CMS issued a bulletin Dec. 8 outlining guidance on Medicaid’s forthcoming work requirements.
Some states are already embracing work requirements, while others are looking for exceptions.
Here are eight things to know:
1. Work requirements will kick in Jan. 1, 2027, unless a state opts to implement them sooner.
2. Most individuals enrolled in a state plan’s adult group must comply. This also includes those who can enroll under a waiver that provides minimum essential coverage, who fall within the adult group age range, are not pregnant and are not on Medicare.
3. Enrollees must work, participate in community service or attend school — or carry out a combination of these — for a minimum of 80 hours per month. Enrollees could also be a half-time student, have an income of at least $580 per month or earn an average monthly income over the past six months that matches the federal minimum wage.
4. Former foster care youth, Native Americans, caregivers of dependent children or disabled individuals, veterans with a total disability rating, those with special medical needs, those meeting Temporary Assistance for Needy Families requirements or receiving Supplemental Nutrition Assistance Program benefits, those in drug or alcohol rehabilitation, inmates, and pregnant people or those eligible for postpartum medical help are exempt.
5. Noncompliance can result in losing Medicaid eligibility. In this event, individuals would not receive ACA premium tax credits.
6. States should begin outreach by July, August or September 2026, depending on how many months of community engagement individuals need at the time of their Medicaid application.
7. States facing compliance barriers may qualify for good-faith-effort exemptions, but they will expire no later than Dec. 31, 2028.
8. The federal government has $200 million to allocate to states for implementation.
