CMS Issues Initial Guidance on Work Reporting Requirements
A summary of the initial CMS guidance (CMCS informational bulletin) on how states should implement Medicaid work reporting requirements under H.R. 1, clarifying high-level expectations and key technical points.
This resource reviews preliminary guidance issued by CMS on December 8, 2025, interpreting the Medicaid work reporting requirements added by H.R. 1, including which populations must comply, what kinds of activities count toward work or community engagement, and how compliance must be verified.
It highlights key clarifications — such as which waiver populations are subject to the rules, how lookback periods apply at application and renewal, and state flexibility around compliance and exemptions — as well as numerous operational questions CMS has left unresolved. Because the guidance remains high-level, states continue to face significant uncertainty about the detailed policies and systems changes needed before the requirements take effect.
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