NWLC Submits Comments Opposing Disastrous Work Requirements Interim Final Rule

On July 30, 2026, the National Women’s Law Center submitted a comment opposing the U.S. Department of Health and Human Services’ Medicaid work requirements Interim Final Rule (IFR) and calling for it to be rescinded.

Our comment explains that the IFR runs contrary to the Medicaid statute and contains exclusions processes that are more restrictive than the statutory text. This IFR will lead to widespread loss of Medicaid coverage in populations intended to be excluded from the requirement and especially harm disabled women, women of color, women with high health needs, and caregivers.