An Early Look at State Approaches to Implementing Medicaid Work Requirements
Starting January 1, 2027, federal law will require that adults enrolled in the Affordable Care Act (ACA) Medicaid expansion and enrollees in partial expansion waiver programs in Georgia and Wisconsin meet new work requirements. On April 30, 2026 , KFF hosted an hour-long interactive virtual briefing focused on states’ efforts to implement these new Medicaid work and community engagement requirements, which have created new administrative demands on states at a time of federal funding cuts, slowing revenue growth, and increasing spending demands.
The briefing included a presentation of findings from KFF’s 24th annual survey of state Medicaid and CHIP program officials on eligibility, enrollment, and renewal policies, conducted with Georgetown University’s Center for Children and Families, as well as insights from Kate McEvoy of the National Association of Medicaid Directors about how states are approaching implementation of Medicaid work requirements.
Moderator
Panelists
Jennifer Tolbert
Director of State Health Policy and Data, Deputy Director Program on Medicaid & Uninsured
Tricia Brooks
Research Professor, Georgetown University’s Center for Children and Families
Kate McEvoy
Executive Director, National Association of Medicaid Directors
At this KFF virtual briefing, Medicaid experts discussed how states are preparing to implement new federal work and community engagement requirements for Medicaid, drawing on KFF’s 24th annual survey of state Medicaid and CHIP program officials on eligibility, enrollment, and renewal policies. In opening remarks, Larry Levitt noted that these work requirements were part of the biggest rollback in federal Medicaid spending to date, are expected to increase the number of uninsured, and would roll out on tight timelines that vary significantly across states.
Drawing on survey findings, Tricia Brooks explained how income eligibility, immigrant coverage rules, and cost-sharing policies intersected with the new law, highlighting particular concerns for very low-income parents and immigrant families, as well as the role of integrated eligibility systems and online tools in easing administrative burdens. Jennifer Tolbert then detailed how most affected states plan to verify work or exemption status, use hardship exceptions, tap new data sources (including claims and other administrative data), and, in some cases, pilot AI tools, all while grappling with limited time, staffing constraints, and pending federal guidance on key issues such as medical frailty.
Offering a state perspective, Kate McEvoy emphasized the ongoing collaboration with CMS, the use of new federal tools like the “Eligibility Made Easy” system, the importance of partnerships with labor, education, managed care plans, and community organizations, and the lessons from the Medicaid unwinding that states hope will help minimize coverage disruptions as work requirements take effect.
Questions from the audience included:
- How are states handling the tight implementation timeline, staffing, systems changes, and overall operational readiness for work requirements?
- What kinds of data sources (state workforce data, payroll vendors like ADP, federal data hubs, student records, VA status, etc.) will states rely on to verify work, school, and exemption status, and what that will cost to build and maintain?
- How will exemptions work in practice, and how clearly will states communicate who is and is not subject to the new rules?
- What role will managed care plans and community-based organizations play in outreach, navigation support, and preventing eligible people from losing coverage?
- How will policymakers, advocates, and the public will be able to track impacts over time and what will CMS publish in terms of data, reporting conventions, and guidance in the coming months?
AI Usage Disclosure: This event summary was created with assistance from AI tools. It was reviewed and edited by KFF Staff.