On June 1, CMS released an interim final rule entitled "Medicaid Program; Community Engagement Requirement for Certain Individuals," implementing work requirements mandated by HR 1 — commonly known as the One Big Beautiful Bill or the Working Families Tax Cut Act.

The rule requires Medicaid expansion enrollees to meet community engagement requirements as a condition of eligibility. States must have these programs operational by January 1, 2027. The rule provides guidance on exemption criteria, redetermination timing, and related provisions from the legislation.

Additional provisions include a moratorium on enforcement of the 2024 Eligibility and Enrollment Rule and changes allowing increased frequency of eligibility determinations for the Medicaid expansion population — adults ages 19–64 not enrolled through other pathways such as waivers or nursing home eligibility.

Both work requirements and more frequent Medicaid renewals represent new burdens for this population. LeadingAge has published a detailed analysis of the rule and implications for LeadingAge members seeking a deeper review.