All But the Most Disabled Threatened by Medicaid Work Requirements
New federal work requirements could cause people with disabilities in the Medicaid expansion population to lose coverage — even when they should qualify for an exemption. Medicaid is a critical source of health care and home and community-based services (HCBS) that help many people with disabilities live independently. Last year, H.R. 1 added new work requirements to Medicaid expansion programs, putting coverage at risk for people who may face barriers to work, documentation, or navigating the exemption process.
On June 3, the Centers for Medicare and Medicaid Services (CMS) released a rule explaining how those work requirements will work. Under the rule, most people on Medicaid expansion between ages 19 and 64 must show they are doing at least 80 hours per month of work, school, job training, volunteering, or similar activities to keep their coverage. States must follow this rule by January 1, 2027.
The Problem With the Disability Exemption
The rule does not simply exempt everyone with a disability. Instead, it requires people to show both that they are medically frail or have special medical needs, and that those needs significantly impair their ability to comply with the work requirements. That two-part burden of proof creates a documentation challenge — and raises the risk that people who should be exempt could still lose coverage.
In plain terms: even if you have a disability, your state may still require you to meet the work requirements. If you can't document your compliance — whether because you truly can't work, because accessible jobs aren't available, or because the paperwork process is unclear — you could lose your health care. CMS's own estimates project that millions of people could lose Medicaid coverage under the rule.
❗ Comments on the CMS rule are due July 31, 2026. The resources below can help you submit a public comment or contact your legislators.
For Taking Action
#ProtectMedicaid
This is one of three major threats disabled people are facing right now. See all three and how to get involved →
ECNV will be participating in Hill Day on Wednesday, July 22nd, during NCIL's annual conference, bringing these issues directly to our representatives in Washington. If you're interested in joining us, please email Laura Kim, Policy & Advocacy Coordinator, at LauraK@ecnv.org by July 15th.
We're stronger when we advocate together!