The Centers for Medicare & Medicaid Services (CMS) announced an optional hold harmless period through and including June 30, 2027, providing states a transition period to further modernize systems, improve processes, and streamline the applicant and beneficiary experience.
States that implement the hold harmless period will assess whether individuals meet the work requirement or are excluded from it, but they will not deny applications or disenroll otherwise eligible individuals solely for failure to meet the requirement.
The optional hold harmless transition period gives states the ability to improve and refine their systems and processes before enforcement begins, supporting long-term success of the work requirement. It will also provide states the opportunity to learn from the early months of implementation to identify and address workforce training needs and improve the beneficiary experience.
“States have made real progress, and they’ve been clear with us about what it takes to get this right for beneficiaries—at scale and for the long term,” said Deputy Administrator and Director of the Center for Medicaid and CHIP Services Dan Brillman. “If the state can use data to show that someone is working or qualifies for an exclusion, that person should not have to track down paperwork to prove it. And when someone needs support, they should know exactly what to do, when to do it, and where to go. That’s how we build a Medicaid program that works better for people, connects them to work, education, and training opportunities, and supports paths to prosperity.”
NEWS: The administration is giving states another 6 months before they must enforce Medicaid work requirements. CMS told Medicaid directors today it's pushing the deadline from Jan. 1 to July 1. People can't be kicked off until then if states opt in. https://t.co/gOb60D2JaX
— Paige W. Cunningham (@pw_cunningham) November 13, 2026
States implementing by Jan. 1 can use the transition period to improve their systems and processes, supporting a successful launch of the work requirement.
In addition to implementing the hold harmless period, CMS also strongly encourages all states implementing the work requirement to:
Maximize automated verification. Use reliable data already available to the state to verify qualifying activities and identify people who qualify for exclusions before asking applicants and beneficiaries for additional information.
Make the process clear and easy to navigate. Give people clear, timely notices that explain what the state has already verified, what information is still needed, and how to respond or get help.
Test and strengthen end-to-end processes. Confirm that data matching, notices, and eligibility decisions work together accurately. Test how systems handle missing, outdated, or conflicting information, and identify and resolve operational issues as they emerge to minimize beneficiary burden and inappropriate coverage disruptions.
Promote Paths to Prosperity. Coordinate with community partners to connect applicants and beneficiaries who need assistance with opportunities for employment, education, job training, and volunteering, while supporting their health and well-being.
Beginning Jan. 1, 2027, certain Medicaid applicants and beneficiaries ages 19-64 must meet a statutory work requirement, unless excluded. CMS’ June 2026 interim final rule outlines qualifying activities, including 80 hours per month of work, community service, or participation in a work program; enrollment in an educational program at least half-time; a combination of qualifying activities totaling at least 80 hours per month; or meeting the specified monthly income threshold.
New: Trump admin announces it will allow states to delay enforcement of Medicaid work requirements for 6 months, until July 1 2027 Work req's are set to go into effect Jan. 1. Dems had been pushing for delay arguing states aren't ready https://t.co/OvIE5Fn1VE
— Peter Sullivan (@PeterSullivan4) November 13, 2026