Since enactment of HR 1 in July 2025, states are grappling with implementing work reporting requirements for the Medicaid Expansion population. In an article published in Health Affairs on January 12, 2026, researchers from the the LeadingAge LTSS Center at UMASS Boston and George Washington University make a case for broad definitions when implementing Medicaid work reporting requirement exemptions. The law includes exemptions from the reporting requirement for a number of categories including individuals with 'serious or complex' conditions within the exemption for medical frailty. No standard definition exists for this exemption category.

For this brief, researchers used data from the 2022 Health and Retirement Study to review diagnosis data on individuals between 50 and 65 years old who would otherwise be subject to work reporting requirements. They hoped to better understand health characteristics and trends in this population. Researchers found multiple indications of chronic conditions that require ongoing monitoring or pharmaceutical intervention such as hypertension, diabetes, arthritis, depression, and others. Authors contend that inconsistent Medicaid coverage (resulting from coverage loss for failure to meet work reporting requirements) could lead to avoidable consequences due to poorly or unmanaged chronic conditions. For these reasons, the authors argue that states should consider broad definitions of medical frailty and look for ways to include medical history including diagnosis, pharmaceutical use, claims history, and others to qualify for exemption categories within work reporting requirements to protect older adults.

The brief can be accessed here.