Medicaid work requirements start on January 1, 2026. States not ready will get a six-month grace period from the federal government.
Federal Grace Period Granted to States
States that choose not to enforce the mandate will face no federal accountability until at least July 1, 2026. This window is a hold harmless period under new guidance from the Centers for Medicare & Medicaid Services.
“States have made real progress, and they’ve been clear with us about what it takes to get this right for beneficiaries — at scale and for the long term,” said Dan Brillman, who oversees Medicaid at CMS.
The rules stem from the One Big Beautiful Bill Act. It was signed into law last year.
Able-bodied adults ages 19 to 64 on expanded Medicaid must prove they work, volunteer, or attend school for at least 80 hours a month. Officials in several states warned that they lacked the necessary data and IT infrastructure to verify employment and health exemption statuses by the January deadline. In Colorado, Medicaid director Adela Flores-Brennan said that her department was missing health and employment records for at least 175,000 affected residents.
Federal Judge Strikes Down Medical Frailty Rule
A federal judge in Boston struck down the administration’s medical frailty rule. CMS lacked the authority to require states to assess whether a patient’s condition significantly impairs their ability to work.
The decision restored the original congressional policy. Individuals with qualifying conditions or serious illnesses can claim an exemption without proving work impairment.
Millions of people's health care is at risk because of the Republican reconciliation law’s work requirement, as states scramble to implement on a rushed timeline & respond to shifting federal requirements. Today’s news lets states delay the harm. https://t.co/v1peCq0N9o
The ruling followed a lawsuit filed in June 2026 by a multistate coalition led by the attorneys general of New Jersey, California, and Massachusetts. Attorney General Jennifer Davenport welcomed the decision. It prevents bureaucratic red tape from stripping healthcare access from vulnerable residents.
“This win will help people with complex or serious medical conditions stay on Medicaid and keep their healthcare,” said Attorney General Davenport.
Work Requirements Leave Millions Uninsured by 2034
The work requirements will leave 5.3 million more people uninsured by 2034. The Congressional Budget Office estimated this alongside $317 billion in federal savings as part of nearly $1 trillion in Medicaid cuts.
Sarah Lueck, vice president for health policy at the Center on Budget and Policy Priorities, criticized the rushed implementation timeline. Enrollees face paper-driven renewal processes and notices.
“Millions of people’s health care is at risk because of the Republican reconciliation law’s work requirement, as states scramble to implement on a rushed timeline & respond to shifting federal requirements,” Lueck said in a post on X.
Will states build the IT infrastructure needed before the July deadline arrives?