CMS Launches Nationwide Framework to Implement Medicaid Work Requirements
CMS Launches Nationwide Framework to Implement Medicaid Work RequirementsThe Centers for Medicare & Medicaid Services (CMS) released an Interim Final Rule with Comment (IFC) requiring that certain adult Medicaid applicants and enrollees must, as a condition of Medicaid eligibility, meet an 80 hours per month work requirement, through employment, education, work programs, or community service. The rule establishes a nationwide operational framework designed to promote economic stability, self-sufficiency, and independence.
Quick Links:
- Medicaid Flyer For The Liver Spot Community PDF: https://lifering.org/wp-content/uploads/2026/07/Medicaid-Flyer-July-1-2026.pdf
- Medi-Cal Changes: https://www.dhcs.ca.gov/medi-cal/updates/medi-cal-changes/
- Medicaid Community Engagement Requirement Interim Final Rule (CMS-2454-IFC) Press Release: https://www.cms.gov/newsroom/press-releases/cms-launches-nationwide-framework-implement-medicaid-work-requirements
- Full copy of Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC): https://www.cms.gov/newsroom/fact-sheets/medicaid-community-engagement-requirement-certain-individuals-interim-final-rule-comment-period-cms
- National Medicaid number: 1-877-267-2323.
- Medicaid State Contact Directory: https://www.medicaid.gov/about-us/where-can-people-get-help-medicaid-chip
Because Medicaid is administered at the state level, the best way to get personalized help is to call your specific state’s Medicaid office. Find your state's direct phone number by using the Medicaid State Contacts Directory.
Medicaid Community Engagement Requirements
What The Liver Spot Participants Need to Know | Information current as of June 2026
Why are we talking about this?
Beginning no later than January 1, 2027, many states will begin implementing new federal Medicaid Community Engagement Requirements (sometimes called "Medicaid work requirements"). These new rules may affect whether some adults remain eligible for Medicaid.
For people living with advanced liver disease, recovering from alcohol use disorder, awaiting transplant, or adjusting to life after transplant, maintaining health insurance is often essential for ongoing medical care.
The Liver Spot wants participants to understand these changes so we can prepare—not panic.
Frequently Asked Questions
What is the Medicaid Community Engagement Requirement?
Certain adults enrolled through Medicaid Expansion may be required to complete 80 hours per month of qualifying activities to keep Medicaid coverage.
Qualifying activities may include:
- Employment
- Job training
- Education
- Community service
- Approved work programs
Some people may also qualify by earning a minimum monthly income established by federal rules. Activities may be combined to reach the 80-hour monthly requirement.
When does this start?
Federal law requires states to implement these requirements no later than January 1, 2027, although some states may begin earlier.
Does everyone on Medicaid have to comply?
No.
The requirements apply only to certain Medicaid beneficiaries. Many people are exempt.
Who may be exempt?
Federal guidance includes exemptions for many individuals, including:
- Pregnant individuals
- Postpartum individuals
- People considered medically frail
- Many people with disabilities
- Certain caregivers
- Former foster youth
- American Indians and Alaska Natives
- People already meeting similar SNAP or TANF work requirements
Additional state-specific exemptions may also exist.
What does "medically frail" mean?
This is an important question.
CMS recognizes that some individuals have serious medical conditions that make work requirements inappropriate.
Examples may include people with:
- Serious chronic illnesses
- Complex medical needs
- Conditions requiring ongoing treatment
- Physical or mental limitations
States will determine how medical frailty is documented using federal guidelines. Some aspects of these determinations are still being clarified.
I have liver disease. Am I automatically exempt?
Not necessarily. Each person's situation is unique.
Having liver disease alone does not automatically qualify someone for an exemption. However, many Liver Spot participants may qualify if they are considered medically frail or meet another exemption category.
I am waiting for a liver transplant. Will this affect me?
Possibly.
Many transplant candidates have serious medical conditions that may qualify for exemptions, but eligibility will depend on state implementation and individual circumstances.
If you are listed for transplant, discuss this with:
- Your transplant coordinator
- Your hepatologist
- Your Medicaid case worker
Do not assume your exemption will happen automatically.
I already work. Do I have anything to worry about?
Possibly. Even if you are working enough hours, you may still have to report or verify your work.
Many experts note that maintaining eligibility may depend not only on meeting the requirement but also on completing any required documentation.
I can't work because of my health. What should I do?
If your medical condition limits your ability to work:
- Speak with your physician.
- Ask whether your condition may qualify as medically frail.
- Keep copies of important medical documentation.
- Stay in communication with your Medicaid office.
Does volunteering count?
In many cases, yes.
Community service is listed as one of the qualifying activities under the federal rule. Specific qualifying activities will ultimately be determined by your state's implementation.
Does school count?
Yes.
Enrollment in an educational program at least half-time can satisfy the federal requirement.
Can different activities be combined?
Yes.
Federal rules allow combinations of work, education, community service, and qualifying programs to reach the required monthly hours.
What happens if I don't meet the requirement?
States are required to notify individuals if they cannot verify compliance and generally must provide an opportunity—typically 30 days—to demonstrate compliance or show that an exemption applies before taking action on eligibility.
Could I lose Medicaid because of paperwork?
Potentially.
Some health policy experts and researchers point to earlier state experiences in which eligible people lost coverage because of reporting or administrative issues rather than because they were not working. This is one reason it is important to respond promptly to notices and keep documentation up to date.
What Liver Spot Members Can Do Now
Stay informed.
Rules will be implemented by each state.
Keep your contact information updated.
Don't miss important Medicaid notices.
Save important medical records.
Keep copies of:
- physician letters
- transplant status
- hospital discharge summaries
- disability documentation
Talk with your healthcare team.
Ask: "Will my medical condition qualify me for an exemption?"
Don't ignore mail from Medicaid.
Deadlines matter.
Reach out early if you receive a notice.
Waiting can make problems harder to resolve.
Remember
The Liver Spot is a peer-support community.
We are not attorneys, insurance specialists, or Medicaid caseworkers.
We encourage every participant to discuss their individual situation with:
- Their transplant center
- Their hepatology team
- Their Medicaid eligibility office
- A qualified benefits counselor or legal aid organization, if needed
Final Thoughts
For many people in recovery and living with liver disease, Medicaid is more than an insurance program—it can be the pathway to transplant evaluation, medications, counseling, laboratory monitoring, and long-term recovery support.
The new Community Engagement Requirements introduce additional responsibilities for some beneficiaries, but they also include exemptions and appeal processes. Understanding the rules early, keeping documentation organized, and staying connected with healthcare providers can help reduce the risk of interruptions in coverage.
