06/03/2026
Advocacy Alert! ๐จ โผ๏ธ
The Centers for Medicare & Medicaid Services (CMS) has issued an Interim Final Rule (IFR) outlining how states must implement the new Medicaid work requirements enacted by Congress through H.R. 1. These requirements take effect January 1, 2027, and apply to adults ages 19โ64 enrolled in Medicaid expansion (or similar) coverage programs.
Key Provisions of the Interim Final Rule
The IFR provides guidance to states on determining which individuals are subject to Medicaid work requirements and the criteria states must use when making eligibility determinations.
The rule also defines which activities qualify as "community engagement activities" for purposes of meeting work requirements and outlines exceptions for certain individuals, including those who are considered medically frail and some family caregivers.
In addition, the IFR establishes requirements for verifying compliance and exemptions, including the use of state data systems for ex parte verification, documentation requirements, and circumstances under which individuals may self-attest.
Comment Opportunity
CMS is accepting public comments on the Interim Final Rule through July 31, 2026. This is an important opportunity to highlight potential impacts on people with developmental disabilities, family caregivers, and others who may face barriers to maintaining Medicaid coverage.
The Interim Final Rule is available here: https://www.federalregister.gov/documents/2026/06/03/2026-11094/medicaid-program-community-engagement-requirement-for-certain-individuals
CMS Fact Sheet is here: https://www.cms.gov/newsroom/fact-sheets/medicaid-community-engagement-requirement-certain-individuals-interim-final-rule-comment-period-cms
If you choose to write comments, please consider sharing any concerns regarding implementation and potential effects on individuals with developmental disabilities and their families. And, as always, please share with us and other organizations you're aligned with and we will help share your story.
Thank you for your advocacy.
Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC)