Beware of Medicaid red tape: The Republican big spending bill is forcing states to deal with new requirements for users
Although Medicaid work requirements will not take effect until 2026, critics warn that they are unnecessary red tape that could threaten access.


The spending bill passed by Republicans in Congress, dubbed the One Big Beautiful Bill Act (OBBA), might not live up to its name for some receiving Medicaid.
The package imposes work requirements on Medicaid recipients aged 19 to 64. Those within this age group who are not eligible for an exemption will be required to work at least 80 hours per month to continue receiving Medicaid coverage. Additionally, to qualify for Medicaid, one must demonstrate compliance with the law for a period of one to three months before applying.
- Parents, guardians, or caretakers of dependent children or individuals with disabilities
- Pregnant individuals or those receiving postpartum coverage
- Foster youth or former foster youth under age 26
- Individuals who are medically frail
- Participants in a substance use disorder (SUD) treatment program
- Individuals meeting SNAP or TANF work requirements
- American Indians and Alaska Natives
- Disabled veterans
- Individuals incarcerated or released from incarceration within the past 90 days
- Individuals entitled to Medicare Part A or enrolled in Medicare Part B
Source: Kaiser Family Foundation
When do these requirements go into effect?
In a move that appears to be driven by electoral concerns, the work requirements for Medicaid will not take effect until December 2026—after the midterm elections. Democratic lawmakers have accused Republicans of delaying the implementation to avoid potential voter backlash that could affect the November 2026 ballot.
Republicans argue that the delayed timeline gives states more time to set up the systems needed to track whether Medicaid recipients are complying with the federally imposed work requirements. Still, the GOP may be rightly concerned about how changes to Medicaid eligibility could impact their electoral prospects, with millions expected to lose coverage in the coming years. The law requires states to reassess Medicaid eligibility at least twice a year. This means recipients must regularly submit documentation proving they meet the work requirements or qualify for an exemption. Critics argue that these rules create bureaucratic hurdles designed to limit access to the program. Missing a deadline could jeopardize someone’s health coverage.
For individuals with limited access to technology, the requirement to upload documents digitally could pose additional challenges, potentially leaving them without insurance.
The Center on Budget and Policy Priorities strongly criticized the work requirement approach, saying it “needlessly puts tens of millions of people at risk of losing health coverage by saddling them with red tape and one-size-fits-all requirements that can make it harder for people to work.” The organization also cited data showing that about two-thirds of Medicaid recipients are already employed, meaning the new rules simply add unnecessary paperwork for people who already qualify.
How many people are expected to lose coverage?
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In a letter to Congressional leaders, Congressional Budget Office Director Phillip L. Swagel wrote that the agency’s analysis—rejected by GOP leaders—estimates that 18.5 million people would be subject to the work requirements each year. By 2034, Medicaid coverage is projected to decline by 10.9 million due to policies included in the OBBA. The CBO had already forecast that around 5.1 million people would lose access to health insurance for reasons other than the ACA repeal. Altogether, in just under a decade, the CBO projects that roughly 16 million fewer people will have health insurance in the U.S. than do today.
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