Trump Administration Delays Enforcement of Medicaid Work Requirements

The Trump administration announced November 13, 2026, that states may protect certain Medicaid applicants and beneficiaries from work-requirement-related coverage denials through June 30, 2027. The Centers for Medicare & Medicaid Services (CMS) said the statutory requirement begins January 1, 2027.

States that choose the hold harmless period will still assess whether people meet the requirement or qualify for an exclusion. They may not deny an application or disenroll an otherwise eligible person solely because that person fails to meet it.

The rule covers certain applicants and beneficiaries ages 19 to 64, unless they qualify for an exclusion. The protection applies only in states that adopt the option.

The checks continue. The coverage consequence changes temporarily.

States decide whether to protect otherwise eligible people

State Medicaid agencies have not yet made public which states will use the option. Where a state adopts it, the federal agency says it will not take enforcement action against that state during the period.

Nebraska offers an early example of the coverage consequences states are preparing to manage. The state launched its requirements May 1, and state figures show more than 1,000 people had lost coverage or been denied benefits through August.

The option is meant to give participating states time to refine eligibility systems and processes. It does not remove the need to determine whether people meet the requirement or are excluded.

Work, service, education or income can satisfy the rule

The agency’s June 2026 interim final rule identifies several ways to qualify. They include:

• Completing 80 hours per month of work, community service or participation in a work program.
• Enrolling in an educational program at least half-time.
• Combining qualifying activities to reach 80 hours per month.
• Meeting the specified monthly income threshold.

The requirement applies unless a person falls within an exclusion. A federal judge last month blocked enforcement of a portion concerning people considered medically frail, and the administration plans to appeal. The court action concerned that portion, not the full requirement.

CMS cites system readiness as advocates warn of coverage losses

The agency described the transition as a chance for states to update systems, improve processes and make the applicant and beneficiary experience more manageable. States have raised concerns about launch readiness and the verification systems needed to check compliance.

In a letter to state Medicaid directors, Dan Brillman, deputy administrator and director of the Center for Medicaid and CHIP Services, wrote: “We have heard directly from states about their implementation timelines, impediments to successful launches at scale”. The agency urged states to use automated verification, send clear and timely notices, test eligibility processes from end to end, and work with community partners on employment, education, training and volunteer opportunities.

Brillman also said people should not have to find paperwork when state data already verifies their work or an exclusion. The agency asked states to request flexibility in their mitigation plans by December 11. That is a state planning step.

Lisa Lacasse, president of the American Cancer Society Cancer Action Network, welcomed the option, saying: “On behalf of cancer patients, survivors and their loved ones, ACS CAN is pleased to hear that states have been given the option to delay terminations or denials of coverage associated with Medicaid work requirements.”

The Congressional Budget Office estimated the requirements alone would leave 5.3 million more people uninsured by 2034 and save the federal government $317 billion. Those estimates concern the work requirements, not the temporary state option.

People who may be subject to the rule should watch for their state’s adoption decision and notices explaining what information remains necessary and how to respond. The agency’s guidance tells states to make those notices clear and timely.