The Centers for Medicare & Medicaid Services (CMS) has released an Interim Final Rule with Comment (IFC) requiring certain adult Medicaid applicants and enrollees to meet an 80-hour-per-month work requirement as a condition of Medicaid eligibility. Qualifying activities include employment, education, work programs, or community service. The rule establishes a nationwide operational framework designed to promote economic stability, self-sufficiency, and independence.
The Working Families Tax Cut legislation made historic changes to the Medicaid program, and CMS is working closely with states to put those changes into action,” said CMS Administrator Dr. Mehmet Oz. “This rule helps Americans build skills and independence through work, education, job training, or community service, creating new opportunities for themselves and their families.
Issued under Public Law 119-21 – referred to by CMS as the Working Families Tax Cut (WFTC) legislation – the rule sets the standards states must follow to implement the statutory work requirement, covering eligibility determinations, exemptions, verification procedures, and state reporting obligations. It reflects extensive coordination with states and builds on CMS’s ongoing efforts to modernize eligibility systems, improve beneficiary interactions, and strengthen program accountability.
The rule applies to adults ages 19 to 64 who must demonstrate participation in qualifying work-requirement activities. Certain individuals are exempt based on health-related needs or qualifying circumstances, including but not limited to individuals who are pregnant or postpartum, disabled, medically frail, American Indian or Alaska Native, parents or caregivers of young children or people with disabilities, and those already complying with comparable requirements under the Supplemental Nutrition Assistance Program (SNAP) or the Temporary Assistance for Needy Families (TANF) program.
CMS is supporting implementation through a combination of federal resources, technical assistance, and private-sector collaboration. This includes $200 million in Government Efficiency Grants authorized under the WFTC legislation for state system modernization, along with more than $600 million in committed support from private-sector technology vendors to help states update eligibility and enrollment systems and conduct outreach to Medicaid beneficiaries.
These investments build on CMS’s broader modernization efforts, including expanding automation, data integration, and real-time verification capabilities to improve efficiency and strengthen oversight.
Applicable states must implement the work requirement no later than January 1, 2027. Some states, including Nebraska, have already moved forward with early implementation. This rule is being issued with a comment period to remain consistent with the legislative directive and implementation timeline established under the WFTC legislation, allowing CMS to continue collecting public feedback while ensuring a timely rollout.
Organizations serving populations that include adults in the 19–64 age range – particularly safety-net providers, FQHCs, and community health centers – should monitor state-level implementation timelines and assess operational readiness ahead of the January 2027 deadline.
