The Medical Frailty Exemption from Medicaid Work Requirements: Key Takeaways from the CMS Interim Final Rule Authors: Amaya Diana, Jennifer Tolbert, and Robin Rudowitz Published: Jun 23, 2026

https://www.kff.org/medicaid/the-medical-frailty-exemption-from-medicaid-work-requirements-key-takeaways-from-the-cms-interim-final-rule/ On June 1, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a long-anticipated interim final rule that will guide state implementation of Medicaid work requirements. The 2025 reconciliation law requires 44 states to condition Medicaid eligibility for adults in the Affordable Care Act (ACA) Medicaid expansion group and enrollees in certain waiver programs, including in non-expansion states (Georgia, Tennessee, and Wisconsin), on meeting work requirements starting January 1, 2027, or sooner at state option. The law specifies mandatory exemptions, including individuals who are “medically frail.” Given the abbreviated implementation timeline, states had tentatively moved forward with key decisions over how to implement the medical frailty exemption even as they waited for formal guidance from CMS.