In December,Nebraska was teh first state to announce that it would be enforcing Medicaid work requirements early, starting May 1, 2026.The 2025 reconciliation law requires states to condition Medicaid eligibility for adults in the ACA Medicaid expansion group and enrollees in partial expansion waiver programs (Georgia and Wisconsin) on meeting work requirements starting January 1,2027; however,states have the option to implement requirements sooner through a state plan amendment or through an approved 1115 waiver. Implementing work requirements will require complex changes to eligibility and enrollment systems,and also enrollee outreach and education,staff training,and coordination with managed care plans,providers,and other stakeholders.Early reports from the state during its recent January Medicaid Advisory committee (MAC) meeting and data from KFF’s Medicaid work requirements tracker provide initial insight into how Nebraska is preparing to implement Medicaid work requirements. similar facts from MAC meetings in other states and data on the KFF tracker can be helpful to assess how other states may implement new requirements as well.
Most Medicaid adults in Nebraska under age 65 who will be subject to the new work requirements are working already or attending school. As of March 2025, there were about 72,000 expansion enrollees in Nebraska who could be affected by the new requirements. KFF analysis indicates that roughly 65% of Medicaid adults without dependent children in Nebraska who could be subject to work requirements work 80 or more hours per month or are attending school. In addition, many enrollees who are not working the required hours will likely qualify for exemptions from the new work requirements.
In a recent Medicaid Advisory Committee (MAC) meeting, Nebraska provided a first look into how the state is planning to implement work requirements. All states are required to have a Medicaid Advisory Committee to advise the State Medicaid agency about health and medical care services. These groups include Medicaid enrollees, advocates, and providers. In its January 15, 2026 meeting, Nebraska state officials provided early insight into key decisions related to work requirements and look-back periods, data matching, medically frail exemptions, enrollee verification, short-term hardship exceptions, and outreach (Table 1). State officials also confirmed that the state does not intend to hire or increase staffing levels to facilitate implementation of work requirements or other eligibility changes.
