Medicaid Work Reporting Requirements Member Scenarios

Support for this was provided by the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the Foundation. Additional author: Judy Arnold.

H.R. 1 (P.L. 119-21) makes work reporting requirements a condition of Medicaid eligibility beginning January 1, 2027 for adults ages 19 through 64 who are applying for or renewing coverage through Medicaid expansion and expansion-like waiver programs. The new regulations require states to follow a stepwise process to determine whether an individual is subject to work reporting requirements, and, if so, to evaluate them for an exception or compliance (see the Appendix for a list of specified exclusions, exceptions, and qualifying activities). The scenarios in this toolkit illustrate how states can apply these steps in practice, including the evaluation hierarchy, data verification, and noncompliance process across specified exclusions, mandatory and short-term hardship exceptions, and qualifying activities.

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