Medicaid work reporting rules start in 2027

On January 16, 2026, The Arc published guidance on a new federal Medicaid policy that will add community engagement, also described as work reporting, requirements. States must implement these requirements beginning January 1, 2027, unless a state chooses to start earlier. The guidance outlines who may have to report work or community activities, who is exempt, and what people and caregivers can do now to help protect Medicaid coverage under the new policy.

What the new requirement does

Federal law now conditions Medicaid eligibility for many adults on reporting work or other qualifying community engagement activities. The guidance lists examples of qualifying activities, including employment, volunteering, schooling, or training. This shift centers on reporting and documentation, and it will shape how eligibility is maintained for people who fall under the requirement.

Timeline and who may be subject to reporting

The implementation date set in federal policy is January 1, 2027. While that is the deadline for states to begin, the guidance notes that some states may choose to start sooner. The Arc’s guidance explains that the applicable individuals are generally adults ages 19–64 in the Medicaid expansion population. It also highlights that certain groups are typically not subject to the new reporting requirement. This includes people receiving Supplemental Security Income (SSI) and many people with disabilities, such as those on Medicaid through disability categories or those receiving long-term services and supports.

How reporting may work and what to prepare for

Early federal guidance released to states indicates that individuals may need to demonstrate compliance when applying for Medicaid and at renewal. The guidance also points to flexible “look-back” periods and potential exemptions as part of how compliance could be assessed.

Advocates and providers warn that the new rules will require massive administrative changes. They also raise concerns about the risk of coverage loss for people who do not understand the reporting requirements or cannot meet them. The Arc’s guidance underscores that outreach and support will be critical in the next year as the policy moves toward implementation.

Key preparation steps highlighted in the guidance include getting clear now on who will be affected in each state, preparing for reporting systems and outreach, and understanding exemptions. The guidance also notes that information can be summarized for specific audiences, including people with disabilities, caregivers, or state providers.