Posted on June 5, 2026
On June 3, 2026, the Centers for Medicare and Medicaid Services (CMS) released an Interim Final Rule with Comment Period (IFC) which will require some adult Medicaid applicants and enrollees to meet a community engagement requirement of 80 hours per month by January 1, 2027. The community engagement requirement can be met through employment, volunteer work, as well as through participation in certain job programs and educational programs. This requirement will apply to Medicaid enrollees and recipients who are aged 19-64, not pregnant, and not entitled to enroll in Medicare. There are exemptions for several groups of people, including individuals with disabilities, medically frail individuals, former foster care youth, veterans with a total disability rating, and other groups.
This work requirement will only apply to certain adults in the 41 states who have expanded Medicaid under the Affordable Care Act. People in the following states will not be affected: Alabama, Florida, Georgia, Kansas, Mississippi, South Carolina, Tennessee, Texas, Wisconsin, and Wyoming.
This IFC is nearly 400 pages, so it will take time to determine everything that it includes. However, the increased bureaucratic red tape and reporting mandates which are outlined in this IFC will almost certainly cause people who are eligible for Medicaid to lose access to their benefits, solely because they cannot successfully navigate these administrative obstacles.
ACB strongly opposes this IFC. Even with the listed exemptions, the administrative obstacles created by this IFC threaten the independence and health of people with disabilities who depend on Medicaid for essential medical care. ACB will be submitting comments detailing our opposition to this rule, and we encourage others to do the same.
The rule can be found at the following link: https://www.federalregister.gov/documents/2026/06/03/2026-11094/medicaid-program-community-engagement-requirement-for-certain-individuals
This rule is open for public comment until July 31, 2026. Comments should reference file code CMS-2454-IFC and can be filed at this link: https://www.regulations.gov/docket/CMS-2026-2047