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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.
State-by-state information on Medicaid 1115 work requirement waivers.
KFF resources on the Medicaid work requirements in the 2025 Reconcilation law.
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
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.
The 24th annual survey of state Medicaid and CHIP program officials conducted by KFF and the Georgetown University Center for Children and Families (CCF) provides a baseline of state Medicaid and CHIP eligibility, enrollment, and renewal policies in place as of January 2026 as they prepare to implement the changes included in the 2025 reconciliation law.
A new KFF survey of state Medicaid officials and focus groups in eight states captures the different choices states are making about how to implement Medicaid work requirements, with seven states planning for a more restrictive approach to verifying work or exemption status or to implement work requirements early. These implementation plans are taking shape as states encounter time, cost, and other constraints as well as uncertainty about how to define and verify certain exemptions…
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