CMS gives states six month hold harmless on Medicaid work rules

The Centers for Medicare and Medicaid Services told states on November 13 they may delay denying or terminating Medicaid coverage over the new work requirements until June 30, 2027, even though the requirements still take effect on January 1.

Why it matters: The delay removes the near term coverage cliff for expansion state enrollees who must show 80 hours a month of work, school or volunteering, and it pushes the first large scale disenrollment risk, which the Congressional Budget Office has linked to millions losing coverage by 2034, into mid 2027.

Data as of CMS letter to state Medicaid directors announced November 13, 2026, as reported by STAT and Nextgov and confirmed in the ACS CAN statement of the same day. The STAT report is subscription limited; every figure in this story is corroborated by at least one fully readable source.

The Trump administration announced on Friday, November 13 that states will get an additional six months before they must enforce the Medicaid work requirements created by the One Big Beautiful Bill Act. In a letter to state Medicaid directors, the Centers for Medicare and Medicaid Services offered an optional hold harmless transition period running through June 30, 2027. States that take it must still assess whether enrollees meet the work requirements from January 1, but they may not deny or terminate coverage solely for non compliance during the window, and CMS will not take enforcement action against them. States are asked to request the flexibility in their mitigation plans by December 11.

The requirements themselves are unchanged and still take effect on January 1. In states that expanded Medicaid under the Affordable Care Act, most working age adults without dependent children must show at least 80 hours a month of employment, school or volunteering, unless they are disabled, caring for young children or medically frail. States have been racing to rebuild eligibility systems to police the rules, and a federal judge recently rejected the federal government’s medical frailty definition and ruled that states had not been given adequate time or resources to overhaul their systems. Litigation brought by states challenging the implementation rule is continuing, and four states had asked a court to halt the January 1 deadline.

The practical effect is to move the first coverage losses from January to July 2027 at the earliest, and only in states that choose to enforce on schedule. The Congressional Budget Office has estimated the work requirements could leave 5.3 million additional people uninsured by 2034. Patient groups welcomed the pause while asking for more: the American Cancer Society Cancer Action Network called the six month delay encouraging and urged Congress to delay the requirements in all states for two years. For providers and Medicaid managed care plans, the announcement converts a January systems deadline into a phased 2027 rollout whose shape will now vary state by state.

CMS gives states six month hold harmless on Medicaid work rules

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