CMS Issues New Guidance for States on Medicaid Work Requirements

December 10, 2025

CMS this week provided guidance to states on changes to Medicaid stemming from the passage of H.R. 1 earlier this year.

The guidance provides additional information about Medicaid eligibility requirements for “community engagement” that will take effect January 1, 2027.  

Officials said the changes “aim to connect able-bodied, working-age adults with work and community engagement opportunities, reduce improper enrollment, and strengthen the long-term sustainability of Medicaid and the Children’s Health Insurance Program (CHIP).”

Notably, to meet the community engagement requirements, beneficiaries will need to do one or more of the following:

• Work at least 80 hours
• Complete at least 80 hours of community service
• Participate in a work program
• Be enrolled in an educational program, including an institution of higher education
• Engage in any combination of the above for at least 80 hours

The agency says its goals are to connect beneficiaries to work and community opportunities; offer flexibility to states to reduce operational costs; align policies with requirements for other programs; and protect taxpayers. The guidance also notes the income thresholds for beneficiaries.

States must require Medicaid beneficiaries who are subject to community engagement to demonstrate compliance for one or more months in between renewals, as part of the state’s routine renewal process. The guidance also outlines exceptions to these eligibility requirements.

HAP continues to review changes stemming from H.R.1 and provide updates to members. The guidance is available online.