The Centers for Medicare & Medicaid Services (CMS) said Nov. 13 that states can give Medicaid applicants and recipients up to six months of additional time before denying or ending coverage over a new federal work requirement.
States that take the option will still begin checking whether people meet the requirement or qualify for an exemption. Through June 30, 2027, participating states can approve applications and keep people enrolled if they otherwise qualify for Medicaid.
States can also choose a shorter transition period.
CMS asked states that decide they want to use the option beginning Jan. 1, 2027 to notify the agency by Dec. 11.
“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,” Deputy Administrator and Director of the Center for Medicaid and CHIP Services Dan Brillman said in a statement. “If the state can use data to show that someone is working or qualifies for an exclusion, that person should not have to track down paperwork to prove it.”
Sen. Ron Wyden (D-Ore.) and Rep. Frank Pallone Jr. (D-N.J.) called the Trump administration’s decision to let states defer Medicaid disenrollments over new work requirements for up to six months a “small step in the right direction.”
In a Nov. 13 statement, they urged every state to use the option and warned that the reporting requirements could still jeopardize coverage for millions of Americans. Earlier in the week, the two Democrats had called for a full implementation delay regarding the requirements.
States must request federal approval as part of a plan that addresses problems they expect to encounter in implementing the requirement.
The federal requirement applies to certain adults ages 19 to 64, primarily those eligible for Medicaid through the program’s expansion to low-income adults.
CMS outlined the eligibility rules in an interim final rule issued in June.
President Donald Trump signed the federal Medicaid work requirement into law on July 4, 2025, as part of the One Big Beautiful Bill Act.
Adults subject to the rule can qualify by completing 80 hours a month of work, volunteering, or other qualifying activities, enrolling in school at least half time, or meeting a monthly income threshold. Others qualify for exemptions.
A federal judge in Massachusetts struck down part of the Trump administration’s Medicaid work requirement rule on Oct. 29, ruling that federal officials had unlawfully narrowed an exemption for people who are medically frail or have special medical needs.
Massachusetts Attorney General Andrea Joy Campbell, California Attorney General Rob Bonta, and New Jersey AG Jennifer Davenport co-led the multistate lawsuit, which was filed in June. Washington Attorney General Nick Brown and Michigan Attorney General Dana Nessel were among the other attorneys general who joined the challenge.
The states said the rule would make it harder for people with serious health conditions to keep their Medicaid coverage.
U.S. District Judge Richard Stearns vacated language that required people seeking the exemption to show that their condition significantly impaired their ability to meet the work requirement. He also barred federal officials from penalizing the plaintiff states for errors or delays in medical frailty determinations for six months.
The broader work requirement remains in place.
Nebraska became the first state to implement the new federal Medicaid work requirements on May 1, 2026, eight months ahead of the federal deadline. The requirements applied immediately to new Medicaid expansion applicants.
Nebraska phased in checks for people already enrolled, starting with those whose eligibility periods ended July 31. Existing recipients must show they met the requirement for at least one month since they first qualified or last renewed their coverage.
“These requirements will help Nebraskans achieve greater self-sufficiency through employment and other meaningful activities,” Nebraska Gov. Jim Pillen said in a 2025 statement. “Working not only provides purpose but helps people become active, productive members of their communities.”
