The 2025 reconciliation law requires states to condition Medicaid eligibility for adults in the ACA Medicaid expansion group on meeting work requirements starting January 1, 2027; however, states have the option to implement requirements sooner through a state plan amendment (SPA) or through an approved 1115 waiver.
State Plan Amendments (SPAs)
Some states may choose to implement work requirements prior to the January 1, 2027 deadline through a state plan amendment. Nebraska is the first state to have announced that it will begin enforcing federal work requirements early through a state plan amendment, starting May 1, 2026.
1115 Waivers
States may also choose to implement work requirements early through an 1115 waiver. Since the start of the second Trump administration, several states have submitted waivers to implement work requirements, although some states may no longer be moving forward with proposed 1115 waivers due to the passage of federal work requirements or because they plan to implement early through a state plan amendment. While states are required to fully align with federal work requirements starting January 1, 2027, it is not clear how CMS will treat pending 1115 waivers that seek to implement early and deviate from federal requirements (specified in the law) prior to this deadline.
Currently, Georgia is the only state with a Medicaid work requirement waiver in place following litigation over the Biden administration’s attempt to stop it. CMS recently approved a temporary extension for Georgia’s waiver that added new exemptions from work requirements (see the table below for more details). Georgia’s waiver is now set to expire December 31, 2026, and the state will be required to come fully into compliance with new federal requirements starting January 1, 2027.
Early Implementation and Waiver Status
The map below identifies states that have indicated they will implement work requirements early through a state plan amendment as well as approved (Georgia) and pending work requirement waivers (submitted to CMS since the start of the second Trump administration). The table below the map provides more detailed state waiver information.
