States should first try to confirm automatically, using the past 12 months of claims data, whether a Medicaid enrollee is "medically frail" and exempt from new work requirements, federal officials say in new guidance. If that fails, a person may self-declare once, and states must re-verify every 12 months. The 33-page guidance from the Centers for Medicare & Medicaid Services was released in early September 2026, Disability Scoop reported on Sept. 18.
Who the work rules cover
Under the 2025 federal law, many adult Medicaid enrollees will have to show 80 hours a month of work, volunteering or school, and most states must start by the beginning of 2027. People with intellectual, developmental or physical disabilities can be exempt. But a CMS rule issued in June set a narrower test than many expected: the disability must significantly impair at least one activity of daily living.
What the guidance adds
CMS also offered an optional tiered model that ends in manual review for unclear cases. The Arc's Kim Musheno warned that claims records often don't show how a lifelong disability affects daily life. ANCOR and more than 70 other groups have joined a legal challenge to the rules.
Why this matters for providers and DSPs
Some people you support could lose Medicaid coverage over paperwork, even when their disability has not changed. If coverage lapses, agencies may keep providing services without being paid. It makes sense now to help families and coordinators watch for state notices, respond on time, and keep documentation of daily-living needs current.