Federal Circuit Court Upholds Decision Prohibiting Medicaid Work Requirements

On February 14, 2020, a federal circuit court in Washington, D.C., upheld a district court decision that the federal Department of Health and Human Services (HHS) acted capriciously when it approved Medicaid waivers submitted by Arkansas and Kentucky to impose community engagement and work requirements as a condition of Medicaid eligibility. The circuit court upheld the district court ruling vacating HHS approval for the waivers.

The District Court for the District of Columbia had previously held that HHS had acted in an arbitrary and capricious manner because it failed to analyze whether the waiver demonstrations would promote Medicaid’s . . .