New Federal Guidance Implements Policy That, Research Shows, Will Not Increase Employment and Unenrolls Eligible Individuals From Medicaid Coverage
For Immediate Release: June 1, 2026
Contact: Jess Davidson, jdavidson@aapd.com; 202-465-5528
WASHINGTON, D.C. – Today, June 1, 2026, the Centers for Medicare and Medicaid Services (CMS) shared their intent to publish an Interim Final Rule (IFR) on Wednesday, June 3rd, regarding new Medicaid community engagement and work requirements. The IFR provides guidance to states on implementing the Medicaid community engagement requirements enacted last July as part of the sweeping changes and cuts to Medicaid in H.R. 1, the 2025 budget reconciliation bill.
Under these provisions, all 41 states that expanded Medicaid under the Affordable Care Act (ACA) will be required to implement work requirements for Medicaid recipients beginning January 1, 2027. The Medicaid work and community engagement requirements will apply everywhere except Alabama, Florida, Georgia, Kansas, Mississippi, South Carolina, Tennessee, Texas, Wisconsin, and Wyoming.
There will be a comment period following the formal publication of the IFR on June 3. The comment period is currently scheduled to close on July 31, 2026. AAPD encourages people with disabilities, our family members, and allies to submit comments on this interim final rule. AAPD will be creating tools and resources to support comment submissions in the coming days.
While AAPD digs into the specifics of this IFR, we know that Medicaid work requirements are a direct threat to the health, independence, and lives of millions of people with disabilities who depend on Medicaid for essential medical care, home- and community-based services, long-term supports, and life-sustaining treatments.
The research could not be clearer: work requirements do not increase workforce participation or help people get jobs; work requirements get people kicked off of Medicaid. For the millions of Americans with disabilities who depend on Medicaid not just for doctor visits but for the personal care, medications, employment supports, and services that keep them alive and living in their communities, a loss of coverage is not a mere inconvenience; it can be a death sentence.
In Arkansas, which implemented work requirements between 2018 and 2020, 18,000 people were kicked off Medicaid after work requirements went into effect. These 18,000 individuals did not lose their Medicaid because they were no longer eligible, but rather, because they could not navigate the administrative and bureaucratic barriers of work requirements. No one should be forced to prove the legitimacy of their disability over and over again in order to keep their health care coverage.
The disability community faces numerous barriers when attempting to navigate the documentation and reporting mandates for Medicaid work requirements. Many individuals lack the stable internet access, reliable transportation, or specialized assistive technology required to fulfill digital reporting obligations. Furthermore, obtaining the necessary government identification, legal documentation, and up-to-date medical certification required to prove exemption eligibility presents a significant challenge—even for those who clearly qualify. The consequence of this policy is predictable: individuals with disabilities who rely on Medicaid will be stripped of their coverage.
Despite the promises made by Congress and exemptions listed in the rule, people with disabilities will not be protected. They will lose their lifeline not because they are ineligible, but because the administrative obstacles created by this guidance are too great to overcome.
While these consequences are predictable, they do not have to be inevitable. Just as they voted for these changes last year, Congress can vote to reverse them. CMS and state governments can work to make the exemptions to this rule as broad as possible and can ensure that outreach and information sharing are conducted in the most accessible ways possible.
AAPD and numerous partner organizations from across the country worked to defeat these work requirements and accompanying cuts to Medicaid last year, warning Members of Congress of these exact consequences.
AAPD will be releasing additional resources for the community in the coming days regarding these new Medicaid work and community engagement requirements, how they operate, who is exempt, and how you can best prepare for implementation.