Medical Frailty and Medicaid Work Requirements: Challenges for People with HIV Authors: Lindsey Dawson and Jennifer Tolbert Published: Jul 1, 2026

https://www.kff.org/medicaid/medical-frailty-and-medicaid-work-requirements-challenges-for-people-with-hiv/?utm_campaign=KFF-HIV-AIDS&utm_medium=email&_hsenc=p2ANqtz--RED5r1ZUUKIcyQpLwENlbI0Sn6hxQcQCxTy34qqOhOhBvNq873hiueYn3dKa2bSZhhlGrvEYBJLtaO6_3eimplkVozQ&_hsmi=426519366&utm_content=426519366&utm_source=hs_email On June 1, 2026, the Centers for Medicare and Medicaid Services (CMS) issued an interim final rule providing states with guidance for implementing Medicaid “community engagement” or Medicaid work requirements as part of the 2025 federal budget reconciliation law. The law requires states to condition Medicaid eligibility for enrollees with coverage through the Affordable Care Act (ACA) expansion or under certain waivers on meeting these requirements or qualifying for an exclusion, including one related to being “medically frail or otherwise” having “a special medical need.” In defining medical frailty, the rule introduces a two-part test, requiring an enrollee to both have a qualifying condition and demonstrate that the condition impairs their ability to fulfill the community engagement requirement, differing from stakeholders’ expectations. Early on, and as with Nebraska’s early implementation, states believed they would be able to exclude people based on presence of a condition alone and several states planned to exclude all people with HIV.