Medicaid work requirements 2027 will test states’ medical-frailty exemptions
Certain Medicaid adults will face an 80-hour monthly requirement in 2027, while some states may demand proof for health exemptions sooner.
By Sofia Marchetti · World Affairs Correspondent
3 min read
Federal Medicaid work requirements 2027 rules will generally take effect by Jan. 1, requiring certain adults to show 80 hours a month of work, approved activities or education to gain or keep coverage. The central issue for people with serious health needs is how states decide they qualify for an exemption—and whether they can produce the evidence a state demands.
The Centers for Medicare & Medicaid Services issued its interim final rule on June 1. It applies to non-pregnant adults ages 19 through 64 who are not enrolled in or entitled to Medicare and receive coverage through the Medicaid adult group or certain Section 1115 demonstrations, CMS said in its fact sheet.
Who must meet Medicaid work requirements in 2027?
People subject to the rule can meet it by working, performing community service, taking part in a work program, or combining those activities for at least 80 hours a month. Half-time enrollment in school also qualifies, as can earning at least 80 times the federal minimum wage in a month, according to CMS.
The rule does not cover all Medicaid recipients. CMS lists exemptions for people who are pregnant or receiving postpartum coverage, people with disabilities or medical frailty, certain parents and caregivers, American Indians and Alaska Natives, former foster-care youth, and several other groups.
For the medical exemption, CMS says a person must be medically frail or have special medical needs that significantly impair their ability to meet the requirement. States, rather than CMS, will identify who is exempt and verify compliance.
How will medical-frailty exemptions be checked?
If a state cannot verify that a person met the requirement, it must issue a notice and give the person 30 calendar days to demonstrate compliance or show that the rule does not apply, CMS said. Failure to respond can result in a denied application or disenrollment, although people who lose coverage may reapply.
Fortune reported that federal regulations allow an initial self-attestation of medical frailty during the first year, but that Arkansas, Idaho, Indiana, New Hampshire, North Carolina and Ohio have laws or policies requiring documentation from the outset. The report said states may look to third-party data, such as workers’ compensation claims or prescription information, and could seek a clinician certification, disability award letter or other evidence when available data do not resolve the question.
The Medical Care Blog likewise reported that people may be able to self-attest in 2027 and once in 2028 before states seek proof when they cannot verify a condition through existing data. Those reported transition details are separate from CMS’s baseline rule, and procedures will vary by state.
Jennifer Tolbert of KFF told Fortune that an applicant may be unable to work yet unable to afford a medical appointment needed to document that limitation before Medicaid coverage begins. Disability advocates told the publication that additional paperwork can cause eligible people to lose coverage.
Supporters of stricter verification argue that it protects program integrity. Jonathan Ingram of the conservative Foundation for Government Accountability called self-attestation “fraud-by-design” in comments reported by Fortune. The publication noted that self-attestations are made under penalty of perjury and false statements can carry criminal consequences.
CMS says states must conduct outreach to affected applicants and enrollees. People who may be subject to the rule should watch for notices from their state Medicaid agency and confirm that state’s process for reporting activities or requesting an exemption.
This story draws on original reporting from Fortune.