick people sicker and hard times even harder. When these requirements go into effect at the beginning of next year, it’s going to be a complete train wreck for America, and not just for the Americans caught in the bureaucratic maze Republicans have created: Every community will be left with worse healthcare."
“These work requirements address a problem that doesn’t exist," said one researcher. "They just strip healthcare from millions of low-income people by making it harder for them to prove they qualify.”
A pair of leading humanitarian groups warned Tuesday that millions of people will soon be "at risk of an avoidable loss of healthcare coverage" as states move to implement new Medicaid work requirements, which were at the center of the reconciliation package enacted by congressional Republicans and President Donald Trump last year.
Oxfam America and Human Rights Watch (HRW) warned in a joint letter to top federal health officials that the work requirements—which mostly target adults in states that expanded Medicaid under the Affordable Care Act—will result in a massive surge in the uninsured population if concrete steps aren't taken to mitigate coverage losses.
The groups point to a Congressional Budget Office analysis projecting the Trump-GOP budget law "will cause roughly 10 million people to lose health insurance coverage by 2034," increasing "the number of uninsured people in the US by nearly 50%, exposing millions of people to high drug and hospital costs, and forcing many to forgo or ration healthcare."
Under the 2025 law, people subject to the work requirements must document 80 hours per month of work or another qualifying activity.
"Work requirements are sold as sensible, pragmatic reforms, but the lived reality couldn’t be more different."
Analysts have warned that the new work reporting mandates—which account for around $326 billion of the Trump-GOP law's total cuts to Medicaid—will create massive administrative hurdles and burdens for Medicaid recipients and for states. Given that most Medicaid recipients already work, experts say coverage loss from the new mandates will largely be attributable to enrollees' failure to comply with byzantine reporting procedures.
“Work requirements are sold as sensible, pragmatic reforms, but the lived reality couldn’t be more different,” said Jackson Gandour, senior policy advisor for economic justice at Oxfam America. “In practice, evidence shows they can create unfair and effectively insurmountable barriers for people who need coverage and are making every effort to meet the requirements.”
The federal work requirements are set to formally take effect in most states by January 2027—though some states are rushing forward with the mandates ahead of schedule, heightening fears of chaos and large-scale coverage loss. By June 1, federal agencies must issue guidance to states on how to implement the new Medicaid work requirements.
Oxfam and HRW urged the Trump administration to do all it can to mitigate coverage loss, including by "reducing documentation requirements, broadly interpreting exemptions, and recognizing a wide range of qualifying activities that reflect real labor conditions, including gig work, unpaid caregiving, and seasonal employment."
A 36-year-old woman in Atlanta, Georgia—which has state-level work requirements that predate the Trump-GOP mandates—told the humanitarian groups that she lost Medicaid and nutrition assistance after her child was born late last year, despite working sufficient hours to comply with Georgia's requirements.
“After I had the baby, my Medicaid and food stamps were turned off,” she said. “[They] said that I failed to report that I was working."
The woman said she's spent months trying to restore her coverage, encountering chaos and administrative barriers.
“It’s hectic,” she said. “You’re not able to reach anybody.”
The Urban Institute has estimated that even if strong mitigation measures are put in place, around 3 million people could lose Medicaid coverage due to the new federal work requirements.
“These work requirements address a problem that doesn’t exist since most Medicaid recipients are already working,” said Matt McConnell, economic justice and rights researcher at Human Rights Watch. “They won’t fix the budget. They just strip healthcare from millions of low-income people by making it harder for them to prove they qualify.”