Work requirements for Medicaid eligibility are set for 2027, but states can request short-term exceptions for counties with high unemployment. By assessing county-level data in Medicaid expansion states, KFF found only 7% of counties meet the exception criteria using a 12-month average unemployment rate.
The law permits states to request exemptions for counties with unemployment rates at least at 8% or below 8% but 1.5 times at or above the national average rate.
About 1.4 million expansion enrollees would meet that criteria, but the number of eligible counties could go up if CMS allows states to also account for three- or six-month average unemployment rates.
While urban counties are less likely to qualify, 80% of enrollees with exemptions would be based in urban areas because of the larger population.
Most expansion enrollees span five states: California, New York, Michigan, Kentucky and Ohio. California enrollees make up over half the number of individuals living in qualifying counties.
