Commonwealth Fund December 18, 2025
MaryBeth Musumeci, Preeyanka Rao, Allyson Crays, Carmel Shachar

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As Medicaid work requirements take effect in 2027, it’s unclear how states will determine who qualifies as medically frail and exempt from the rules

Although medical frailty has been part of Medicaid policy for more than 20 years, the processes for determining it are often not well developed

Under H.R. 1, states must require that low-income people meet work-reporting requirements to qualify for Medicaid under the Affordable Care Act’s (ACA) Medicaid expansion. Everyone applying for or seeking to maintain coverage under the expansion must show they are participating in work or another approved activity, or that they meet a specified exemption. This requirement will affect 25 percent of current Medicaid enrollees and must be implemented by January 1, 2027,...

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