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An Update on Medicaid Work Requirements: What the Interim Final Rule Means for Pennsylvania

On June 1, 2026, the Centers for Medicare & Medicaid Services (CMS) released an interim final rule containing new details about the Medicaid work requirements coming to all states, including Pennsylvania. These work requirements are just one part of a much larger set of Medicaid cuts and changes under the 2025 budget reconciliation bill (also known as H.R. 1), signed into law on July 4, 2025. Among its many provisions, the law requires people in the Medicaid Expansion group to prove they are working in order to keep their coverage.  

This article discusses what you need to know about the new rule released earlier this month, as well as what we currently know about Pennsylvania's plan to implement the new work requirements once they go into effect next year. 

 

What's Changing

Starting January 1, 2027, some adults on Medicaid (also called Medical Assistance) will need to meet new "work and community engagement" requirements to keep their coverage. This applies to adults ages 19–64 who do not have a dependent child under 14. You will need to show that you meet the requirement when you apply for or renew your Medicaid coverage, and report it to the PA Department of Human Services (DHS) in order to maintain eligibility.

 

How You Can Meet It

You will need to show 80 hours per month of qualifying activities. The good news is that this activity does not necessarily need to be a traditional job, and you can combine activities to get to the 8- hours per month. Qualifying activities include:

  • Working
  • Volunteering or community service
  • A job training program
  • School, at least part-time
     

You can also meet the work requirement by earning at least $580 a month. Seasonal workers will have a separate calculation. Because the hours can come from more than one activity, many people already meet this through their daily lives.
 

Who's Exempt

Many people won't have to do anything new. Exemptions include:

  • People who are pregnant or recently pregnant
  • Parents and caregivers
  • Former foster youth
  • People in treatment for alcohol or substance use
  • Veterans with a 100% disability rating
  • People incarcerated within the last 90 days
     

There is also an exemption for people who are "medically frail" or have serious health conditions, though the  final rule made this exemption harder to qualify for than many initially expected. Under the rule, it is not enough to simply have a serious condition, disability, substance use disorder, or mental health condition; you must also show that the condition "significantly limits" your ability to meet the work requirement. This means some people with serious health conditions will need to actively prove they qualify, rather than being exempt from the work requirements automatically based on their health condition(s). States will need to verify not just that someone has a qualifying condition, but also that their condition limits their ability to work.

NOTE: Pennsylvania is still working out details of its plan to implement the new work requirements framework following CMS' interim final rule released earlier this month. If you have a disability or serious health condition, stay tuned for more details. PHLP will share additional information as we learn more. 

 

Self-Attestation Will Go Away in 2028

How you prove you meet the requirement or qualify for an exemption will change over time as the new framework is implemented. 

  • In 2027, if DHS can't confirm that you meet the requirement or qualify for an excemption using data it already has (called ex parte review), you will be able to self-attest (state for yourself) that you meet the requirement or qualify for an exemption.
  • Starting in 2028, self-attestation goes away. You will need to provide reasonably available documentation to prove that you meet the work requirements or that you qualify for an exemption. The rule notes that if documentation truly doesn't exist — e.g., if you're informally caring for an aging parent — the state cannot deny or end your coverage just because you can't produce a document, but you may need to provide other information to stay covered.

 

What to Do Right Now

The most important step you can take right now is to watch for mail, calls, and texts from PA DHS. Outreach to those impacted by the new rule begins by September 2026, and your benefits won't change without notice.

To stay ready:

  • Update your address in COMPASS at dhs.pa.gov/COMPASS or the myCOMPASS PA app
  • Update your address with the U.S. Postal Service at USPS.com/move

  • Sign up for texts and email alerts from DHS at dhs.pa.gov/text 

  • Open any mail from PA DHS right away

This article provides general legal information, not legal advice. Every situation is different. If you have questions about how the law applies to you, please call PHLP's Helpline at 1-800-274-3258 or email staff@phlp.org.