Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements

The 2025 reconciliation law, once called the “One Big Beautiful Bill,” signed by President Trump on July 4, 2025, conditions Medicaid eligibility for adults in the Affordable Care Act (ACA) Medicaid expansion group and enrollees in partial expansion waiver programs (Georgia and Wisconsin) on meeting work requirements starting January 1, 2027. Currently, 41 states (including DC) have expanded their Medicaid programs under the ACA to nearly all adults with income up to 138% FPL ($21,597 for an individual in 2025).

To implement Medicaid work requirements, states will need to make important policy and operational decisions, implement needed system upgrades or changes, develop new outreach and education strategies, and hire and train staff, all within a relatively short timeframe. The information tracked here can serve as a resource to understand Medicaid work requirements and state options, gauge readiness, and track implementation of the requirements, including:

• State and national data and current state policies related to Medicaid enrollment, renewal outcomes, and application processing times that can serve as a baseline for assessing the potential readiness to implement the requirements and the impact of work requirements once implemented;
• Federal guidance and a list of policy and operational questions that states will need to answer as they implement work requirements;
• Updates on 1115 waivers submitted by states to implement work requirements (while waivers will no longer be needed starting January 2027, some states may pursue waivers to implement work requirements earlier than January 2027); and
• A compilation of KFF issue briefs and other resources on Medicaid work requirements.

This resource will be updated to include guidance from the Centers for Medicare and Medicaid Services (CMS), information on state policy decisions as they are made, and new data when available.