Across the country, state and local governments are grappling with the implementation of the ‘community engagement’ or work requirements that became law in July 2025 as part of the One, Big Beautiful Bill Act (OBBBA). As part of that legislation, these new federal work requirements will apply to Medicaid beneficiaries (ages 19-64) beginning on January 1, 2027. Individuals will be required to meet the 80-hour per month requirement via work, education training (including WIOA programs), and volunteerism (or a combination of the three elements).
Research published by the Kaiser Family Foundation showed that a recent analysis of Medicaid beneficiaries from 2023 showed that nearly two-thirds are already working (at least part time). For those individuals, the challenge will be to properly document and complete any administrative steps so they can maintain their coverage. Included in the implementing rules from the Centers for Medicare and Medicaid Services (CMS) are exemptions for pregnant women, individuals who are ‘medically frail’ with serious/complex conditions impacting their ability to work, primary caregivers for dependent children under 13 years old (or disabled individual), and individuals incarcerated the three months prior to enrollment. States could also develop additional hardship exemptions.
Local workforce development professionals and stakeholders have been working with individuals to meet SNAP work requirements and TANF work participation rates so there is an expectation that work will continue for these Medicaid beneficiaries. However, unlike with SNAP and TANF, there is no additional funding connected to Medicaid work requirements.
Given the importance and connection to health insurance for Medicaid beneficiaries and their families, it is imperative that local workforce development stakeholders work with their state counterparts on the implementation of these requirements. This will require cross-agency coordination with health and workforce agencies.
