CMS Releases Interim Final Rule on Medicaid Work Requirements
Article Publication Date
Summary
On June 1, the Centers for Medicare & Medicaid Services (CMS) released an Interim Final Rule with Comment (IFC) requiring that certain adult Medicaid applicants and enrollees must, as a condition of Medicaid eligibility, meet an 80 hours per month work requirement, through employment, education, work programs, or community service.
The IFC establishes the standards states must use to implement the statutory work requirement, including clear expectations for eligibility determinations, exemptions, verification, and state reporting requirements. The IFC also defines which adults ages 19 through 64 will be required to demonstrate work requirement activities, as well as which individuals are not subject to the requirement because of health-related needs and other qualifying circumstances. These exemptions include, but are not limited to:
• Individuals who are pregnant, postpartum, disabled, medically frail, American Indian or Alaska Native
• Parents or caregivers of young children and people with disabilities
• Those who are already complying with similar requirements through the Supplemental Nutrition Assistance Program (SNAP) or the Temporary Assistance for Needy Families (TANF) program
The IFC also includes state data reporting requirements and establishes requirements for how states must assess and verify compliance and communicate the new requirement to Medicaid applicants and beneficiaries. The work requirement must be implemented no later than January 1, 2027, in applicable states.
The IFC is open for public comment until July 31, 2026.
The IFC establishes the standards states must use to implement the statutory work requirement, including clear expectations for eligibility determinations, exemptions, verification, and state reporting requirements. The IFC also defines which adults ages 19 through 64 will be required to demonstrate work requirement activities, as well as which individuals are not subject to the requirement because of health-related needs and other qualifying circumstances. These exemptions include, but are not limited to:
• Individuals who are pregnant, postpartum, disabled, medically frail, American Indian or Alaska Native
• Parents or caregivers of young children and people with disabilities
• Those who are already complying with similar requirements through the Supplemental Nutrition Assistance Program (SNAP) or the Temporary Assistance for Needy Families (TANF) program
The IFC also includes state data reporting requirements and establishes requirements for how states must assess and verify compliance and communicate the new requirement to Medicaid applicants and beneficiaries. The work requirement must be implemented no later than January 1, 2027, in applicable states.
The IFC is open for public comment until July 31, 2026.