On Monday, the Centers for Medicare & Medicaid Services (CMS) announced an interim final rule that requires certain adult Medicaid beneficiaries to meet an 80-hour work requirement. Experts have cautioned that 80-hour work requirements could compromise home care workers’ access to health care and lead to unmet needs for home care recipients. Under the Working […] The post CMS Announces 80-Hour Medicaid Work Requirement Amid Home Care Concerns appeared first on Home Health Care News.
On Monday, the Centers for Medicare & Medicaid Services (CMS) announced an interim final rule that requires certain adult Medicaid beneficiaries to meet an 80-hour work requirement. Experts have cautioned that 80-hour work requirements could compromise home care workers’ access to health care and lead to unmet needs for home care recipients.
Under the Working Families Tax Cut (WFTC) legislation, adults ages 19 through 64, with several exceptions, will be required to demonstrate work requirement activities such as employment, education, work programs or community services. The rule, which states are required to implement by Jan. 1, 2027, is designed to promote economic stability and independence, according to CMS.
“The Working Families Tax Cut legislation made historic changes to the Medicaid program, and CMS is working closely with states to put those changes into action,” CMS Administrator Dr. Mehmet Oz said in a statement. “This rule helps Americans build skills and independence through work, education, job training or community service, creating new opportunities for themselves and their families.”
Exceptions to the rule include people who are pregnant, postpartum, disabled, medically frail, American Indian or Alaska Native, parents or caregivers of young children and people with disabilities.
Some states, including Nebraska, have already implemented the work requirement, CMS said, with other states considering early implementation.
The rule includes a comment period. Comments on the rule must be received by July 31.
In its announcement, CMS cited a new study sponsored by the Department of Health and Human Services’ (HHS) Office of the Assistant Secretary for Planning and Evaluation. The study, also published on Monday, stated that the Working Families Tax Cut Act of 2025 could reduce poverty by 1.6 to 2.9 million people.
The study analyzed two scenarios. The first scenario included the entire Medicaid-eligible population and found that, in an average month, 5.8 million adults would be subject to the work requirement, and that if all these adults worked in the months they would otherwise have lost Medicaid, they would see an average net income increase of $16,780 per family. This scenario assumes that all eligible adults enroll and immediately secure adequate employment, and that states face no implementation challenges.
The second scenario accounted for the fact that around 85% of eligible adults actually enroll in Medicaid and did not assume that all those who did would easily find employment. With these considerations, the study found that 3.3 million adults would increase work to comply in an average month.
The second Trump administration has consistently sought to cut spending on government programs such as Medicaid. The work requirement rule is projected to save $391.9 billion in total Medicaid spending over 10 years through reduced enrollment. The rule is estimated to lead to 3.1 to 3.3 million fewer enrollees.
Potential impacts for home-based care
Home-based care stakeholders have warned that such work requirements could make it difficult for home care workers to access care, creating ripple effects throughout the home care industry and the broader health care system.
PHI has previously stated that, because approximately one-third of U.S. direct care workers rely on Medicaid for their own health coverage, 80-hour work requirements are likely to compromise access to coverage for many direct care workers and exacerbate workforce shortages. These effects could cause care gaps and lead to unmet needs among consumers of long-term services and supports.
“Destabilizing [the direct care] workforce will have ripple effects across the long-term services and supports system, the broader health care system, the labor market and state economies overall,” PHI wrote. “Because of the unique characteristics of their jobs, direct care workers will likely face heightened barriers to comply with or prove their compliance with the 80-hour requirements.”
According to PHI, home care workers often experience inconsistent schedules because their hours can fluctuate widely in response to client needs. They are also vulnerable to sudden employment gaps, such as if a client dies or is hospitalized. These workers are also more likely to struggle to consistently document their hours and are likely to have family caregiving responsibilities of their own.
The CMS Interim Final Rule implements the statutory requirements established by HR 1, or the One Big Beautiful Bill Act (OBBBA). Home-based care experts have predicted that OBBBA would have a slew of impacts for home-based care.
The Medicaid Home Care Chartbook 2026, an annual report co-authored by the National Alliance for Care at Home (the Alliance) and the Research Institute for Home Care (the Institute), predicted that OBBBA, including its work requirements, would decrease the number of individuals enrolled in Medicaid who receive home care services by 311,879.
The Center on Budget and Policy Priorities (CBPP), a nonpartisan research and policy institute, has stated that the OBBBA will take Medicaid away from millions of people, many of whom are actually Medicaid-eligible but will lose coverage due to reporting burdens or red tape.
Also according to CBPP, years of evidence across multiple programs show that work requirements do not increase employment but do take coverage away from eligible people, regardless of how well a state attempts to implement them.
The organization additionally stated that this problem would be exacerbated by a rushed rollout, lack of federal guidance and states’ limited capacity to handle such a massive change.
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