CMS Announces Optional Six-Month Delay for Medicaid Work Requirements
The Centers for Medicare and Medicaid Services (CMS) has announced an optional six-month delay for states implementing Medicaid work requirements, according to a report by KFF.
On November 13, 2026, the Centers for Medicare and Medicaid Services (CMS) announced it would grant states a six-month delay on enforcing new Medicaid work requirements, as reported by KFF. This optional 'hold harmless' period allows states to request an extension through June 30, 2027, providing additional time to update systems, refine verification processes, train staff, and conduct outreach to enrollees and partners. During this period, states will need to verify whether individuals meet the work requirements or qualify for an exclusion as required by the law but can suspend application denials and disenrollments for otherwise eligible individuals who do not 'demonstrate that they meet the requirements' (Source ID 1). [1]
The delay will help many individuals who would have been barred from enrolling or who would have lost current coverage due to an inability to navigate work requirements, allowing them to obtain and maintain Medicaid temporarily. Most Medicaid enrollees are working or would likely qualify for an exemption from the new requirements, but could lose coverage because of red tape. Dr. Mehmet Oz, Administrator of the Centers for Medicare & Medicaid Services (CMS), emphasized that states must be moving toward full implementation of the requirements (Source ID 1). [1]
CMS clarified that the 'obligation to work towards full compliance with the statute' does not require states to implement a requirement that individuals prove their health condition limits their ability to work in accordance with a recent court ruling. Instead, states will only need to verify that individuals have a condition that falls into one of the five medical frailty categories specified by the statute to qualify for the medical frailty exclusion (Source ID 1). [1]
On November 13, 2026, the Centers for Medicare and Medicaid Services (CMS) announced it would grant states a six-month delay on enforcing new Medicaid work requirements, as reported by KFF. The delay will help many individuals who would have been barred from enrolling or who would have lost current coverage due to an inability to navigate work requirements, allowing them to obtain and maintain Medicaid temporarily (Source ID: 1). [1]
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According to the letter from CMS, states can request this optional 'hold harmless' period for up to six months through June 30, 2027. During this time, states will need to verify whether individuals meet the work requirements or qualify for an exclusion as required by the law but can suspend application denials and disenrollments for otherwise eligible individuals who do not 'demonstrate that they meet the requirements' (Source ID: 1). [1]
CMS clarified that the 'obligation to work towards full compliance with the statute' does not require states to implement a requirement that individuals prove their health condition limits their ability to work in accordance with a recent court ruling tossing out a key provision in the interim final rule related to the medical frailty exclusion. Instead, states will only need to verify that individuals have a condition that falls into one of the five medical frailty categories specified by the statute to qualify for the medical frailty exclusion (Source ID: 1). [1]
On November 13, 2026, the Centers for Medicare and Medicaid Services (CMS) announced it would grant states a six-month delay on enforcing new Medicaid work requirements, as reported by KFF. This delay allows states to request a 'hold harmless' period for up to six months through June 30, 2027, providing temporary relief for individuals who might otherwise lose coverage due to an inability to meet work requirements. The decision acknowledges the challenges states face in implementing these requirements and the need for additional time to prepare systems and processes. [1]
During the six-month hold harmless period, states are required to verify whether individuals meet the work requirements or qualify for an exclusion as outlined by the law. However, they may suspend application denials and disenrollments for otherwise eligible individuals who do not demonstrate that they meet the requirements. This temporary measure aims to prevent eligible individuals from being denied coverage or disenrolled due to states' unpreparedness to implement the changes, as noted by KFF. [1]
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CMS clarified that the 'obligation to work towards full compliance with the statute' does not require states to implement a requirement that individuals prove their health condition limits their ability to work. This follows a recent court ruling that dismissed a key provision in the interim final rule related to the medical frailty exclusion. Instead, states only need to verify that individuals have a condition that falls into one of the five medical frailty categories specified by the statute to qualify for the exclusion, according to the report. [1]
On November 13, 2026, the Centers for Medicare and Medicaid Services (CMS) announced it would grant states a six-month delay on enforcing new Medicaid work requirements, as reported by KFF. According to the letter from CMS, states can request this optional 'hold harmless' period for up to six months through June 30, 2027. This delay is intended to provide states with additional time to prepare for the implementation of these requirements and to avoid disenrolling eligible individuals who may not yet be able to meet the new work requirements. [1]
During the six-month hold harmless period, states are required to verify whether individuals meet the work requirements or qualify for an exclusion as outlined by the law. However, they can suspend application denials and disenrollments for otherwise eligible individuals who do not 'demonstrate that they meet the requirements.' This means that many individuals who would have been barred from enrolling or who would have lost current coverage due to an inability to navigate work requirements will be able to obtain and maintain Medicaid temporarily. [1]
CMS clarified that the 'obligation to work towards full compliance with the statute' does not require states to implement a requirement that individuals prove their health condition limits their ability to work in accordance with a recent court ruling tossing out a key provision in the interim final rule related to the medical frailty exclusion. Instead, states will only need to verify that individuals have a condition that falls into one of the five medical frailty categories specified by the statute to qualify for the medical frailty exclusion. [1]
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