Medicaid Unwinding and Work Requirements: Endangering Access to Healthcare

Within the complex American healthcare system, Medicaid stands as an essential lifeline for low-income individuals and people with disabilities. Medicaid became even more critical for supporting people’s health during COVID. During the pandemic, it is estimated that the number of Medicaid members grew from 23.3 million to nearly 95 million.[1] However, there is a growing concern for this population with the end of continuous coverage requirements. In a concerted effort to respond to the pandemic, the federal government introduced protections and flexibilities for Medicaid across the United States. This waived Center for Medicare & Medicaid (CMS) rules for their typical annual renewal process so people would only be disenrolled if they requested, moved out of state, or passed away.

However, the continuous coverage provision’s end date changed to March 31 when Congress passed an omnibus spending bill in December 2022 that decoupled the rule from the Public Health Emergency (PHE). Therefore, beginning April 1, states were permitted to resume regular Medicaid eligibility redeterminations and disenrollments. It is anticipated that hundreds of thousands of people in Illinois (millions throughout the country) will be at risk of losing access to healthcare during this “unwinding” period. Not only that, House Republicans have since proposed a debt ceiling bill with the condition to add work requirements for certain Medicaid members. The potential consequences of all these changes raise serious concerns about the well-being of vulnerable populations and the overall accessibility of healthcare services.

 The Unwinding of Medicaid Continuous Enrollment in Illinois

Illinoisans insured by Medicaid have benefitted from the temporary suspension of continuous coverage requirements during the pandemic. This allowed these individuals to maintain their Medicaid coverage without having to undergo the burdensome annual renewal process. However, with the expiration of this provision, the state is now poised to reinstate disenrollment practices, leaving as many as 700,000 Illinoisans at risk of losing their vital healthcare coverage.[2]

In Illinois, beginning the first week of May, Medicaid members will begin to receive renewal notices in the mail from the Illinois Department of Human Services (DHS). The first one-twelfth of members will receive renewals, with responses due back no later than June 15 to avoid a potential termination by July 1. Renewals will continue throughout this upcoming year. To find out their renewal date, Medicaid members are encouraged to either check online in’s “Manage My Case” under the Benefit Details section or call the DHS Customer Help Line (PH: 800-843-6154) with their Recipient Identification Number (RIN). Members may also be renewed electronically when the State has enough information to do so, termed “ex parte”.[3] We hope to see high number of “ex parte” renewals to reduce people being terminated for procedural reasons not related to ineligibility.

Nevertheless, we do expect such procedural terminations to occur in some volume, with serious consequences for Medicaid members. Medicaid members who have disabilities and older adults, who are terminated despite remaining eligible, will face challenges accessing medications, medical equipment, and specialty care in particular.  Procedural terminations could lead to delayed or neglected medical treatment, worsening health outcomes, and increased financial burden for individuals who may have to pay out-of-pocket for services that Medicaid would have covered.

Legal Council for Health Justice is actively engaged in addressing the challenges posed by the unwinding of continuous Medicaid. Our teams are working closely with current clients to navigate the sometimes difficult processes involved in maintaining their health insurance. Additionally, Legal Council continues to accept referrals from our health partners for individuals who face termination and need assistance to appeal their cases. Additionally, our organization closely monitors the state’s communications regarding Medicaid policy changes to stay informed and share relevant information with stakeholders. Our advocacy work plays a crucial role in providing feedback when systemic issues arise and promoting legislative changes to protect Medicaid members’ rights. It is important to Legal Council for Health Justice’s mission to assist Medicaid members to overcome these challenging times and ensure access to healthcare for all.

The Debt Ceiling Proposal & Medicaid Work Provisions

As if the potential disenrollment crisis were not alarming enough, there is also an effort in the U.S. House to introduce a debt ceiling bill that includes work requirements for Medicaid members. Under House Speaker Kevin McCarthy’s proposal, individuals covered by the Affordable Care Act (ACA)’s expansion would need to demonstrate compliance with employment or job training programs to maintain their Medicaid eligibility. This policy would target “able-bodied adults without dependents”  between the ages of 19-55, putting 10 million people (or 1 in 5 of members living in states that chose to expand ACA Medicaid coverage) in jeopardy of losing their coverage. In Illinois, over 500,000 individuals, or about 21% of all members would be at risk. Furthermore, the McCarthy proposal could dissuade states from adopting the ACA expansion or even causing others to consider dropping it.[4]

Similar state-imposed work requirements during the previous federal administration were proven to be merely a tool to terminate eligibility that served no legitimate policy interests. Back in 2018, Arkansas implemented such work requirements for Medicaid. As a result, 18,000 members lost coverage in just 7 months and people reported having to delay care, ration medication, or incur medical debt.[5] While proponents of this change alleged that they sought to increase employment rates, what ultimately happened was that the work requirements instead made thousands of Arkansans become uninsured. Moreover, of those terminated, many said they never even knew about the work requirement policy or were having difficulty reporting their working hours or requesting exemptions.  Rather than increasing employment, work requirements are designed to save federal money by shifting costs to states and increasing the burdens on low-income people.[6]

The evidence also shows that work requirements hurt people with disabilities. Work requirements are fundamentally based on ableist assumptions that everyone can work, and that it is easy to identify when someone cannot. People with disabilities already face numerous barriers in the workforce with inadequate support systems, discrimination, and workplace exploitation. This could inevitably put people with disabilities in the difficult position of either claiming to be “unfit” for employment to seek an exemption or risk losing access to benefits if they cannot obtain employment due to the many barriers stacked against them. And, even when they request an exemption, Arkansas’s previous experiment with work requirements shows that the administrative burdens involved cause people with disabilities to wrongfully lose coverage.

Legal Council will fight any attempts to impose work requirements on the program with every tool in our advocacy toolkit.


The unwinding of Medicaid continuous enrollment and the proposed work requirements tied to debt ceiling negotiations pose significant challenges in Illinois and across the United States. The end of the continuous coverage provision puts hundreds of thousands of Illinoisans at risk of losing their vital healthcare coverage. Furthermore, the introduction of work requirements for certain Medicaid members, as proposed by House Republicans, adds to the concerns.

We all must ensure that healthcare remains accessible and affordable, regardless of income, legal status, race or other identities, or ability to work. It is imperative for policymakers and stakeholders to work together to protect and strengthen Medicaid. By prioritizing the needs of vulnerable populations and promoting equitable access to healthcare, we can strive for a society where everyone has the opportunity to lead a healthy and fulfilling life.

[1] Tolbert, Jennifer and Meghana Ammula. “10 Things to Know about the Unwinding of the Medicaid Continuous Enrollment Provision.” KFF, 05 Apr. 2023,

[2] Schencker, Lisa. “As Many as 700,000 Illinois residents could lose Medicaid health coverage this year”. Chicago Tribune. 28 Feb. 2023,

[3] Ibid.

[4] Lukens, Gideon. “McCarthy Medicaid Proposal Puts Millions of People in Expansion States at Risk of Losing Health Coverage”. Center on Budget and Policy Priorities. 21 Apr. 2023,

[5] Youdelman, Mara and David Machledt. “Top 10 Reasons Why Speaker McCarthy’s Work Requirements Are Bad for Medicaid”. National Health Law Program. 26 Apr. 2023,

[6] Machledt, David. “‘Unfit’ to Work? How Medicaid Work Requirements Hurt People with Disabilities”. National Health Law Program. 15 May 2023,