The Centers for Medicare & Medicaid Services (CMS) recently released an Interim Final Rule (IFR) that provides details about how states must implement new Medicaid work requirements beginning January 1, 2027.
The work requirements were established through H.R. 1, passed by Congress in 2025, and apply to adults ages 19–64 who receive coverage through their state's Medicaid expansion program or a similar coverage group.
The new rule explains how states must determine who is subject to the requirements and how they will identify individuals who qualify for an exception. It also outlines what activities count toward meeting the work requirement, referred to as "community engagement activities."
Some individuals may qualify for an exception from the work requirements. These include people who are considered medically frail and certain family caregivers. The rule also describes how states must verify whether a person meets the requirements or qualifies for an exception. Verification may occur through state data systems, documentation provided by the individual, or, in some circumstances, self-attestation.
In addition to the required exceptions outlined in federal guidance, states have the option to provide exceptions for certain short-term hardship events. According to the Georgetown University Center for Children and Families' Tracking Implementation of H.R. 1 Medicaid Work Reporting Requirements, Indiana Family and Social Services Administration (FSSA) leadership has chosen not to offer hardship exceptions related to:
- Receiving care in a hospital or nursing facility
- Living in an area where an emergency or disaster has been declared
- Living in an area with a high unemployment rate
- Needing to travel for medical treatment
CMS is accepting public comments on the Interim Final Rule from June 3 through July 31, 2026. The comment period provides an opportunity for families, advocates, providers, and other stakeholders to share feedback about the rule before implementation.
Additional information is available through Justice in Aging's H.R. 1 summary and Medicaid Work Requirements Toolkit, as well as Georgetown University's Tracking Implementation of H.R. 1 Medicaid Work Reporting Requirements resource.
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