Partnering with States on Work Requirements Implementation

Signed into law on July 4, 2025, the One Big Beautiful Bill Act (OBBBA) is sweeping federal legislation that includes provisions establishing Medicaid work and community engagement requirements for certain adult Medicaid enrollees. This marks a significant shift in Medicaid policy and will require new systems, partnerships, and outreach strategies to ensure compliance and minimize unnecessary coverage loss.

As passed in the OBBBA, “community engagement” requirements (also known as work requirements) are a condition of Medicaid eligibility in which adults who are otherwise eligible must show they are meeting 80 hours per month of one (or a combination of) the following activities:

• Employment (paid work),
• Job training or educational program,
• Volunteer or community service, or
• Other approved engagement activities. 

Yes. Under the OBBBA, states must conduct outreach to applicable individuals enrolled in Medicaid by August 31, 2026 (or earlier, if a state has elected to implement these requirements prior to January 1, 2027). At a minimum, states must provide notice on how to comply with these requirements, the consequences of noncompliance, and how to report changes that may impact an individual’s eligibility. Notice must be provided by regular mail (or e-mail) and at least one other form (e.g., phone call, text message, website).

States will be responsible for tracking, verifying, and reporting enrollee compliance and exemptions. The OBBBA requires states to rely on “ex parte” verifications, meaning that states will have to establish processes to verify compliance and exemptions using existing, reliable information about enrollees. This information can come from state payroll databases, medical provider encounter data, or Medicaid payments to states for individuals. Where possible, states must leverage these existing data without requiring individuals to submit additional information.