New Federal Medicaid Work Reporting Requirements Rule Threatens Coverage for Vulnerable Americans: An Explainer of the Interim Final Rule

On June 1, 2026, the Centers for Medicare & Medicaid Services (CMS), published the Interim Final Rule with Comment (CMS-2454-IFC, hereafter referred to as the IFR) “Medicaid Program; Community Engagement Requirement for Certain Individuals” as required by the 2025 Budget Reconciliation Law (hereafter referred to as H.R. 1). States that have expanded Medicaid to adults…

July 16, 2026

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Medicaid Work Reporting Requirements: States Ask a Federal Court to Protect Medically Frail Individuals from CMS Overreach

On June 3, CMS issued an Interim Final Rule (IFR) misinterpreting the work reporting requirements enacted last July in H.R. 1. The H.R. 1 provisions were bad enough, but as my colleague Leo Cuello has explained, the IFR imposes policies on states and individuals that the Congress did not enact. Most notably, the IFR makes…

July 2, 2026

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Andy Schneider

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Court Order Presses Pause on New ACIP Committee and Changes to Childhood Vaccination Schedule

It has been a tumultuous year for federal vaccine policy – and children are starting to feel the effects. Amidst a major measles outbreak, the Centers for Disease Control and Prevention (CDC) chose to roll back nearly half of all childhood vaccination recommendations in early January. As readers of Say Ahhh! Health Policy Blog might…

March 31, 2026

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Kelly Whitener

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Hannah Green

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CMS Weaponizes Fraud Against Medicaid in Minnesota: Part 2

At a White House press conference last Wednesday, Vice President J.D. Vance, newly tasked with leading a war on fraud, announced that “we have decided to temporarily halt” $259 million in federal matching payments to the state of Minnesota due to fraud against its Medicaid program. He emphasized: “…we don’t want to do this. We…

March 2, 2026

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Andy Schneider

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District Court Strikes Down Approvals of Harmful Waivers in Indiana (and Shows the Supreme Court is Wrong About Many Things)

After a week full of partisan and poorly-reasoned Supreme Court decisions, it was a relief to see that at least one federal court continues to do its job faithfully. The U.S. District Court for the District of Columbia issued yet another stellar section 1115 demonstration decision, in a case called Rose v. Becerra, vacating the…

July 3, 2024

By

Leonardo Cuello

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Comment Period for New DACA Regulation Closes November 29

The Department of Homeland Security (DHS) issued a new notice of proposed rulemaking (NPRM), “Deferred Action for Childhood Arrivals,” in late September and the comment deadline of November 29 is fast approaching. The NPRM seeks to codify the DACA policy originally laid out in a memo by then-Secretary of DHS Janet Napolitano in June 2012.…

November 11, 2021

By

Kelly Whitener

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Medicaid Wars: The Unwinding (and Litigation) Continues (Episode IV)

It’s been seven months and change since the Biden Administration took office. What it found waiting for it on January 20 was not just a crisis of democracy and a global pandemic and a surge of unaccompanied children at the border, but also a large pile of policy intended to undercut the Administration’s ability to…

August 26, 2021

By

Andy Schneider

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Some States’ Letters to CMS on Medicaid Work Requirements Double Down

Last month, CMS began taking steps to get rid of Medicaid section 1115 work requirement waivers as my colleague Joan Alker has written about. The Biden Administration sent letters to states with approved work requirements that “preliminarily” disapproved the policy on the basis of the COVID-19 pandemic and uncertainty of its aftermath on health and…

March 23, 2021

By

Allexa Gardner

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Medicaid Wars: Rescind and Withdraw (Episode II)

The Biden Administration has a long list of bad Medicaid policies to unwind. As chronicled in Episode I, the groundwork for the unwinding was laid in a Presidential Executive Order, “Strengthening Medicaid and the Affordable Care Act,” issued on January 28. Among other things, the E.O. directs the Secretary of HHS to review section 1115 demonstrations and…

March 19, 2021

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Andy Schneider

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What Can We Expect from Biden Administration on Work Reporting Requirement Waivers?

