Work Requirements on Medicaid
Community engagement (aka work) requirements are coming for Medicaid enrollees in 2026. States have a January 1, 2027 deadline to meet this requirement from the federal budget reconciliation package (HR 1). In the meantime, some states are opting to meet these requirements early. Kaiser Family Foundation offers a map showing the pathways states are using to implement these work requirements ahead of the federal deadline.
[Bookmark the KFF tracker for year-long access: Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements]
It’s important to note that most of the people who will be subjected to work requirements are already working, and may not have options for coverage through their employers. These workers rely on the affordability of Medicaid, when employer-sponsored coverage is less affordable. Often, part-time workers are the primary cohort who are unable to attain employer-sponsored coverage. Many of these individuals are people with disabilities who rely on Medicaid to meet daily living needs that support their ability to work as well. Work requirements are an added administrative burden.
Technically, people receiving Home- and Community-Based Services are exempt from work requirements. Given the cuts to the Medicaid program overall, these services are also most likely to be cut first at a state level, meaning this specific work reporting exemption may be precarious among this particular cohort of Medicaid enrollees. SSI recipients, some veterans, formerly incarcerated people who are newly reintegrating to their communities, people with substance use and mental health-related disabilities, and complex medical conditions are also exempt from work requirements. The American Association of People with Disabilities offers an explainer on how work requirement exemptions should be pursued for people with a variety of disabilities.
States may use existing data sources on Medicaid enrollees to determine their compliance with work requirements. One of these data sources includes federal SNAP benefits eligibility data. While SNAP is also facing some new work requirements of its own, but data sharing here is helping some states make verification smoother for enrollees. About 1 in 5 of the people navigating work requirements will also be SNAP beneficiaries, so understanding the nuances of reporting work for both will be helpful with supporting people to stay enrolled.
Work requirements are part of a broader effort to curb “waste, fraud, and abuse” under this current administration. However, as the Center on Budget and Policy Priorities (CBPP) points out: “in Medicaid, like in private health insurance, fraud that does exist is overwhelmingly committed by providers, not program enrollees.” We think that ridding Medicaid of fraud and abuse is warranted, but we also believe that using fraud allegations to undermine essential healthcare access and community living for vulnerable populations is the wrong way to address these issues.
With many changes to Medicaid rolling out over the coming year, Princeton University’s State Health and Value Strategies program has resources to support engagement with enrollees. Watch the recording from their recent webinar on “Preparing Consumers for Changes to Medicaid”. Check out their Communications Workplan for further messaging guidance on how to communicate these changes with enrollees.
Last Call: Comments to CMS
Today is the final day to submit public comments to CMS on proposed rule changes that would affect the ACA Marketplace. The 2027 Notice of Benefit and Payment Parameters is over 500 pages long, so a number of advocates have prepared summary documents on the impacts that this would have on the operations of the Affordable Care Act. Families USA has prepared a guide featuring additional resources about how these rule changes would impact care. Healthcare policy writer Andrew Sprung explains that these plans would bring back non-network plans, which force enrollees to negotiate payment rates with their providers. These plans had been banned under the previous administration in 2024. Journalist Charles Gaba reflects on the proposed changes in a 3-part blog series (Read parts 1, 2, and 3). Submit your comments today.
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