As states prepare to implement new Medicaid work reporting requirements, the Centers for Medicare and Medicaid Services (CMS) is providing resources and instruction for guidance.

A recent CMS-hosted webinar, for instance, focused on the application of medical frailty exemptions outlined optional steps states can take to verify medical frailty for exemption from work requirements, providing a three-tiered option as an available framework for establishing exemption. Agency staff also shared potential data sources and medical codes for consideration, as well as examples in an effort to help states understand their options and obligations.

Slides from the presentation, distributed to states on September 8, 2026, provide little new information. Examples show obvious examples of exemption eligibility within tiers and do not address the harder-to-determine grey areas. Additionally, the guidance provides no information to states about how claims data can actually demonstrate an individual’s ability to work, as was required by the interim final rule.

During the call, CMS outlined optional steps states can take to verify medical frailty for exemption from work requirements, providing a three-tiered option as an available framework for establishing exemption. CMS also shared potential data sources and medical codes for consideration, as well as examples in an effort to help states understand their options and obligations.

Work reporting requirements are applicable to the Medicaid Expansion population, those between 19 and 64, with income slightly over legacy eligibility requirements. The compliance deadline for states to implement the policy is January 1, 2027.

With the January 1 compliance date less than six months away, states are already communicating with enrollees to whom the new requirements apply. Pivoting to a new policy practice on medical frailty exemptions would add complexity to an already capacity-limited policy and timing challenge.

States opting to accept self-declaration of exemption eligibility could find limited utility in the CMS presentation, with longer timelines to finalize exemption criteria prior to a concrete ex parte process by 2028.