As I was waiting to watch Vice President-elect Kamala Harris start her speech on Saturday night, I tweeted the following: Goodbye and good riddance to Medicaid work requirement waivers. — Joan Alker (@JoanAlker1) November 8, 2020 It proved to be a popular sentiment – at least on my twitter feed. As we have blogged about…

November 12, 2020

By

Joan Alker

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DACA is here to stay… for now

Today, the Supreme Court rejected the Trump Administration’s decision to terminate Deferred Action for Childhood Arrivals (DACA), finding that the move was a violation of the Administrative Procedure Act (APA) because it was arbitrary and capricious. (This may sound familiar – it’s the same problem the Administration has faced in the litigation surrounding Medicaid work…

June 18, 2020

By

Kelly Whitener

Blog

Medicaid Work Requirements: News from the Litigation Front

It has been obvious for several months that the wheels have come off the Medicaid work requirements bus. The Secretary of HHS has approved “demonstrations” of work requirements in nine states; none of these states is currently implementing. And no state that accepts the 6.2 percentage point increase in its federal Medicaid matching rate made…

May 27, 2020

By

Andy Schneider

Blog

D.C. Circuit on Medicaid Work Requirements: Read the Statute

For over two years, CMS Administrator Seema Verma has been on a crusade to impose work requirements on Medicaid beneficiaries. Her agency has approved ten state “demonstrations” of work requirements under section 1115 of the Social Security Act. When federal District Court Judge James Boasberg ruled on four separate occasions that the Secretary’s approvals of…

February 19, 2020

By

Andy Schneider

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Appeals Court Strikes Decisively at the Heart of Administrator Verma’s Medicaid Agenda

In a decision which warmed my heart on a cold Valentine’s Day here in Washington, the federal Court of Appeals issued an unanimous opinion striking down the Arkansas work requirements waiver. In doing so, it upheld district court Judge Boasberg’s decision vacating the Arkansas’ Section 1115 waiver (including most famously Medicaid work requirements) because it…

February 14, 2020

By

Joan Alker

Blog

Medicaid Work Requirements and Beyond: CMS Administrator Tries a New Work-Around

For the past 3 years, CMS Administrator Seema Verma has been on a crusade to convert Medicaid from health insurance to a welfare program. The spear at the point of this attack has been work requirements, which, under the guise of “demonstrations,” she has sought to impose as a condition of eligibility for Medicaid coverage. …

January 30, 2020

By

Andy Schneider

Blog

South Carolina Becomes First State to Impose Harmful Work Requirements Primarily on Poor Parents

I had held out a little sliver of hope that the Trump Administration would not cross this line but today those hopes were extinguished when CMS Administrator Verma traveled to South Carolina to personally deliver the news to South Carolina Governor McMaster that his state would be the first in the nation to apply a…

December 12, 2019

By

Joan Alker

Blog

Medicaid Work Requirements: Another Win for Beneficiaries, Another Loss for CMS

CMS Administrator Seema Verma is visibly proud of her agency’s Medicaid and CHIP scorecard, which she claims has ushered in “a new era of accountability and transparency in Medicaid”. The scorecard includes measures of, among other things, federal administrative accountability; one of those measures reports the percentage of Section 1115 demonstration applications that CMS approved…

July 30, 2019

By

Andy Schneider

Blog

Judge Blocks Arkansas and Kentucky Medicaid Work Requirement Waivers: What Does This Decision Mean for Other States?

Under the Administrative Procedures Act (APA), federal agencies may not take actions that are “arbitrary or capricious.” If they do, federal courts are instructed to hold the action unlawful and set it aside. Late yesterday afternoon, that’s exactly what Judge James E. Boasberg of the U.S. District Court in the District of Columbia did with…

March 28, 2019

By

Andy Schneider

Blog

Evaluating the Administration’s Narrative on Medicaid Work Reporting Requirements

It turns out that last week was Never Mind Week. Who would have guessed? On Monday the Administration released its “Budget for a Better America,” proposing to cut federal Medicaid spending by nearly $1.5 trillion (with a “t”) over the next ten years. These cuts included a mandate that state Medicaid programs require that “able-bodied,…

March 19, 2019

By

Andy Schneider

Blog

CMS Administrator Ignores Congressional Advisory Committee Recommendation

In 2009, Congress created the Medicaid and CHIP Payment and Access Commission (MACPAC) to advise it on coverage for low-income Americans through Medicaid and CHIP. One of MACPAC’s statutory responsibilities is to “review and assess…Medicaid and CHIP eligibility policies, including a determination of the degree to which federal and state policies provide health care coverage…

February 15, 2019

By

Andy Schneider

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