On June 3, 2026, the Centers for Medicare & Medicaid Services (CMS) published an interim final rule with comment period entitled “Medicaid Program: Community Engagement Requirement for Certain Individuals” (the “Interim Final Rule” or “IFC”), 91 FR 33348, setting forth engagement or work obligations for both individual adults and states with respect to Medicaid.
What You Need to Know
- Work Requirements: The Interim Final Rule requires that certain adult Medicaid applicants and enrollees (aged 19 through 64), as a condition of Medicaid eligibility, meet an 80-hour-per-month work requirement through employment, education, work programs, or community service.
- Exemptions: The IFC’s exemptions include individuals who are pregnant, postpartum, disabled, medically frail, American Indian or Alaska Native, parents or caregivers of young children or people with disabilities, or already complying with similar requirements through the Supplemental Nutrition Assistance Program (SNAP) or the Temporary Assistance for Needy Families (TANF) program.
- Medically Frail: CMS interprets the “medically frail” exemption more narrowly than under existing Alternative Benefit Plan (ABP) and section 1115 regulations, requiring that qualifying conditions “significantly impair” the individual’s ability to comply with the work requirement.
- Enrollment Impact: CMS’s projections estimate that the IFC will reduce Medicaid enrollment by 2.3 million people in fiscal year (FY) 2027, rising to over 3...
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