As states move forward with implementing Medicaid changes included in the One Big Beautiful Bill Act (OBBBA), one of the most extensive changes includes forthcoming Medicaid work requirements, which are estimated to result in up to 5.2 million beneficiaries losing their Medicaid coverage by 2034.
While some have opted to implement the requirements early, the new work reporting requirements will take effect in most states on January 1, 2027*. These requirements introduce more restrictive eligibility rules for enrolling in and maintaining Medicaid coverage and increase the risk that eligible individuals or those who qualify for an exemption could lose coverage due to paperwork or other administrative barriers. Compounding the issues for patients and families, states also face significant challenges in supporting beneficiaries and applicants through outreach and education materials about these changes.
Substance use disorder providers anticipate work requirements’ administrative burdens
In a recent Source New Mexico article, Medicaid advocates and beneficiaries expressed concerns that work requirements could cause patients to lose a critical pathway for effective and affordable substance use disorder treatment:
- “Changes that make it harder for people with drug-use disorders to get or renew Medicaid coverage will push [the overdose death] toll up… It’s not theoretical… It’s happening every day. Treatment at clinics like this are a literal lifeline.”
–– Daniel Duhigg, addiction psychiatry specialist at Duke City Recovery Toolbox, a methadone clinic in Alburquerque, New Mexico
- “It’s going to be time-consuming, it’s going to be labor-intensive… It puts a strain on our system.”
–– Kate Morton, chief clinical officer at Alburquerque Health Care for the Homeless in Alburquerque, New Mexico
Physicians worry about determining if their patients are “medically frail”
The Centers for Medicare and Medicaid Services (CMS) published an interim final rule on the work requirements. The interim final rule further limits who qualifies for the “medically frail exemption” by requiring that in addition to having a “qualifying condition,” beneficiaries must also demonstrate that said condition “significantly impairs” their ability to comply with work requirements. An article in The Washington Post spotlights providers’ concerns around Medicaid work requirements and the complex assessment around ability to work:
- “When you introduce unnecessary, non-evidence-based, confusing and bureaucratic policies like this into clinical care, it just raises the level of moral distress for providers… But deciding whether a patient is too sick to work is a subjective, high-stakes decision… We’re trained to take care of people. We’re trained to learn about someone’s symptoms, make diagnoses, [and] treat them. We’re not trained to make these kinds of work determinations.”
–– Christopher Chen, hospitalist at Valley Medical Center in Renton, Washington, and senior adviser at Manatt Health
National cancer center leaders fear work reporting requirements may interfere with patients’ “treatment, recovery or long-term survivorship care”
A piece in Becker’s Oncology highlights concerns from operational leaders and oncologists from cancer centers across the country as they look to support their patients under the new Medicaid work requirements:
- “A cancer diagnosis often creates significant physical, emotional and financial burdens. Patients may experience periods of disability, reduced work capacity, frequent medical appointments and treatment-related complications that make compliance with additional administrative requirements challenging…”
–– David Cohn, MD, COO and Gynecologic Oncologist at The Ohio State University Comprehensive Cancer Center, Ohio
- “Even short-term lapses in coverage due to reporting challenges or eligibility changes could disrupt continuity of care, delay treatment and ultimately impact outcomes… We are proactively preparing by strengthening patient navigation and financial counseling support to help individuals understand and meet new requirements.”
–– Michaela Newman, MSN, RN, Executive Director of Operations for Cancer Services at Nebraska Medicine’s Fred & Pamela Buffett Cancer Center, Nebraska
Policymakers must provide states, providers and beneficiaries with adequate support for enrollment so that eligible individuals can get and keep the coverage they need. For more information on Medicaid’s vital role, visit https://modernmedicaid.org/.
*Nebraska implemented work requirements on May 1, 2026. Montana began implementation on July 1, 2026, and Iowa will begin implementation on December 1, 2026. Arkansas launched a soft implementation on July 1, 2026, but will not disenroll beneficiaries before January 1, 2027.