CMS drops interim final rule implementing Medicaid work requirements

CMS has published its interim final rule for Medicaid work requirements, following the agency's prior policy announcement. The rule formalizes the 80-hour monthly work or community engagement mandate for certain Medicaid expansion enrollees, with narrow exemptions for disability, pregnancy, and primary caregivers. States must now submit implementation plans to CMS for approval. Nebraska is an early test case, as noted in a related report. For clinics with a significant Medicaid population, this shift will likely lead to coverage churn and eligibility verification complexity starting in late 2026 or 2027, depending on state adoption speed.