CMS issues guidance on Medicaid work requirements

The Centers for Medicare & Medicaid Services (CMS) issued new guidance on December 8, 2025, detailing the implementation of federal Medicaid work requirements set forth in Public Law 119-21. This informational bulletin clarifies eligibility, exemptions, verification protocols, and compliance timelines related to community engagement mandates.

The requirements apply to adults aged approximately 19 to 64 enrolled in Medicaid expansion or similar Section 1115 waiver programs. Exclusions include individuals who are pregnant, receiving Medicare, or otherwise ineligible. To satisfy the work mandate, beneficiaries must complete at least 80 hours per month of approved activities. Qualifying engagements include paid employment, community service, vocational training, and enrollment in educational programs. Certain seasonal or intermittent work may also meet the threshold.

CMS acknowledges exemptions for medically frail individuals, caregivers, persons with disabilities—including those with serious mental illness—as well as pregnant and postpartum beneficiaries. States may also grant short-term hardship exceptions. Verification relies first on available administrative data such as payroll information, enrollment records, or training attendance before requesting beneficiary documentation. If a state cannot verify compliance through data matching, it must notify the individual and allow 30 days for proof submission.

CMS will release an interim final rule by June 1, 2026, to formalize enforcement standards. States are required to begin applying the work requirements no later than January 1, 2027, although earlier implementation is possible with CMS approval. States face significant challenges in designing systems and policies within tight timeframes. Early feedback highlights ongoing uncertainties around verification mechanisms and operational logistics, signaling the need for further clarification ahead of compliance enforcement.