Medicaid Work Requirements Would Leave Brain Injury Survivors Behind

Washington, D.C. — Newly proposed work requirements for Medicaid recipients could have devastating consequences for people living with brain injury. While policymakers may argue that these measures promote workforce participation and personal responsibility, the reality is far more complex for people living with invisible disabilities.

“The effects of brain injury are often unseen to outside observers,” said Rick Willis, President and CEO of the Brain Injury Association of America. “Executive dysfunction, memory loss, communication difficulties, and behavioral changes can make it difficult for survivors to maintain consistent employment. Many people living with the lifelong effects of brain injury are currently using Medicaid and would face significant challenges without accommodations to the current proposal.”

Brain injury can develop into a chronic health condition, which has lifelong impacts on employment. According to research from the CDC, most people (55%) with moderate to severe TBI do not have a job 5 years after their injury.

The National Association of State Head Injury Administrators (NASHIA) is reporting that state administrators are already seeing gaps in care for individuals with brain injuries. The proposed work requirements risk widening these gaps further, particularly for people who live with significant daily challenges as a result of their brain injury but who may not qualify for the disability exemptions outlined in the legislation or are in the early stages of navigating disability systems.

“Survivors and their families are already juggling intense medical, emotional, and financial strain,” added Rebeccah Wolfkiel, NASHIA’s Executive Director. “Forcing people to jump through more hoops without appropriate exemptions, accommodations, or adequate support only delays care.”

BIAA and NASHIA are urging Congress to take the following steps, as outlined in a joint Policy Paper, before any work requirement is enacted:

1. Mandate Broad Exemptions for individuals with brain injuries, caregivers, and those actively engaged in rehabilitation or attempting to reenter the workforce.
2. Provide Testing for Medicaid applicants who suspect they may have an undiagnosed brain injury, such as screenings, evaluations, or assessments, so they can meet eligibility requirements without financial hardship.
3. Count gig and seasonal work as work for the purposes of Medicaid requirements to ensure coverage for those who may struggle with rigid hourly thresholds.
4. Count volunteer, education, and participation in brain injury resource facilitation, an evidence-based service that leads to increased employment for people with brain injury.
5. Mandate comprehensive reporting platform standards for every state to ensure that reporting is accessible and easy to do for those with disabilities.
6. Require Accessibility and Language Accommodations for any work reporting tools used at the state or federal level.
7. Expand Workforce Rehabilitation Services to ensure survivors have realistic pathways back to employment, if and when they are ready.

“Congress cannot treat Medicaid reform as a one-size-fits-all solution,” Willis said. “We urge lawmakers to listen to the lived experiences of people with brain injury and ensure no policy makes their path to recovery harder.”

People living with brain injury want to work, contribute, and lead fulfilling lives, but many struggle with their recovery and progress is rarely straightforward. Many are actively pursuing rehabilitation or transitional employment when they face the threat of losing Medicaid due to rigid work requirements. These proposals risk cutting off essential health services, therapies, and community support precisely when individuals are striving to regain independence.

Without thoughtful exemptions and safeguards, work requirements could unintentionally penalize the very people who are working hardest to rebuild their lives. Congress must ensure that these policies do not undermine recovery, stability, or the dignity of those living with brain injury.