In its annual survey of Medicaid officials, KFF asked about policy decisions related to implementing this new requirement, which applies to the 41 states that expanded Medicaid coverage under the Affordable Care Act.
Among the KFF findings:
- The deadline for implementing work requirements is Jan. 1, 2027. Iowa, Montana and Nebraska will implement them before that date. Most states plan to verify compliance every six months and will look back one month at application and renewal to confirm work status.
- The “work” requirement can be met in more than one way. Enrollees must spend at least 80 hours a month working, doing community service or enrolled in school training. States have added new data sources to verify school attendance and community service as well as exemptions from this requirement outlined by Congress.
- In January, 10 healthcare technology companies offered discounts on services that could help states update IT systems to support implementation of work requirements. KFF found that most are using existing vendors, in part because long procurement timelines cut into the time available to work with new companies.
- States want more guidance from CMS on a range of details, from acceptable verification methods to exemptions and what counts as “community” service. They see risk and added costs in making decisions about systems and policy in the absence of this guidance.
