Work Reporting Requirements
H.R.1 imposed a mandate on states to establish new work reporting requirements (WRR) for adults covered through Medicaid expansion or similar coverage offered through a waiver.
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The U.S. dollar wrapped by red tape
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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…
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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…
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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…
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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…
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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…




