Ohio’s path toward Medicaid work requirements was initially shaped by the Ohio General Assembly, which twice required the state to seek federal approval for such policies. The legislature first mandated Medicaid work requirements in the state budget adopted for 2017–2018, directing the Ohio Department of Medicaid (ODM) to submit a Section 1115 demonstration waiver to Centers for Medicare and Medicaid Services (CMS). In response, ODM submitted a waiver in 2019 proposing that Medicaid expansion adults complete 80 hours per month of work or community engagement as a condition of eligibility. That waiver was approved in early 2020 during the first Trump administration, but implementation was halted due to the COVID-19 pandemic, and then CMS, under the Biden administration, formally withdrew approval in 2021.
The legislature renewed its directive in the FY 2024–2025 state budget (House Bill 33), again requiring ODM to pursue a work requirement waiver for Medicaid expansion adults—this time structured around a20-hour-per-week standard. ODM submitted the waiver to CMS as required.
However, the environment shifted dramatically in July 2025 with the passage of the One Big Beautiful Bill Act (H.R.1). The law established a nationwide Work and Community Engagement Requirement, mandating that non-exempt Medicaid adults ages 19–64 document 80 hours per month of employment or qualifying community engagement activities.
This federal requirement supersedes Ohio’s pending waiver and places the state on a hard implementation timeline, with full enforcement required no later than January 1, 2027.
On Friday, November 7 and Wednesday, November 12 the Ohio Department of Medicaid hosted a webinar featuring Patrick Beatty, Deputy Director – Chief Policy Officer, discussing how ODM plans to operationalize the new federal law. It offered the most detailed picture yet of how Ohio will move forward, how Medicaid beneficiaries will be affected, and what partners across the state should prepare for as implementation moves forward.
