New Medicaid Work Requirements Delayed

The Trump administration will give states the option of a six-month delay in enforcement of Medicaid work requirements, the Centers for Medicare and Medicaid Services announced on Friday, meaning some states can choose to start the controversial policy in July rather than January of next year.

The delay is optional, however, and states that want to move forward and begin disenrolling people who can’t prove they meet the requirement or qualify for an exception may still do so. States must inform the Trump administration by Dec. 11 which path they plan to take.

In a Friday letter to state officials, leaders of the federal agency said they were offering states this “hold harmless period” in response to feedback from around the country on “impediments to successful launches at scale, policy updates, operations, and overall readiness.” States now have until June 30, 2027 to set up the verification systems to enforce the new work requirement rules.

Republicans established the Medicaid work requirements as part of the One Big Beautiful Bill, and scheduled them to be mandatory nationwide beginning Jan. 1. The rules stipulate that all adults ages 18 to 64 enrolled in the Affordable Care Act’s Medicaid expansion prove that they’re completing at least 80 hours of work or other qualifying activities per month, such as taking classes or volunteering, unless they meet certain exemptions.

Nonpartisan government scorekeepers have estimated the policy will kick more than 5 million Medicaid enrollees off their health insurance. Democrats have pushed the Trump administration to delay or amend the new requirement in lawsuits and letters to CMS, and have pledged to repeal the work rules and cuts to the program enacted by Republicans last year when they have a House and Senate majority in 2027.

In the meantime, in a letter to CMS Administrator Mehmet Oz on Wednesday, Finance Committee Ranking Member Ron Wyden (D-Ore.) and Energy and Commerce Ranking Member Frank Pallone (D-NJ) demanded a delay in enforcement similar to what the agency announced Friday.

State officials say they’ve had to spend millions of dollars, and in some cases tens of millions, to hire staff and create the databases needed to verify whether expansion enrollees are adhering to the rules to maintain their coverage, or qualify for an exemption due to an illness, pregnancy, substance abuse disorder or other factor.

Several Medicaid officials from both blue and red states have warned in recent weeks that they are not on track to fully enforce the rules come January, saying they have yet to figure out how to access certain data files to check patients’ eligibility.

Virginia Secretary of Health Marvin Figueroa said in an interview that while he still needs to read the fine print of what the Trump administration is offering, he expects to accept the six-month grace period and sees it as “a recognition that the timeline was unrealistic.”

“There is a lot of technology that we still need to test,” he said. “We’re dealing with a lot of legacy systems that on their best days struggle to do what they’re supposed to do and on their worst days need to be replaced, and now we’re making them do things they weren’t designed for.”

State officials say legal battles over the policy have created further delays and uncertainty.

In late October a federal judge in Boston sided with a coalition of Democratic attorneys general and struck down a key piece of the law that required patients with cancer and other chronic illnesses to prove their inability to work in order to keep their insurance.

The states that brought the case said they were blindsided in June when the Trump administration put out guidance on the “medical frailty” exemption that was much narrower than what Congress approved in 2025. They were then forced to abandon months of setup work and change course, they said. Now, in the wake of the rule, they have to change course again.