On May 9, 2025, the National Women’s Law Center submitted a comment opposing work reporting requirements and other proposed policies that would harm many Medicaid enrollees in Arizona.

Arizona’s government has asked the Department of Health and Human Services to approve a Section 1115 waiver application—an option meant to allow states to pursue innovative approaches in Medicaid that advance the program’s goals of expanding coverage. But Arizona’s application tries to impose policies that would lead many Medicaid enrollees to lose their coverage, such as work reporting requirements and lifetime caps on coverage.

Our comment explains that this application runs contrary to the Medicaid statute and so must be rejected. We lay out why it would lead to widespread loss of Medicaid coverage, especially harming women of color, disabled women, and women overall.

The full comment can be found here.