The Centers for Medicare and Medicaid Services (CMS) issued an Interim Final Rule (IFR) detailing how states must implement new Medicaid work requirements, which take effect January 1, 2027. These work requirements were passed by Congress under H.R. 1 last July and apply to adults aged 19 to 64 who are enrolled in their state Medicaid expansion (or similar) program.  

The IFR clarifies the process for determining who is subject to work requirements and outlines the criteria states must use when assessing whether an individual falls under these provisions.

The rule explains which activities qualify as “community engagement activities” for purposes of meeting work‑requirement standards. It also defines exceptions from meeting these standards in certain circumstances, including individuals deemed “medically frail” and family caregivers.

Finally, the IFR details how states must verify work requirements compliance and exceptions, including utilizing the state’s own data systems to verify ex parte, requiring individuals to provide documentation, and specifying the circumstances under which individuals can attest their compliance.

CMS is accepting comments on the IFR from advocates and stakeholders at www.regulations.gov/docket/CMS-2026-2047/document until July 31.

Despite the extensive IFR, Justice in Aging remains concerned that millions of people, including older adults, people with disabilities and caregivers, will lose coverage due to the administrative complexities of Medicaid work requirements.

We will be reviewing the IFR and providing additional analysis and resources to help advocates understand the rule and advocate for their state to mitigate the harm as much as possible.

For more information, see Justice in Aging’s H.R. 1 summary and Medicaid work requirements toolkit at www.bit.ly/4ovLS1z. Additional resources on defending Medicaid are available at www.bit.ly/4xdQNbd. 

Justice in Aging is a national organization that uses the power of law to fight senior poverty by securing access to affordable health care, economic security and the courts for older adults with limited resources. Learn more at www.justiceinaging.org.

Justice in Aging
Oakland, CA