WASHINGTON — The Centers for Medicare and Medicaid Services issued an interim final rule on June 1 implementing new federal Medicaid work requirements for certain adults, advancing the rollout of a policy enacted in last year’s reconciliation legislation, officials said.
The rule provides guidance to states on the community engagement requirement, which generally applies to adults ages 19 to 64 in the Affordable Care Act Medicaid expansion population and certain partial expansion programs. It takes effect no later than Jan. 1, 2027, though some states may begin earlier, according to the Centers for Medicare and Medicaid Services.
Under the policy from the 2025 reconciliation law, known as H.R. 1 or the One Big Beautiful Bill and signed by President Donald Trump on July 4, 2025, affected individuals must complete at least 80 hours per month of qualifying activities — such as employment, education at least half-time, job training or community service — or meet an exemption to maintain eligibility.
Exemptions include pregnant or postpartum individuals, people with disabilities, parents or caregivers of young children or those with disabilities, older adults, former foster youth and others specified in the law and rule.
"This rule establishes the standards states must use to implement the statutory work requirement, including clear expectations for eligibility determinations, exemptions, verification, and state reporting requirements," CMS said in a June 1 statement.
The requirement builds on prior state-level experiments under Section 1115 waivers and aligns Medicaid with work rules in programs such as the Supplemental Nutrition Assistance Program. States must make system changes, update forms and conduct outreach, with initial notices to enrollees required months ahead of implementation.
Some states have already moved forward. Nebraska implemented early, while others like Montana and Iowa plan to begin before the federal deadline, according to tracking by policy organizations.
Supporters, including administration officials, have described the measure as promoting employment and accountability in the program. Critics, including consumer advocates and some state officials, have raised concerns about administrative burdens, potential coverage losses and challenges for individuals with barriers to consistent work, such as intermittent employment or health conditions that do not qualify for exemptions.
Estimates of potential coverage impacts vary. Projections from groups like the Urban Institute have suggested millions could lose eligibility over time due to the requirements and verification processes, though actual outcomes will depend on implementation, exemptions and state actions.
States can request good-faith extensions until the end of 2028, and the rule includes provisions for verification and reporting. Details on final enrollment effects and state-by-state rollout timelines remain subject to ongoing planning and potential adjustments.
As of mid-June 2026, states are preparing operational changes while CMS accepts public comments on the interim final rule. Federal officials and independent analysts continue to monitor preparation efforts ahead of the 2027 deadline.
