Implementing Medicaid Work Requirements: A Guide for States
This guide explains how states can implement new Medicaid work requirements introduced by H.R. 1, focusing on minimizing harm to eligible clients while preparing for compliance by 2027.
The document outlines how the new federal rules apply to expansion adults (ages 19–64, not pregnant, disabled, or otherwise eligible), and describes the “look-back” requirement that checks work activity or exemptions in the months prior to enrollment or renewal.
It introduces a four-step compliance flow—checking for automatic hardship, screening for exemptions, verifying participation in work or related activities, and allowing for hardship requests—and provides state options for defining these steps. The guide stresses early planning, careful screening, and clear communication with clients to reduce risk of wrongful denials, while acknowledging areas where federal guidance remains uncertain.
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