Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Work Requirements Waivers

The 2025 budget reconciliation legislation requires states to condition Medicaid eligibility for adults in the ACA Medicaid expansion group on meeting work requirements starting January 1, 2027, but states have the option to implement requirements sooner using an 1115 waiver or through a state plan amendment.

Prior to the passage of the federal reconciliation legislation and since the start of the second Trump administration, some states have shown renewed interest in pursuing work requirement policies through 1115 waivers. Some states may no longer be moving forward with proposed 1115 waivers due to the passage of federal work requirements; Montana is the only state that has submitted a waiver since the passage of the 2025 budget reconciliation legislation. While states are required to fully align with federal work requirements starting January 1, 2027, it is not clear how CMS will treat pending 1115 waivers that seek to implement early and deviate from federal requirements (specified in the law) prior to this deadline.

The first Trump administration encouraged and approved 1115 demonstration waivers that conditioned Medicaid coverage on meeting work requirements which were subsequently rescinded by the Biden administration or withdrawn by states. Currently, Georgia is the only state with a Medicaid work requirement waiver in place following litigation over the Biden administration’s attempt to stop it. CMS recently approved a temporary extension for Georgia’s waiver that added new exemptions from work requirements (see the table below for more details). Georgia’s waiver is now set to expire December 31, 2026, and the state will be required to come fully into compliance with new federal requirements starting January 1, 2027.

The map below identifies approved (Georgia) and pending work requirement waivers (submitted to CMS since the start of the second Trump administration). The table below the map provides more detailed state waiver information.

For more information on Section 1115 Waivers visit our Medicaid Waiver Tracker.