From the JONAH Mental Health Task Force
This week, we’ll be sharing about some of the changes to Medicaid, particularly the work requirements that went into place in January of this year. The health system is complex so our goal is to make it as digestible as possible!
**Disclaimer: Wisconsin has NOT adopted this expansion yet BUT because this state receives federal waivers for its Medicaid program, we are still subject to some provisions under the new law, including the work requirements.**
The 2025 budget reconciliation bill (H.R.1), signed into lay on July 4, 2025, introduces new work requirements for certain Medicaid participants. These changes made continued Medicaid eligibility contingent on participation in work or other qualifying activities (listed below). The bill mandates that Medicaid members age 19-64 who are covered through the Affordable Care Act Medicaid Expansion or a 1115 demonstration waiver that provides minimum essential coverage MUST engage in employment, education, work program, or community service to maintain their Medicaid eligibility.
States are required to implement work requirements by January 1, 2027, though they may choose to do so sooner. The final legislation permits the Secretary to grant extensions until December 31, 2028 for states that demonstrate “good faith effort” to meet the requirements. As of July 2025, 41 states have adopted these work requirements for Medicaid.
Work requirements include: 80 hours per month of one or more of the following activities; employment, participation in a work program such as job training, enrollment in an educational program (at least part time), community service activities or a combination of these.
People who are exempt from this new requirement: Foster care youth under 26 years old, Individuals recognized as American Indians or Alaska Natives, caregivers of a dependent child under 13 years of age and under or a person who is disabled, veterans with a disability rated as total, medically frail individuals (people who are blind, disabled, have a substance use disorder, a disabling mental health disorder, a physical, intellectual, or developmental disability, or who have a serious or complex medical condition), individuals already meeting work requirements (usually under SNAP/TANF), people participating in a substance use disorder treatment program, incarcerated/recently incarcerated, pregnant/postpartum, or a person dealing with a short-term hardship.