These requirements may reduce enrollment and increase administrative complexity as states implement verification systems. Beneficiaries unable to meet the requirements could lose coverage. States will be required to adjust eligibility systems and conduct outreach and oversight. There are a number of exemptions for those who are caregivers, foster care youth, veterans, medically frail, incarcerated or recently incarcerated, in a substance use disorder treatment program, pregnant or postpartum, or otherwise experiencing short-term hardship. Depending on implementation, the transition may create confusion as those who qualify for an exemption seek to be exempted, jeopardizing health coverage.
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Department of Health and Human Services
A legally binding directive issued by a federal agency to implement, interpret, or enforce laws passed by Congress. Rules go through a formal rulemaking process, including public notice and comment, before taking effect.
Who It Impacts: Businesses, organizations, and individuals subject to federal agency oversight. For example, a new environmental regulation could impact manufacturing companies, or a healthcare rule could affect providers and insurers.
Who Is Not Impacted: People or entities not subject to the agency’s jurisdiction. For example, a rule by the Environmental Protection Agency (EPA) regulating industrial emissions would not directly impact a restaurant owner unless they operate in an affected industry.
Date Enacted
December 8, 2025
Last Updated
December 16, 2025
Policy Type
Healthcare Coverage
Healthcare Delivery, Services & Quality
No items found.
Summary
This guidance from the Centers for Medicare & Medicaid (CMS) outlines new Medicaid community engagement requirements for certain adults (generally ages 19-64, non-pregnant, non-disabled adults) enrolled in Medicaid. To remain eligible, these individuals must complete 80 hours per month of work, community service, education, or equivalent income and meet periodic verification. States must notify eligible individuals and verify compliance beginning January 1, 2026.
Impact Analysis
Legal Challenges
N/A
Take Institutional Action
- Healthcare professionals can develop patient outreach programs to educate affected Medicaid enrollees about engagement requirements, exceptions, and documentation deadlines.
- Community-based organizations can advocate for policy adjustments or exemptions for those with barriers to employment and/or education.
- Individual advocates can provide public comment on interim rules and regulations, and share relevant stories of impact.
Policy Prior to 2025
N/A
