Nebraska will be the first state to pursue work requirements for its Medicaid expansion population, in compliance with the requirements of HR 1, enacted July 4, 2025.

Governor Jim Pillen, in a December 17 press conference with CMS Administrator Dr Mehmet Oz announced that the intention to implement requirements by May 1, 2026.

HR 1, enacted July 4, 2025, requires states that expanded Medicaid under the Affordable Care Act to implement community engagement requirements for that expansion population. The implementation deadline for states to add community engagement requirements to their program is December 31, 2026.

However, states can choose to implement the requirements early.

LeadingAge learned on a call with the Center for Medicaid and CHIP services (CMCS) that Nebraska will begin sending notifications to beneficiaries that will be subject to community engagement requirements in January 2026.

Most Medicaid beneficiaries that LeadingAge members serve are not subject to community engagement requirements, though there will be some staff and residents/clients who are. LeadingAge is engaging with CMS to ensure the clearest possible guidance to states on compliance and exemptions and welcome feedback from state partners and members as community engagement and other components of HR 1 are rolled out.