Five governors have asked the Department of Health and Human Services to delay the Jan. 1, 2027, deadline for implementing Medicaid work requirements, arguing that the new policy left states without enough time to make changes.
Under the new Medicaid work requirements, those aged 19 to 64 must work, volunteer, or participate in job training for at least 80 hours per month or earn $580 per month. Qualified activities also include being a part-time student.
The June guidance from the Centers for Medicare and Medicaid Services applied to 20.4 million Medicaid expansion beneficiaries with household income up to 138 percent of the federal poverty level. Exemptions include being pregnant, medically frail, a parent of children under 14, or a caregiver for a disabled person.
The federal agency further published guidance in September on using data matching to determine medical frailty to reduce the need for additional documentation from beneficiaries.
Governors stated that states will not be able to adjust within less than 100 days before Jan. 1, as compliance or exemption evaluation requires new system logic, revised processes, updated notices, and additional staff training.
“We have been candid from the outset that we oppose these requirements as a matter of policy. Medicaid eligibility has historically been based on income, not employment status, and conditioning coverage on work reporting will cause harm,” the governors wrote.
“The new rules institute additional administrative barriers that will lead to people losing their healthcare,” Oregon Gov. Tina Kotek said in a statement, adding that one-third of Oregon families rely on Medicaid.
Kotek, California Gov. Gavin Newsom, Maine Gov. Janet Mills, New Mexico Gov. Michelle Grisham, and Virginia Gov. Abigail Spanberger signed the letter to Health Secretary Robert F. Kennedy, Jr. on Oct. 1.
The governors did not request an indefinite postponement but asked the federal department to delay the compliance date until states’ systems are ready.
The five states are among 25 states suing the Trump administration over the Medicaid work requirement rule, alleging the rule adds costs to states and creates a tight timeline that is difficult to comply with.
A judge rejected states’ request to block the rule in July and said Congress, in the 2025 One Big Beautiful Bill Act, set the timeframe, not the Centers for Medicare and Medicaid Services.
Denials in Nebraska
Nebraska was the first state in the nation to start implementing Medicaid work requirements in May. After a few months of implementation, the state released data on the new policy in September and found the majority of work requirement-related denials in the state were due to lack of documentation.
During the three months from May to August, Nebraska denied nearly 52 percent of more than 9,600 new applications.
Roughly 11 percent of denials were related to work requirements, most (88 percent) of which were due to not providing requested information.
But the majority (89 percent) of denials were for other reasons, such as exceeding eligible income limits.
Among more than 500 renewal denials—7 percent of total renewals—between July and August, most (92 percent) lacked sufficient documentation to demonstrate compliance or exemption, and 8 percent were noncompliant.
Nebraska Medicaid exempted more than 62 percent of renewed enrollees from work requirements mainly as a result of being a parent (31 percent) or medically frail (39 percent).
The new rules appear to have a bigger impact on new applicants than those currently enrolled in Medicaid, Joan Alker, a research professor at Georgetown University, said in a September analysis.
“Over time, this will result in lower Medicaid enrollment through attrition and more barriers to getting back on even if someone is still eligible,” Alker said.









