CMS Interim Final Rule with Comment on Medicaid Work Requirements

The U.S. Centers for Medicare & Medicaid Services (CMS) recently announced an Interim final rule with comment period (IFC) that interprets and implements the community engagement requirement in Medicaid.  The IFC “specifies the requirements and expectations for States, including Medicaid applicants and beneficiaries who must demonstrate community engagement as a condition of their eligibility, the types of qualifying activities that satisfy the community engagement requirement, the criteria to meet an exception from the requirement (that is, be deemed compliant), and the criteria to meet a specified exclusion for the requirement.”  Adults aged 19-64 must meet an 80 hours per month work requirement through employment, education, work programs, or community service.  Exemptions include “individuals who are pregnant, postpartum, disabled, medically frail, American Indian or Alaska Native, parents or caregivers of young children and people with disabilities….”  The IFC will be effective on, and comments will be received through, 7/31/2026.  For more information, see the “Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period” (CMS-2454-IFC) and 91 Fed. Reg. 33348, (June 3, 2026).