What's at stake as states prepare to implement Medicaid work requirements in January. ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­    ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­  
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Medicaid

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As states prepare to implement Medicaid work requirements in January, the medical frailty exclusion could become one of the most consequential — and contested — policy areas. CMS's interim final rule established an approach to the medical frailty exclusion that differed from states’ early expectations and requires that a condition limit the individual’s ability to meet the community engagement requirements. The new standard could have significant implications for some of the people enrolled and enrolling in Medicaid, including SSI applicants, people with HIV, and others with disabilities or serious health conditions. KFF’s latest work examines these Medicaid issues and more.
 
Read the latest from KFF on Medicaid policy research, polling, and journalism below.

Featured

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The Medical Frailty Exemption from Medicaid Work Requirements: Key Takeaways from CMS' Interim Final Rule

 

CMS's interim final rule, which guides how states implement Medicaid work requirements, adopted a restrictive definition of medical frailty that differs from states’ early expectations. KFF analyzes the new guidance and potential challenges states will face in operationalizing the medical frailty exemption. 

What Could Medicaid Work Requirements Mean for SSI Applicants?

 

Medicaid work requirements may make it more difficult for some SSI applicants to maintain coverage due to the added complexity of navigating the verification process for the medical frailty exclusion. KFF's policy analysis explains why SSI applicants, who are covered through the Medicaid expansion or certain waiver programs, are particularly at risk of going uninsured under the new Medicaid rules.

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Medical Frailty and Medicaid Work Requirements: Challenges for People with HIV

 

Medicaid expansion is the most common pathway for Medicaid coverage for people with HIV, so many with HIV will be subject to new work and community engagement requirements. This analysis reviews the implications for people with HIV of the new medical frailty definition. 

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KFF Health Tracking Poll: Public Views on Fraud in Government Health Programs

 

As the 2026 midterms approach, health care costs remain voters' top health priority, but fraud in government health programs, including Medicaid and Medicare, is resonating with Republican voters, 55% of whom say it's extremely important for candidates to address. 

 

Although a majority of voters say there is at least some fraud in Medicaid, most (71%) say ensuring Medicaid beneficiaries can access the care they need should be a higher priority than preventing fraud, even if it means some fraud may occur. Republican voters are closely split on this trade-off, with about half (52%) saying access to care should be a priority and about half (47%) saying preventing fraud should be a priority.

Policy Research

More on Medicaid Work Requirements

Medicaid Work Requirements: Federal Outreach Requirements and State Plans
State Medicaid programs must inform people affected by new work requirements with federally required notices, and most states are planning other types of outreach, including phone calls, public ads, and social media posts. This brief describes the federal outreach requirements and state plans, as well as the complexities and tight implementation timelines states face.

 

In 30 of the States Implementing Medicaid Work Requirements, Governors Are on the Ballot in November

A majority of states subject to new Medicaid work requirements — 30 of 44 — will hold gubernatorial elections this November, and leadership transitions, particularly those involving a change in party, could complicate state implementation of work requirements.

 

Watch KFF’s recent event for a broader look at what's ahead for Medicaid and explore KFF's work requirements tracker for the latest data and analysis. 

Medicaid Finances

How Has Projected Medicaid Spending and Enrollment Changed Since Passage of the 2025 Reconciliation Law?

CBO’s latest projections of Medicaid spending and enrollment from February 2026 show how enrollment and spending are expected to change over the next decade, accounting for the historic policy changes and their expected reductions in future federal Medicaid spending, as well as other economic and technical changes.

 

Spending on Medicaid State Directed Payments Before New Limits Take Effect
Forty states and DC currently receive $93 billion in annual federal Medicaid spending through state directed payments (SDPs) and may be at risk due to forthcoming limits on these payments.This issue brief analyzes Medicaid spending by states on SDPs.

 

Forthcoming Policy Changes to Medicaid State Directed Payments

The 2025 reconciliation law reduced federal Medicaid spending by an estimated $911 billion from 2025 through 2034, some of which stems from new restrictions on Medicaid SDPs for hospital and other health care services. This issue brief describes SDPs and forthcoming policy changes stemming from the 2025 reconciliation law and the proposed regulation to implement those requirements and make other changes.

