On July 11, 2025, the National Women’s Law Center submitted a comment opposing work requirements that would harm many Medicaid enrollees in Iowa.

Iowa’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 to Medicaid that expand the program’s goals of expanding coverage. But Iowa’s application seeks to impose work requirements that would lead many Medicaid enrollees to lose their 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 comment can be found here.