Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements: Related Resources
KFF resources on the Medicaid work requirements in the 2025 Reconcilation law.
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KFF resources on the Medicaid work requirements in the 2025 Reconcilation law.
State-by-state information on Medicaid 1115 work requirement waivers.
A list of the implementation questions relating to the Medicaid work requirements in the 2025 Reconciliation law.
Detailed state and national data related to the 2025 Reconciliation Law Medicaid Work Requirements
KFF's interactive tracks key data and policies that will affect how states implement Medicaid work requirements, which are required under the 2025 budget reconciliation law starting in January 2027. The tracker includes state-level data on Medicaid enrollment and renewal outcomes as well as current state enrollment and renewal policies.
On June 1, 2026, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule on Medicaid work requirements that adopts a restrictive definition of medical frailty—differing from states’ early expectations. The more restrictive definition of medical frailty adopted by the Trump Administration will be challenging for states to implement and could lead to more people falling through the cracks and losing coverage.
This policy watch provides initial insight into how North Carolina is preparing to implement certain Medicaid provisions of the 2025 reconciliation law and how other policy changes may affect coverage and access to care.
This brief describes early state plans to operationalize the medical frailty exemption for Medicaid work requirements and identifies key issues and questions states are facing, some of which may be answered in forthcoming CMS guidance.
In the 39 states that are adopting or may adopt the high unemployment hardship exception, about 1.4 million or 7.5% of Medicaid expansion enrollees live in one of the 133 counties that currently meet the high-unemployment criteria.
KFF hosted a 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.
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