Program Integrity

Medicaid Program Integrity: Tracking State-Specific and Nationwide Federal Action
This tracker follows emerging developments in the federal government’s approach to Medicaid program integrity, along with the implications of those actions for different states. 

 

A Closer Look at Deficiencies in Nursing Homes

Amid changes to federal oversight of nursing homes during the Trump administration — including rescinding the nursing home staffing rule issued by the Biden administration, prioritizing inspections that are triggered by complaints over routine inspections, and suspending the deadline to report detailed ownership information — this issue brief provides an overview of the nursing home inspection process and the types of deficiencies identified during these inspections. 

Eligibility and Enrollment

Medicaid/CHIP Monthly Enrollment Tracker
This tracker presents the most recent enrollment data for Medicaid and the Children’s Health Insurance Program (CHIP), including data for children and adults.

 

New Public Charge Policies Will Likely Lead to Decreased Enrollment in Medicaid and CHIP
Between 1.4 to 4.1 million Medicaid and CHIP enrollees living in a household with a noncitizen could disenroll due to public charge and other immigration-related fears.

  

How Many Uninsured Are in the Coverage Gap and How Many Could be Eligible if All States Adopted the Medicaid Expansion?

An estimated 1.2 million uninsured individuals in the ten states without Medicaid expansion, including many working adults, people of color, and those with disabilities, remain in the "coverage gap," ineligible for Medicaid or for tax credits that would make coverage affordable through the Affordable Care Act's Marketplaces.

 

A Profile of Dual-Eligible Individuals

Approximately 12 million people are enrolled in both Medicare and Medicaid, referred to as dual-eligible individuals. This brief examines the demographic, socioeconomic, and health characteristics of dual-eligible individuals compared with Medicare beneficiaries without Medicaid.

 

Five Key Facts About Spending and Enrollment for People with Medicare and Medicaid (Dual-Eligible Individuals)

This issue brief provides a profile of enrollment and spending on dual-eligible individuals, drawing on new analysis of data on chronic conditions to show how higher rates of chronic conditions contribute to higher average spending among this population.

Health News

Medicaid Insurers’ Contracts on the Line in Tight Governor’s Race

The Democratic candidate for governor says he would make Iowa the second state to drop private Medicaid management companies, which he calls “a disaster." (KFF Health News)

 

What the Health? A Shrinking Safety Net

A new report finds that participation in the federal food stamp program is down far more than was predicted when the Republican-led Congress approved cuts in 2025. That portends a similar fate for Medicaid, as states ready comparable changes. (KFF Health News) 

 

A Deloitte-Run System Denied Medicaid Benefits for Michigan’s Disabled. Now Trump’s Law Piles On.

Complex computer systems that decide whether people, including the disabled, get Medicaid benefits have a history of errors. Now changes to comply with Trump’s signature tax and domestic policy law are inundating those systems. (KFF Health News)

 

Doctors ‘Cringe’ at Possibility of Documenting Which Medicaid Enrollees Too Sick To Work

Final regulations on Medicaid work requirements say enrollees must regularly obtain documentation — possibly from medical professionals — to prove that they’re too sick to work. Doctors say the rules put them in a tough spot. (KFF Health News)

 

What the Health? States Start Their Medicaid Cuts

Most of the federal Medicaid cuts don’t take effect until 2027, but many states are already cutting budgets in anticipation of getting fewer health dollars from Washington. Meanwhile, Congress is back from break, but progress on legislative priorities remains slow. (KFF Health News)

 

As GOP Cries Fraud, Newsom Backs Medicaid Spending on Housing and Food

Republicans say California’s use of Medicaid money for social services amounts to waste, fraud, and abuse. But even as Gov. Gavin Newsom voices concern about losing funding, he says he’s proud of the state’s holistic approach to caring for its sickest and most expensive patients. (KFF Health News)

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