Maternity Care Billing Changes Begin in 2027 with Potential for Better Transparency and Payments Across the Continuum of Care

As readers of Say Ahhh! know, 2027 will bring a host of unprecedented Medicaid changes, including work reporting requirements. One less prominent change ahead is adoption of new maternity care codes for insurance payers. Adopting new codes for maternity care adds to the long list of Medicaid agency to-dos, but remains critical for understanding and…

August 31, 2026

By

Kay Johnson

and

Elisabeth Wright Burak

Research & Reports

How Are Parents Impacted By Medicaid Work Reporting Requirements?

Overview Starting January 2027, H.R. 1 requires every state that has expanded Medicaid to low-income adults – whether through the Affordable Care Act’s Medicaid expansion or a Section 1115(a)(2) waiver – to implement work reporting requirements (WRRs). New WRR mandates affect those enrolled in the Medicaid expansion category – coverage for adults with income up…

August 26, 2026

By

Adriana Kohler

and

Joan Alker

Blog

H.R. 1 Readiness Tracker Update: Strain Is Building Before the Work Reporting Requirements Clock Starts

As states prepare to implement work reporting requirements, we are closely monitoring Medicaid and CHIP performance indicators on our H.R. 1 tracker. The latest Q1 2026 data show the status of state eligibility systems and processes right before most states start notifying enrollees about the requirements. The short answer: already strained and getting worse. Renewals…

August 24, 2026

By

CCF Data Staff

Blog

Almost All Custodial Parents, Caretaker Relatives Should Not be Impacted by Medicaid Work Reporting Requirements in 28 States

As states rush to implement complex new work reporting requirement provisions before January 2027, the new Interim Final Rule (IFR) released by the Centers for Medicare and Medicaid Services (CMS) has caused massive confusion. However, the IFR made important clarifications about which adults are not subject to work reporting requirements (WRRs), are excluded from WRRs,…

August 13, 2026

By

Joan Alker

and

Adriana Kohler

Medicaid

CCF Comments on Medicaid Work Reporting Requirements Interim Final Rule

The Georgetown University Center for Children and Families submitted the following comments to the Center for Medicare and Medicaid (CMS) and the U.S. Department of Health and Human Services (DHHS) regarding CMS’s Interim Final Rule (IFR) implementing H.R. 1-mandated Medicaid Work Reporting Requirements (WRRs). Read the Comments.

July 30, 2026

Blog

CCF Submits Comments on Medicaid Work Reporting Requirements Interim Final Rule

Today, CCF submitted public comments on CMS’s Interim Final Rule (IFR) implementing H.R. 1-mandated Medicaid Work Reporting Requirements (WRRs). As we’ve written about time and time again, WRR policies are harmful, create unnecessary barriers to coverage, and will result in coverage losses without actually supporting work. Nonetheless, H.R. 1 has required most states to impose…

July 30, 2026

By

Jade Little

and

Joan Alker

Blog

New Report Examines How States Can Protect Pregnant/Postpartum Enrollees from Losing Health Coverage Due to Work Reporting Requirements (And Why We Should Still Be Worried)

As awareness has grown about the new Medicaid work reporting requirements (WRRs) that have already been put in place in some states but are mandated to begin January 1 of next year, it has created layers of confusion about who will be required to report work hours. Our new report on pregnant women and WRRs…

July 22, 2026

By

Elisabeth Wright Burak

Research & Reports

Medicaid Work Reporting Requirements: How Can States Protect Pregnant and Postpartum Women from Losing Health Coverage?

Overview Starting in January 2027, H.R. 1 requires every state that adopted the Affordable Care Act’s (ACA’s) Medicaid expansion to low-income adults (and select additional states) to implement work reporting requirements. These work reporting requirements (WRRs) predominantly affect those enrolled in the Medicaid expansion category—coverage for adults with incomes up to 138% of the federal…

July 17, 2026

By

Elisabeth Wright Burak

and

Kay Johnson

Research & Reports

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

By

,

,

,

and

Blog

CMS Approach to Work Reporting Requirement Won’t Work for People with Substance Use Disorders or Mental Health Conditions

By Deborah Steinberg, Senior Health Policy Attorney, Legal Action Center A few weeks ago, CCF explained how the Centers for Medicare & Medicaid Services (CMS) issued a new interim final rule with comment period (IFR) that went far beyond its authority to implement the new work reporting requirements. H.R. 1 – the budget reconciliation law…

