Sep 16, 2026 · 9 min · 6 segments
The federal government issues guidance on medical frailty exemptions to Medicaid community engagement requirements. Pennsylvania reports a fourth measles-related death. And the Centers for Disease…
States must implement the requirements, commonly known as work requirements, by January first, twenty twenty-seven under HR1, commonly known as the One Big Beautiful Bill Act.
The Congressional Budget Office estimates the law will cut federal Medicaid spending by roughly one trillion dollars over the next decade.
Under the law, adults between the ages of nineteen and sixty-four who receive Medicaid through the Affordable Care Act expansion or through certain eleven fifteen demonstration waivers must complete eighty hours of employment, education, a work program, or community service each month to maintain coverage.
The law includes exemptions for people with caregiving responsibilities, pregnant women, certain American Indian and Alaska Native beneficiaries, and people who are medically frail.
The law defines medical frailty to include five categories: blindness or disability, a substance use disorder, a disabling mental disorder, a physical, intellectual, or developmental disability that significantly limits activities of daily living, or a serious or complex medical condition.
In a slide deck released last week, CMS said states may use a three-tiered approach based on diagnosis codes and other available data.
Under Tier 1, a diagnosis may be enough to show that a person's condition significantly impairs their ability to meet the work requirement.
CMS cites conditions including ALS, pancreatic cancer, and end-stage renal disease as examples.
Tier 2 covers conditions that may indicate medical frailty but require additional information, such as claims data, care management records, or functional assessments.
Those cases would receive individualized manual review, and states can request medical records, provider documentation, or other evidence of functional limitations.
CMS says its three-tier system is optional, and states may develop their own approaches.
But regardless of the method they use, states must determine both that a person has a qualifying condition and that the condition significantly impairs the person's ability to work or complete another qualifying activity.
States must implement the requirements, commonly known as work requirements, by January first, twenty twenty-seven under HR1, commonly known as the One Big Beautiful Bill Act.
The Congressional Budget Office estimates the law will cut federal Medicaid spending by roughly one trillion dollars over the next decade.
Under the law, adults between the ages of nineteen and sixty-four who receive Medicaid through the Affordable Care Act expansion or through certain eleven fifteen demonstration waivers must complete eighty hours of employment, education, a work program, or community service each month to maintain coverage.
The law includes exemptions for people with caregiving responsibilities, pregnant women, certain American Indian and Alaska Native beneficiaries, and people who are medically frail.
The law defines medical frailty to include five categories: blindness or disability, a substance use disorder, a disabling mental disorder, a physical, intellectual, or developmental disability that significantly limits activities of daily living, or a serious or complex medical condition.
In a slide deck released last week, CMS said states may use a three-tiered approach based on diagnosis codes and other available data.
Under Tier 1, a diagnosis may be enough to show that a person's condition significantly impairs their ability to meet the work requirement.
CMS cites conditions including ALS, pancreatic cancer, and end-stage renal disease as examples.
Tier 2 covers conditions that may indicate medical frailty but require additional information, such as claims data, care management records, or functional assessments.
Those cases would receive individualized manual review, and states can request medical records, provider documentation, or other evidence of functional limitations.
CMS says its three-tier system is optional, and states may develop their own approaches.
But regardless of the method they use, states must determine both that a person has a qualifying condition and that the condition significantly impairs the person's ability to work or complete another qualifying activity.
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