Medicaid Work Reporting Requirements: Implementation Planning Milestones

Kinda Serafi, Lisa Sbrana, Gini Morgan, Mindy Lipson, and Ellen Montz, Manatt Health

H.R.1, signed into law by President Trump on July 4, 2025, requires that states implement work reporting requirements for adults ages 19 through 64 who are enrolled through Medicaid expansion or expansion-like coverage under a section 1115 demonstration. The effective date of work reporting requirements is January 1, 2027 and states will need to proactively prepare for implementation by developing comprehensive policy and operational plans that align with federal guidelines while addressing state-specific needs. The toolkit outlines the key implementation milestones that it is anticipated states will need to meet to launch work reporting requirements and a timeline for doing so.

For an overview of the work reporting requirements in H.R.1, see the expert perspective Medicaid Work Reporting Requirements: Implementation Basics and State Decision Points.

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