July 9, 2026

By

Guest

Blog

Post Office Rural Service and Proposed Medicaid Work Reporting Requirements on Collision Course

I recently wrote about problems with the federal government’s suggested definition of “volunteer” in the proposed rule implementing the new law (H.R. 1) passed by Congress that requires patients to meet work/volunteer reporting requirements to maintain Medicaid coverage. The changes in this law are estimated to increase the number of uninsured Americans by 10 million people…

July 6, 2026

By

Adam Searing

Blog

How H.R. 1 Cuts and Changes to Medicaid Played out in 2026 State Legislative Sessions (Part 2)

It’s been nearly a year since H.R.1 was signed into law, enacting the largest Medicaid cuts in history and setting off a scramble in state capitals to respond. Back in March, we took a look at how ten state legislatures were grappling with the impending budget holes and policies created by H.R.1. Now that most…

July 2, 2026

By

Jade Little

and

Adriana Kohler

Blog

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

By

Andy Schneider

Blog

Ten New States Join the CCBHC Medicaid Demonstration, H.R. 1 Puts Its Success at Risk

As readers of the blog know, the Certified Community Behavioral Health Clinic (CCBHC) model has been one of the rare bright spots in more recent federal behavioral health policy and one with deep bipartisan roots. As a reminder, CCBHCs are community-based behavioral health providers that meet federal certification criteria. While some operate independently, the CCBHC…

June 29, 2026

By

Anne Dwyer

Blog

Would Benjamin Franklin’s Volunteer Fire Brigade Satisfy DHHS’s Proposed Rule on Medicaid Work Reporting “Community Engagement” Requirements?

Americans, as French political scientist Alexis de Tocqueville observed in 1831, have a special propensity for coming together outside of government as volunteers for community improvement. From Benjamin Franklin’s organization of the nation’s first volunteer fire brigade to President George H. W. Bush’s 1989 call for Americans to volunteer as a “thousand points of light,”…

June 18, 2026

By

Adam Searing

Blog

CMS Ignores the Law (Again) – This Time Taking Health Insurance Away from Individuals with Substance Use Disorders, Mental Health Conditions, and Serious Health Conditions

Just a few weeks ago, we explained how the Center for Medicare and Medicaid’s (CMS) proposed regulation on state directed payments goes far beyond the statutory authority in H.R. 1 to incredibly harmful effect. Now it has happened again. This time CMS has issued an interim final rule on work reporting requirements (the “IFR”) that…

June 18, 2026

By

Leonardo Cuello

Blog

New Federal Medicaid Work Reporting Rule Threatens Coverage for Vulnerable Americans

Statement by Joan Alker, Executive Director of the Georgetown University Center for Children and Families and Research Professor at the McCourt School of Public Policy: “This rule gives states a raw deal, but more importantly, puts health care at risk for people with illnesses and chronic conditions like cancer or a substance use disorder. It…

June 2, 2026

Blog

The New Medicaid Work Reporting Requirements Are Here—Don’t Let the Nebraska “Soft Start” Fool You

On May 1, 2026, Nebraska became the first state to start the new work requirements under H.R. 1, the law passed last year making historic cuts to Medicaid. We have reported extensively on why work reporting requirements are a bad idea. Nebraska was not adequately prepared to launch work reporting requirements, nor has the Centers…

May 11, 2026

By

Leonardo Cuello

Blog

What Do We Know So Far About State Materials & Consumer Outreach on Medicaid Work Reporting Requirements?

States need to do effective, consumer-friendly outreach and education to communicate new work reporting requirements to affected Medicaid expansion adults and new applicants. Mandatory work reporting is one of the biggest seismic shifts in Medicaid policy in a generation, and without strong outreach and public awareness – including through content that is easy to understand…

May 7, 2026

By

Adriana Kohler

and

Jade Little

Blog

2026 Report on State Medicaid and CHIP Eligibility, Enrollment, and Renewal Policies Includes Special Edition on Medicaid Work Requirements

Yesterday, the annual KFF survey report was released with a webinar featuring highlights of two reports and a discussion that included Kate McEvoy, executive director of the National Association of Medicaid Directors, and was moderated by KFF’s Larry Levitt. The webinar and reports contain important information that should be of interest to policymakers, stakeholders, members…

May 1, 2026

By

Tricia Brooks

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