Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC)

Administration Share Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC) As required by law, on June 1, 2026, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule implementing a new statutory requirement for certain adults in Medicaid to meet an 80 hours per month work requirement (sometimes referred to as Medicaid community engagement) as a condition of eligibility. States must generally implement this requirement no later than January 1, 2027 . This fact sheet discusses the provisions of the Interim Final Rule with Comment Period. Who is Affected? The work requirement applies to non-pregnant adults between the ages of 19 and 64 who are not entitled to or enrolled in Medicare and are eligible for or enrolled in the Medicaid adult group or in certain section 1115 demonstrations that provide minimum essential coverage to adult beneficiaries. To date, 43 states and the District of Columbia provide coverage to these populations and will be required to implement the new requirement; U.S. territories are not subject to this law. Certain individuals are exempt from the requirement, including those who are pregnant or in a postpartum period, disabled or medically frail, parents and caretakers of children under 14 years of age or people with disabilities, American Indians and Alaska Natives, and certain others. States may also elect to offer short-term hardship exceptions for individuals subject to the work requirement under specific circumstances—for example, those receiving inpatient or certain other medical services, individuals who need (or whose dependent needs) to travel outside their community for certain medical care not available in their home community, those in a county with an unemployment rate at or above 8% or 1.5 times the national average, and those who reside in a county where certain national emergencies or disasters exist. What the Requirement Means Under the rule, affected Medicaid applicants and enrollees (referred to as “applicable individuals”) will be required to demonstrate 80 hours per month of qualifying activities, such as employment, participation in certain work programs, or community service, or be enrolled in educational program at least half time. Individuals may combine activities to meet the 80-hour requirement. or meet it by earning at least 80 times the Federal hourly minimum wage ($580 per month in 2026); for seasonal workers, there is a different calculation. Certain new Medicaid applicants will need to meet the requirement for at least one month before the month in which the applicant applies, and existing Medicaid beneficiaries will need to meet the requirement for one or more months between renewals. States must verify compliance of applicable individuals at application, at renewal, and—at state option—at more frequent periodic intervals. If a state cannot verify that an individual has met the requirement, it must send a notice of noncompliance and provide the individual with 30 calendar days to demonstrate compliance or that the requirement does not apply to them. If the individual fails to do so, their application might be denied or they might be disenrolled from Medicaid. Individuals who are disenrolled may reapply at any time and will be assessed for compliance upon reapplication. States are responsible for implementing and administering the work requirement. This includes: Identifying who is and is not subject to the work requirement, including who meets an exception; Verifying that applicable individuals meet the requirement at application and renewal Providing outreach and notice to affected populations; Taking defined steps when individuals are found noncompliant or compliance cannot be verified; Submitting data to CMS to support monitoring and program integrity. CMS is issuing new reporting requirements and will use existing data reporting systems to monitor state implementation. States that fail to submit required data or show compliance issues may be subject to corrective action. Key Provisions The following chart is a high-level summary of key provisions in the Interim Final Rule. For more information on all provisions, see https://www.federalregister.gov . Topic Description Work Requirement Beginning January 1, 2027, (or earlier date chosen by the state) states must require that certain adults meet a work requirement to enroll in Medicaid or keep their Medicaid coverage when their eligibility is renewed. The work requirement applies to “applicable individuals” or non-pregnant adults between the ages of 19 and 64 who are not entitled to or enrolled in Medicare and are eligible for or enrolled in the Medicaid adult group or in certain section 1115 demonstrations that provide minimum essential coverage to adult beneficiaries. States must conduct outreach to adults who are already enrolled in Medicaid and could be subject to the requirement prior to implementing the new r