Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements

https://www.kff.org/medicaid/medicaid-work-requirements-tracker-overview/ The 2025 reconciliation law, once called the “One Big Beautiful Bill,” signed by President Trump on July 4, 2025, requires 44 states (including DC) to condition Medicaid eligibility for adults in the Affordable Care Act (ACA) Medicaid expansion group and certain enrollees in 1115 waiver programs on meeting work requirements starting January 1, 2027. Currently, 41 states (including DC) have expanded their Medicaid programs under the ACA to nearly all adults with income up to 138% FPL ($21,597 for an individual in 2025). In June 2026, CMS released a list of states with 1115 waiver programs that include individuals who will be subject to work requirements. The list identifies waiver programs in three non-expansion states Georgia, Tennessee, and Wisconsin, as well as in five expansion states, Hawaii, Massachusetts, New York, Oregon, and Utah (Figure 1).