If certain adult Medicaid applicants and enrollees want to be eligible for federal benefits next year, they must meet an 80-hour-per-month work requirement.
The Centers for Medicare & Medicaid Services released its nationwide framework this week, requiring that adults ages 19 through 64 — with some exceptions — demonstrate work through employment, education, work programs or community service.
States have new requirements too, focused on expanding the use of automation, data integration and real-time verification to assess and verify compliance. Compliance activities are reported to state Medicaid agencies biannually.
If a state cannot verify that people have met the requirement, it must send a notice of noncompliance and give them 30 days to demonstrate the requirement does not apply to them.
CMS estimates 2.3 million people will lose Medicaid enrollment in 2027, rising to between 3.1 million and 3.3 million annually in subsequent years. Independent estimates are considerably higher; the Urban Institute projects between 4.9 million and 10.1 million enrollees could lose coverage in 2028 alone.
As the rule is rolled out across the country, states are projected to spend tens of millions of dollars on work verification programs.
Federal grants totaling $200 million can be used to support state system modernization and administrative capacity. An additional $600 million in discounted and free services has been pledged by private-sector technology vendors to help states update eligibility and enrollment systems.
Nebraska became the first state to impose the work prerequisites at the beginning of May, completing the requirement eight months before the deadline set in the One Big Beautiful Bill Act.
Under President Trump’s signature bill, states are not required to mandate the work requirements until Jan. 1.
Forty-three states are subject to this, including the 41 states and D.C. that have adopted the Medicaid expansion and Georgia and Wisconsin that have implemented partial expansion waivers.
Montana and Iowa are moving forward with early implementation ahead of the national deadline. Montana will begin enforcing the rules on July 1, while Iowa plans to implement its requirements on Dec. 1.
Arkansas is also planning what it calls a soft launch implementation in July, but will maintain anyone not meeting the requirements until the 2027 deadline.
“The Working Families Tax Cut legislation made historic changes to the Medicaid program, and CMS is working closely with states to put those changes into action,” CMS Administrator Mehmet Oz said in a statement, referencing the rebranded One Big Beautiful Bill Act. “This rule helps Americans build skills and independence through work, education, job training, or community service, creating new opportunities for themselves and their families.”
Arkansas’ Medicaid policy and healthcare rollout caused significant coverage losses. The 2018 work requirements led to 18,000 eligible residents losing health coverage before a federal judge shut the program down in 2019.
A Harvard study found that over 95% of low-income people in Arkansas subject to the policy were already meeting the work requirements or should have been able to gain an exemption, but one-third had not heard of the requirements. Only half were reporting the required information online to keep their coverage, primarily due to confusion about the process or lack of internet access.
