This Insight is part of PYA’s two-part thought leadership and shares in-depth information about Medicaid community engagement requirements for non-impacted states. Read PYA’s article about the requirements for impacted states.
Medicaid community engagement requirements, commonly referred to as Medicaid work requirements, generally apply to the Medicaid Expansion population under the Affordable Care Act (ACA) or specified Section 1115 demonstration populations and are required to be implemented by January 1, 2027. Six states will experience no impact, and four states will have limited impact. In all, providers should be aware of their state’s situation.
Following the Centers for Medicare & Medicaid Services (CMS) release of CMS-2454-IFC interim final rule on June 1, 2026, several news outlets began reporting on the requirements.[1] The reports suggest that implementation of the requirements would cause a significant drop in Medicaid enrollment, similar to the Medicaid redetermination “unwinding” after the COVID-19 public health emergency, and omit details about states that have little or no impact.
Which States Are Not Required to Implement the Medicaid Community Engagement Requirements?
Six states are not required to implement the Medicaid community engagement requirements:
- Alabama
- Florida
- Kansas
- Mississippi
- Texas
- Wyoming
The six states are exempted because they did not expand Medicaid under the ACA and do not have any 1115 waiver populations that meet the definition.
Which Non-Expansion States May Be Impacted by the Medicaid Community Engagement Requirements?
Several states, however, that did not expand Medicaid under the ACA may be impacted by the Medicaid work requirements. The following states have not expanded Medicaid but have populations that may be impacted by the work requirements:
- Georgia originally implemented an expansion-like program including a work requirement in 2023. However, the enrollment in the program has been much smaller than expected (approximately 16,000[2]), and the implementation has been challenging.
- South Carolina and Tennessee[3] have a small population of Caretaker Relatives that are covered above the required federal poverty level that could be considered expansion-like. These states got approval for this coverage group through waivers negotiated with CMS several years ago. The addition of the coverage group is not considered part of Medicaid Expansion. Both states will implement Medicaid work requirements, but the impact will be significantly smaller than in Medicaid expansion states.
- Wisconsin did not expand Medicaid under the ACA, but it has extended coverage to certain low-income childless adults between the ages of 19 and 64. Those individuals will be subject to the community engagement requirements. The Wisconsin Department of Health Services informed members to expect a mailing this fall about whether they are impacted.[4]
Providers in these 10 states should see little to no impact from implementation of the Medicaid community engagement requirements.
Medicaid Community Engagement Requirements Basics
CMS describes the population impacted by the June 1, 2026, interim final rule as “non-pregnant adults between the ages of 19 and 65 who are not entitled to or enrolled in Medicare and are eligible for or enrolled in the Medicaid adult group or in certain section 1115 demonstrations that provide minimum essential coverage to adult beneficiaries”. [5]
While Georgia, South Carolina, Tennessee, and Wisconsin must implement community engagement requirements, most of the individuals covered under those waivers are excluded from the requirements:
- Pregnant women or women in a postpartum period
- Children under age 19
- Disabled or medically frail individuals
- Parents and caretakers of children under age 14
- People with disabilities
- American Indians and Alaska Natives
Members not covered by these exemptions must meet the community engagement requirements. Those requirements are defined as 80 hours per month of qualifying activities:
- Employment
- Participation in community service
- Participation in a work program
- Enrollment in an educational program at least half time
- A combination of these four activities for at least 80 hours per month
Learn about Medicaid community engagement requirements in impacted states.
How to Prepare for the Medicaid Community Engagement Requirements
As the Medicaid community engagement requirements draw closer, providers should be wary of news reports that do not reflect the nuances of the regulation. State Medicaid agencies implementing the community engagement requirements will be notifying impacted members this fall. Providers should watch for notifications from their state’s Medicaid agency or their state-wide provider organizations as notices start being sent to members. Additionally, PYA will continue to monitor implementation of the Medicaid community engagement requirements and update providers. The public comment period for the interim final rule closes on July 31, 2026.
PYA’s Managed Care experts help all states understand, prepare for, and operationalize strategies in response to the Medicaid community engagement requirements.
[1] 2026-11094.pdf
[2] Data Tracker — GeorgiaPathways.org
[3] Based on results of a national survey conducted by KFF and the Georgetown Center for Children and Families, 2024.
[4] Medicaid: New Federal Work Requirement | Wisconsin Department of Health Services
[5] Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC) | CMS
