Ohio’s Proposed Demonstration Waiver
In February 2025, the State of Ohio applied for a Section 1115 Medicaid demonstration waiver that would restrict eligibility for Ohio’s Medicaid expansion program among adults ages 19–55 to those who are employed, enrolled in school or job training, participating in alcohol or drug treatment, or have intensive physical health care needs or serious mental illness. The state anticipates that approximately 62,000 adults, or 8 percent of those expected to be enrolled in its expansion group in 2026, will not meet these eligibility criteria and will be disenrolled from Medicaid in the first year of the waiver, after which the state expects steady enrollment growth.
Our Comments
In a public comment letter submitted to the Centers for Medicare & Medicaid Services, Urban Institute researchers draw on a recent analysis of a federal Medicaid work requirement policy examining potential national and state-level coverage impacts. They provide evidence that coverage losses under Ohio’s waiver are likely to be much higher than projected by the state, with the largest negative impacts on vulnerable adults and with coverage losses accumulating over time.
Although the state estimates that 92 percent of Ohio expansion enrollees would meet the new eligibility criteria, Urban researchers note that this figure is substantially higher than the share of expansion adults who were deemed exempt or compliant with work requirements under prior waivers in two states, Arkansas and New Hampshire, even though those states offered broader exemptions compared with Ohio’s waiver. They estimate between 158,000 and 180,000 expansion adults ages 19–55 in Ohio would lose Medicaid eligibility in 2026 under a work requirement modeled on a 2023 House bill, assuming implementation processes are similar to those observed in Arkansas and New Hampshire. Potential coverage losses in Ohio could exceed 200,000 if expansion enrollment prior to waiver implementation in 2026 is as high as the state of Ohio expects, which is more than three times higher than the projected loss of coverage of 62,000 in the state’s waiver application.
The letter highlights elements of the program’s design that would likely result in substantial loss of coverage and health care for adults with serious health conditions and disabilities, pregnant women, family caregivers, students, workers, and job seekers. This in turn would reduce receipt of critical health services, including diagnosis and treatment of chronic health conditions and life-threatening illnesses, while causing financial strain for health care providers facing increased uncompensated care burdens. Urban researchers conclude that the waiver is unlikely to increase employment and would shift state Medicaid spending from providing medical care to supporting administrative processes and staff to implement more complex eligibility screening requirements and determine exemptions.
