Project 2025 Tracker / What’s done, what’s next

14. Department of Health and Human Services · Major

Add work requirements to Medicaid

Done

Printed page 468 14. Department of Health and Human Services

“Add work requirements and match Medicaid benefits to beneficiary needs. … Clarify that states have the ability to adopt work incentives for able-bodied individuals (similar to what is required in other welfare programs) and the ability to broaden the application of targeted premiums and cost sharing to higher-income enrollees.”

What has happened

  1. Done

    CMS published an interim final rule with comment period interpreting and implementing the community engagement requirement — qualifying activities, exceptions, exclusions, verification and State outreach duties (effective 2026-07-31; States must apply the requirement by 2027-01-01). Work requirements are now in both the statute and 42 CFR.

  2. Partially done

    Public Law 119-21 § 71119 requires States to establish Medicaid community engagement (work) requirements for certain individuals, and § 71120 modifies cost sharing for expansion adults — both halves of the ask, enacted but not yet operating: States must implement the requirement no later than 2027-01-01.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • A technical correction to the interim final rule was published on 2026-06-29 (FR document C1-2026-11094); it does not change the substance and is not cited separately.
  • State-level § 1115 work-requirement waivers approved before the statute would sit under CMS and Medicaid.gov approval letters; cms.gov and medicaid.gov both refused to open for us, so no waiver letter could be read and none is cited.
Action
restrict
Object
Medicaid work requirements
ID
1281