2025 Medicaid Work Requirements: State and National Data
- 1 and signed into law on July 4, 2025, has established new federal work requirements for specific Medicaid enrollees.
- The policy specifically targets Medicaid members between the ages of 19 and 64.
- To maintain their eligibility for Medicaid, these individuals must engage in one of several approved activities, including employment, education, a work program, or community service.
The 2025 budget reconciliation bill, known as H.R. 1 and signed into law on July 4, 2025, has established new federal work requirements for specific Medicaid enrollees. These mandates, which are also described as community engagement requirements, make continued health coverage contingent upon a member’s participation in employment or other qualifying activities.
The policy specifically targets Medicaid members between the ages of 19 and 64. This includes individuals covered through the Affordable Care Act (ACA) Medicaid expansion or those under an 1115 demonstration waiver that provides minimum essential coverage.
To maintain their eligibility for Medicaid, these individuals must engage in one of several approved activities, including employment, education, a work program, or community service.
Implementation Timeline and Guidance
The transition to these new requirements involves a phased timeline of federal guidance and state-level execution. The Centers for Medicare & Medicaid Services (CMS) issued initial guidance on December 8, 2025, with additional guidance expected to be released in 2026.
Under the law, the Secretary of Health and Human Services (HHS) is required to provide states with comprehensive implementation guidance by June 1, 2026. This forthcoming guidance is intended to include specific definitions and clarifications regarding the standards mentioned in the bill text.
States are mandated to fully implement these work requirements by January 1, 2027. However, some states may choose to implement these requirements earlier by utilizing 1115 waivers.
Public Health and Economic Projections
The introduction of national work requirements has led to analysis regarding the potential impact on healthcare access and state economies. A report titled How National Medicaid Work Requirements Would Lead to Large-Scale Job Losses, Harm State Economies, and Strain Budgets
has provided state-by-state estimates for all 50 states and the District of Columbia.
The findings in this report project several negative outcomes resulting from the policy, including:
- Large-scale losses in Medicaid coverage.
- Reductions in total employment.
- Declines in gross domestic product (GDP) and tax revenue across the states.
Administrative and State Response
Because the requirements are federally mandated, state agencies, healthcare providers, and managed care organizations are now tasked with adapting their operations. The Center for Health Care Strategies (CHCS) has initiated a series to help states design strategies that may mitigate the risk of unintended disenrollment.
The goal of these strategies is to minimize the administrative burden on both the state agencies and the Medicaid members, drawing on previous experiences to support the implementation process.
KFF has also begun tracking the implementation of the 2025 Reconciliation Law, providing data and policy updates as states navigate the new requirements. This tracking effort includes monitoring the status of waivers and the specific policies states are adopting to comply with the federal law.