D.C. may not be a state, but city officials are hoping that the federal government treats its wards like it would a state’s counties.
In a legally clever yet untested move, D.C. has asked the federal government for a waiver from new work requirements for Medicaid recipients that take effect in January, but only for residents living in Wards 7 and 8.
“Our primary concern is ensuring that residents do not unnecessarily lose Medicaid coverage because of barriers to meeting or documenting work requirements, particularly in communities where employment opportunities are more limited,” said Wayne Turnage, D.C.’s deputy mayor for health and human services. “The waiver is an important part of our broader effort to protect coverage while implementing the new federal requirements.”
The new work requirements — which apply to people who were able to qualify for Medicaid under an expansion written into the Affordable Care Act — were included in the Republican-sponsored One Big Beautiful Bill Act that Congress passed in 2025. They mandate that childless adults between the ages of 19 and 64 work, volunteer or participate in a training program 80 hours a month, or attend school at least half-time.
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Proponents say the requirements will help decrease federal Medicaid spending and minimize the number of working-age adults who may choose not to be employed, while critics argue that they could lead to millions of people losing health coverage — many because they have trouble navigating the complicated new rules.
The law includes a provision allowing states to apply for hardship exemptions for residents living in counties where the unemployment rate is above 8%. According to a survey conducted by KFF News, 133 counties in 22 states meet that threshold.
D.C. officials formally applied for the exemption last month, arguing that the city’s wards meet the definition of an “equivalent unit of local government” as outlined in federal guidance on the work requirements.
While the overall unemployment in D.C. was 5.6% in September, it stood at 9.5% and 10% in wards 7 and 8, respectively. Both wards are predominantly Black, and they have the lowest median household incomes in the city: $71,000 and $52,000, respectively, below the citywide average of $109,000 and the high of $144,000 in Ward 3.
The impending work requirements are expected to fall hardest on residents in the two wards east of the Anacostia River. While 75,000 Medicaid-eligible D.C. residents could be subject to the new work requirements when they take effect in January, city officials say that 30,000 of them have addresses in those two wards. (There are roughly 260,000 residents in D.C. enrolled in Medicaid.)
“It is a novel approach to be asking [the federal government] to treat wards as if they are counties,” said At Large council member Christina Henderson, who chairs the D.C. Council’s health committee. “But it creates inequities in our system because it’s not that someone’s ward is why they can’t find work. There are people in Ward 3 who are on Medicaid and have the same difficulties. I feel a little uneasy, but here we are.”
Henderson recently held a hearing on the city’s preparations for the start of the new Medicaid work requirements and also the implementation of new work requirements for recipients of SNAP food benefits that started taking effect over the summer. She told The Washington Sun she’s concerned that not enough is being done to prepare residents who may stand to lose benefits.
“I think we are woefully unprepared,” she said. “There are a lot of residents who have no idea what is coming in terms of the changes, and I wish there was more coordination amongst the government agencies and community organizations who have day-to-day contact with consumers of these benefits.”
Jessica Berger, an attorney with Legal Aid D.C., told the council that city agencies fell short on informing potentially affected residents of the new work requirements for SNAP, opting instead for mass communications that “caused confusion and fear.”
Before those work requirements kicked in, there were roughly 130,000 people in D.C. receiving SNAP. A significant majority are classified as being exempt from the new requirements, but by October the overall number of SNAP recipients dropped to fewer than 120,000. Some advocates say misunderstandings over what the work requirements are and who is exempt led to people choosing to unenroll, even though they may not have had to.
Hannah Eichner, an attorney at Bread for the City, similarly raised concerns with how D.C. is communicating with residents about the changes to Medicaid and SNAP, while also saying that city agencies “are in an impossible position, due to rapid and catastrophic policy shifts by the federal government.”
The landscape around the Medicaid work requirements continues changing, even with January being less than two months off. Late last month, a federal judge in Massachusetts handed a number of states and D.C. a win, ruling against the federal government and lowering the burden of proof that people will have to show to qualify for an exemption to the work requirements based on medical frailty.
In a statement, a spokesperson for Turnage said D.C. is implementing a “comprehensive outreach and implementation strategy” to let residents know about the impending Medicaid work requirements. “Our goal is not simply to inform residents — it is to help individuals navigate the changes and minimize avoidable losses of Medicaid coverage,” the spokesperson said.
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