Toolkit: Medicaid Work and Community Engagement Requirements
Action:
Medicaid work requirements are a rapidly evolving policy issue at both the federal and state levels. In this changing landscape, ACP encourages chapters and members encountering proposals to implement or expand Medicaid work requirements in their states to contact our team using the Advocacy Assistance Request Form for support. ACP can provide guidance on key talking points, assist with engaging the media through statements and op-eds, and help strategize effective responses tailored to your state’s policy environment.
ACP members should be familiar with ACP’s policy positions on Medicaid, health coverage, and access to care, which can be found on ACP’s Advocacy and Policy hub and shared with policymakers. ACP supports policies that maintain and strengthen access to affordable health coverage and reduce administrative barriers that may result in eligible individuals losing coverage.
Members interested in advocating around Medicaid work requirements can consider taking one or more of the following actions:
- Engage state policymakers by sharing clinical perspectives on how coverage disruptions affect patients’ health outcomes and continuity of care.
- Review pending federal and state policies related to Medicaid work requirements and monitor developments in your state.
ACP continues to track legislative and regulatory developments related to Medicaid work requirements and will provide updates and resources to support member advocacy.
Introduction
Beginning January 1, 2027, state Medicaid programs will be required to verify beneficiary compliance with work and community engagement requirements as a new condition of eligibility for Medicaid coverage. Although proponents argue that such policies promote employment and self-sufficiency, empirical research examining prior Medicaid work requirement demonstrations has found little evidence that they meaningfully increase employment among enrollees. Instead, available evidence suggests that coverage losses are the more immediate and measurable effect. Current estimates project that at least 4.8 million individuals could become uninsured by 2034 as a result of these policy changes.
Background
On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) became law and national Medicaid policy underwent major changes. First, most adults between 19–64 years old who reside in a Medicaid expansion state (see map) and are not pregnant, disabled, or otherwise exempted under a qualifying condition (see below) will have to demonstrate compliance with work and community engagement requirements to be eligible for Medicaid coverage. Individuals must demonstrate that they are engaged in at least 80 hours/month of qualifying engagement activities such as:
- Regular employment
- Participation in a work program
- Community service
- At least half-time enrollment in an educational program
- Any combination of these activities
Some individuals may be exempted from meeting these new requirements, if they belong to certain categories such as:
- Certain youth formerly in foster-care
- American Indian and Alaska Native beneficiaries
- Certain caregivers of a dependent child (age 13 or younger) or of a person who is disabled
- Veterans with disabilities
- Individuals who are medically frail, including those with a serious or complex medical condition
- Individuals already meeting work requirements
- Individuals participating in a qualifying substance use disorder (SUD) treatment program
- Incarcerated or recently incarcerated individuals
- Individuals who are pregnant or postpartum
- Individuals experiencing short-term hardship
States will primarily use existing datasets to verify eligibility as well as to verify qualifying exemptions. These may include payroll records, medical claims records, or some other form of existing dataset available to state Medicaid agencies, and if this primary verification comes up inconclusive, states may request official documentation from individuals demonstrating their compliance with the new program requirements.
The official deadline for implementing these changes is January 1, 2027, but some states may choose to start sooner (e.g., Nebraska by May 1, 2026). Some states may also choose to extend the implementation deadline to December 31, 2028, if they are able to demonstrate a good faith effort to make changes to comply with the new requirements.
Federal Activity
In preparation for the implementation deadline, federal agencies are taking steps to ensure a successful implementation of new policy changes.
- The Centers for Medicare & Medicaid Services (CMS) releases initial guidance on how states should implement work and community engagement requirements for Medicaid.
- CMS is required to release additional guidance by June 2026 providing more detailed information about the application of new Medicaid requirements.
- CMS announces that several health technology companies that have existing Medicaid contracts pledge $600M to help states successfully implement new work and community engagement requirements.
- CMS announces plans to distribute $200M in federal funding to help states setup systems necessary to comply with the new requirements.
State Activity
States are also preparing to ensure successful deployments of new changes to Medicaid.
- Many states are actively preparing to implement the new Medicaid requirements by the January 2027 deadline, however, many states are reporting difficulties with implementing changes including upgrading eligibility and IT systems to track and verify compliance, hiring and training additional staff, coordinating data systems across different agencies, and ensuring compliance with applicable legal guardrails such as anti-discrimination protections contained in the Americans with Disabilities Act (ADA).
ACP Resources
References
Research Report – Effects of Work Requirements on Employment, Income, and the Federal Budget | CBO
Regulatory Guidance – Overview of Medicaid Work and Community Engagement Requirements | CMS
Issue Brief – Challenges With Implementing Work Requirements | KFF