The Medical Frailty Exemption from Medicaid Work Requirements: Key Takeaways from the CMS Interim Final Rule
This brief describes new guidance and potential challenges states will face in operationalizing the medical frailty exemption.
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This brief describes new guidance and potential challenges states will face in operationalizing the medical frailty exemption.
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.
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.
Detailed state and national data related to the 2025 Reconciliation Law Medicaid Work Requirements
A majority of states subject to new Medicaid work requirements — 30 of 44 — will hold gubernatorial elections this November, and leadership transitions, particularly those involving a change in party, could complicate state implementation of work requirements.
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.
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