The Center for Medicaid Defines Work Requirements and Exemptions for January 1, 2027

In accordance with the new laws, the Center for Medicare and Medicaid Services (CMS) issued an interim final rule requiring adults to meet a minimum of 80 hours per month to maintain their Medicaid benefits. States must verify compliance at application and at renewal, and may also verify more frequently if they choose. Verification will require documentation, and that does not include self-attestation after the end of 2027. Exemptions to the work requirement include "medically frail" individuals and caregivers of individuals with "disabilities" both of which are defined as an inability to work the required hours—and require proof of that inability. Advocates including the American Cancer Society and the National Alliance for Caregiving are voicing concerns about the tight standards for documentation, given the variability in cancer trajectory experiences and the challenge of producing proof of caregiving responsibilities.

Public comments may be submitted by July 31, 2026.

Learn more about the interim final rule, exemptions, and documentation.