Millions at Risk of Losing Health Coverage as CMS Releases Medicaid Work Reporting Requirement Rule that Creates Confusion and Chaos for States

06.01.2026 / Statement

WASHINGTON, D.C. - An interim final rule released by the Centers for Medicare & Medicaid Services (CMS) today gives guidance to states to implement new burdensome work reporting requirements by January 2027 - setting the stage for mass disenrollment and coverage chaos for millions of Americans. In response, Families USA's executive director, Anthony Wright, issued the following statement:

"Americans are fed up with the cost and complexity of our health system, yet the President and Congress are making matters worse, doubling down on complicated and confusing rules and requirements to implement their health care cuts. This rule implements new bureaucratic barriers on millions of Americans, and many will fall off coverage as a result.

Most adults with Medicaid coverage are working, just at lower-income jobs without health benefits. Medicaid should be a safety-net for people between jobs or who otherwise need health coverage and care to be ready to rejoin the workforce. While reporting requirements have never been shown to encourage work, including in the failed experiments in Arkansas and Georgia, these new bureaucratic barriers will certainly cause millions of eligible and working Americans to be pushed off coverage because of paperwork.

Far from protecting the vulnerable, this guidance significantly raises the barrier for demonstrating medical frailty, meaning many patients in the middle of treatment will have the new hassle of proving their condition, over and over, with any mistake or gap being penalized by the loss of their health care and coverage. Through this rule, CMS is requiring duplicative documentation and prohibiting states from taking full advantage of consumer-friendly tools like self-attestation.

In March, the Urban Institute estimated between 5 and 10 million people would lose Medicaid coverage, depending on the choices states make in implementing the program. By making it more difficult for Medicaid beneficiaries to meet the medical frailty exemption there is a real danger that coverage losses will exceed the high-end estimates, especially given the extremely tight timeline of mere months to stand up and implement these costly and complex programs.

This rule sets in motion one of the most harmful coverage rollbacks in the program's history. We will work with state advocates and policymakers to push back on this timeline and this policy, and to mitigate and document the damage. Every American should recognize this is just another strike in the ongoing assault on our health system by the Trump administration and will cause millions to face more costs and confusion."