On June 1, 2026, the Centers for Medicare & Medicaid Services (CMS) released an Interim Final Rule with Comment Period (IFC) governing how states implement Medicaid work requirements — also known as community engagement requirements — enacted into law as part of the One Big Beautiful Bill Act (OBBBA). The nearly-400 page document establishes standards for how states verify compliance with work requirements, determine exemptions, and adhere to federal reporting requirements. Individuals can submit comments on the rule electronically or by mail to the Federal Register until July 31.
The OBBBA, the 2025 budget reconciliation bill, established mandatory work requirements for most able-bodied adults ages 19-64 beginning Dec. 31, 2026, in states that expanded Medicaid under the Affordable Care Act (otherwise known as Obamacare). To date, 40 states and Washington D.C. have expanded Medicaid to cover childless adults under 65 earning incomes up to 138 percent of the federal poverty level. Georgia and Wisconsin have partially expanded the program. A June 2025 Congressional Budget Office (CBO) analysis estimated that, once implemented in all 42 states and D.C., work requirements would apply to roughly 18.5 million Americans.
Under the OBBBA, Medicaid beneficiaries subject to work requirements must provide evidence that they are either employed, participating in community service or an approved work program, or enrolled at least part time in an educational program for at least 80 hours a month. Individuals subject to work requirements must submit documentation demonstrating their compliance with the law at the time of enrollment and every six months thereafter. Adults subject to work requirements are eligible for an exemption if they meet certain criteria. For example, some former foster care youth are exempt, as are some American Indians, Alaska Natives, and the parents or caretakers of children under 13.
