Georgia Study Links Work Requirements to Mental Health Outcomes
A study published in the medical journal JAMA suggests that work requirements under Georgia's Pathways to Coverage program may be worsening mental health outcomes.
The research was co-authored by Joanne Constantin of SUNY Downstate University. The analysis utilized responses from the national Behavioral Risk Factor Surveillance System across five states, including Georgia.
Finding: Increase in Reported Poor Mental Health
According to the study findings, the start of Georgia's Pathways program in 2023 was associated with an increase in the number of days eligible low-income adults reported having poor mental health or a diagnosis of depression. This trend included individuals who were not enrolled in the Pathways program.
Program Requirements and Denial Rates
Under Georgia's Pathways to Coverage program, eligible low-income adults are required to report 80 hours of work every month to qualify for healthcare coverage.
The study noted that this requirement has created administrative hurdles for many enrollees. Consequently, the number of enrollments is fewer than state leaders initially projected.
Georgia's own evaluation indicated that 28% of eligible individuals were denied coverage due to not meeting qualifying hours and activities (QHA) requirements. Additionally, Georgia's own evaluation indicated that 39% of eligible individuals aged 50-64 were denied coverage for failing to meet the QHA requirement.
Lack of Explicit Exemptions
Medicaid is a significant insurer for individuals with mental health and substance use disorders. However, Georgia's Pathways program does not include explicit exemptions for these conditions. "Good cause" exemptions generally cover temporary and serious illness rather than chronic conditions.
Federal Mandates and CMS Rules
Recent federal legislation mandates that 40 states with Affordable Care Act (ACA) Medicaid expansion implement work requirements by January 1, 2027. The Centers for Medicare & Medicaid Services (CMS) issued an interim final rule on June 3, 2026.
This CMS rule establishes a community engagement requirement for certain adult Medicaid applicants and enrollees aged 19-64. The federal requirements include exemptions for "medically frail" individuals, encompassing those with disabling mental disorders and substance use disorders (SUDs), as well as participation in an SUD treatment program.
Concerns Regarding Exemption Processes
Advocates express concern that bureaucratic challenges in proving eligibility for exemptions may still lead to coverage loss for individuals with SUDs and mental health conditions, despite the federal language regarding medically frail status.
Perspectives on Work Requirements
Proponents of work requirements, including CMS, suggest they can promote employment and self-sufficiency. One study cited by CMS estimates a potential reduction in poverty for up to 2.9 million people due to the implementation of such work requirements.
In contrast, other research indicates that work requirements often do not increase employment rates and can lead to a loss of health insurance coverage. In Arkansas, over 18,000 people lost Medicaid coverage when work requirements were implemented.
Impact on Health Access
Studies suggest that access to Medicaid coverage itself is linked to improved health and increased employment, particularly for individuals with significant health issues. Policies resulting in parents losing Medicaid coverage could negatively impact their access to care, financial stability, and health outcomes.
Such impacts on parents may harm their children's well-being, including mental health.

