Get Ready for Upcoming Medicaid Work Requirements
Published June 23, 2026 | By Miriam Lipschutz, MPP
This blog was updated on August 27, 2026.
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Almost 20 million adults will be impacted next year by new Medicaid work and community engagement requirements. A new Interim Final Rule (IFR) from the Centers for Medicare & Medicaid Services (CMS) details for states how to implement these new requirements.
As states prepare to implement these rules, communities will depend on trusted messengers and enrollment assisters to deliver clear messaging, resources, and hands-on support to ensure individuals and families keep their health coverage.
Medicaid Work Requirements at a Glance
- Origin: One Big Beautiful Bill Act, or H.R. 1, passed in July 2025
- Effective Date: January 1, 2027, or earlier at state option
- Requirements: Demonstrate working or volunteering for 80 hours a month or attending school half-time, as a part of Medicaid eligibility
- Applies to: All states that have expanded Medicaid coverage to low-income adults (43 states plus Washington, DC)
- Exclusions: Includes parents with dependents 13 or under or with a disability, pregnant and postpartum individuals, disabled veterans, former foster youth under 26, those that are medically frail, and others
- Impact on Federal Budget: $326 billion savings over 10 years, making up more than one-third of the Medicaid spending cuts in H.R. 1
- Impact on Americans: More than 5 million people losing coverage, according to the Congressional Budget Office
Sources: H.R. 1, Centers for Medicare & Medicaid Services Interim Final Rule, and Congressional Budget Office
Exclusions Are Now Stricter
The IFR provided a stricter and narrower definition of the medical frailty exclusion than defined in H.R. 1. To meet the medical frailty exclusion, individuals now must have a qualifying medical condition and the condition must significantly impair their ability to work. The IFR allows states to accept self-attestation in 2027, and only once at enrollment or first renewal in 2028 for medical frailty.
This stricter rule creates barriers for individuals with serious health conditions who must understand if they meet the criteria, respond to agency notices requesting information, and find appropriate documentation.
Learn from Previous Work Requirement Implementations
While this is the first federal implementation of Medicaid work requirements, they are not entirely new to several states:
- Arkansas implemented work requirements from June 2018-March 2019 under an 1115 waiver. During that time, 18,000 people subject to the requirements (1 in 4) lost coverage, many saw increased medical debt and delayed care, and many were unaware of the requirements.
- Georgia implemented a new coverage program with work requirements in July 2023 called Pathways to Coverage. While almost 200,000 adults are eligible, as of April 2026, just over 16,500 individuals are enrolled.
Under the new federal requirement, some stakes have already taken up the option to implement work requirements ahead of next year, including Nebraska, Montana, and Arkansas.
While we will be closely monitoring implementation in these states, earlier experiences with state work requirements demonstrate the need for clear messages about compliance for individuals to gain and maintain coverage.
Start Preparing Now to Support Medicaid Applicants and Enrollees
With states hurrying to implement the IFR policies by January, a coordinated on-the-ground effort will be critical to help individuals navigate work requirements and prevent coverage losses. Compliance requirements and timelines will vary by state, making localized assistance to provide accurate information even more critical.
These key messengers can help individuals and families keep their coverage:
- Assisters reach the right audiences. In-person enrollment assisters, who often work for community-based organizations, are local trusted messengers for those seeking support for health coverage. Assisters can play a key role in clarifying who is subject to the new requirements and who isn’t (e.g., children, disabled adults), as well as who meets an exclusion, through targeted messaging and hands-on support.
- Providers deliver the supporting documentation. Because the medical frailty exclusion ties having a condition with being too sick to work, state Medicaid agencies will have a difficult time using data to verify this exclusion, and the bureaucratic burden will be put on enrollees to show they meet the criteria. Providers can help patients identify if they are eligible and provide the needed documentation to demonstrate their medical condition and impact on their ability to work.
- Medicaid managed care organizations (MCOs) amplify outreach and support referrals. Medicaid enrollees may be more familiar with their MCO than their state Medicaid agency, making additional outreach from MCOs a valuable resource. Through the IFR, CMS encourages that MCOs may provide outreach and education and can refer enrollees to work programs. Additionally, MCOs are allowed to share updated contact information with states, which can help ensure notices reach the right address, as well as beneficiaries’ health status, which can help states identify individuals who meet the medical frailty exclusion.
To get started in preparing to communicate about upcoming policy changes, read our blog post on building a communication readiness toolkit.
Contact Transform Health if you want to discuss how Medicaid work requirements will affect your organization or populations served. Book a free discovery call today.
Transform Health is an Inc. 5000-ranked national private health care consulting firm with a mission to drive systems change to build healthy communities.