On June 1, 2026, the Centers for Medicare and Medicaid Services (CMS) issued their interim final rule regarding how states are to implement Medicaid work requirements. These work requirements come directly from the Federal Budget Reconciliation Bill that was signed into law last summer.
It will take more time to fully analyze the impacts of what was released, but it is clear that the guidance will be challenging for states to implement, particularly because the definition of “medical frailty” is more restrictive than initially anticipated.
While it is still our understanding that people with intellectual and developmental disabilities will be exempt, the basis for this decision may still allow people to fall through the cracks. Essentially, the exemption is based more on an individual’s ability to satisfy the 80-hour monthly requirement, rather than a diagnosis alone. This is an area that we will analyze more closely.
We know and appreciate that MassHealth is working thoughtfully to ensure that people do not lose access. We look forward to continuing to work proactively and collaboratively with our state leaders on this.
Public comments will be accepted through July 31. Please stay tuned for a deeper analysis in the days to come.
