Commonwealth Fund November 21, 2025
TOPLINES
In 2027, states must begin enforcing work requirements for people covered under Medicaid expansion, but those with a substance use disorder or disabling mental health condition are exempted
A proactive approach to implementing the behavioral health exemption to work requirements can help minimize impacts for Medicaid enrollees, the behavioral health crisis, and related long-term costs
H.R. 1, the tax and spending law passed in 2025, requires states to implement work requirements for expanded Medicaid populations. The law includes some exemptions, including for people with a substance use or disabling mental disorder. Starting in 2027, the work requirements will impact more than 20 million adults across 40 states and D.C., and in Georgia and Wisconsin through their waiver demonstrations. Effectively...
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