Appeals Court rules Trump’s medicaid work requirements violates the Administrative Procedure Act

A federal appeals court on Friday ruled against Trump-approved Medicaid work requirements in Arkansas, the latest legal setback to the administration’s efforts to remake the safety net health care program.

A three judge panel in a unanimous ruling said HHS didn’t have the authority to require some Medicaid enrollees to work in order to receive coverage.

The decision, which upheld a lower court ruling against the work requirements, brings the Trump administration’s Medicaid overhaul closer to possible review from the Supreme Court. For the first time in Medicaid’s history, the administration has allowed states to condition coverage for some enrollees on whether they work or participate in a similar activity, like job training, volunteering or attending school.


According to the National Health Law Program, “the panel found that in approving the project without considering its effect on Medicaid coverage, the U.S. Department of Health and Human Services violated the Administrative Procedure Act.”

National Health Law Program Legal Director Jane Perkins celebrated the ruling, saying, “We are gratified by the court’s ruling today. It means that thousands of low-income people in Arkansas will maintain their health insurance coverage — coverage that enables them to live, work, and participate as fully as they can in their communities.”

Perkins also noted the sound legal justification behind the ruling, “Section 1115 of the Social Security Act only allows the Secretary to approve experimental projects that further the Medicaid Act’s purpose. As Judge Sentelle’s opinion repeatedly notes, the text of the Medicaid Act is clear as to this purpose – to provide health care coverage. The agency was bound by the purpose Congress selected and could not change it as it attempted to do. Only Congress can do that.”

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