KFF: SSI applicants face Medicaid work-rule frailty test

Adults who are covered by Medicaid expansion while they wait for a decision on Supplemental Security Income could be dropped under the federal work requirements that start Jan. 1, 2027, unless their state counts them as medically frail.

That is the finding of a KFF issue brief first published July 29, 2026, and updated Oct. 14 to reflect newer guidance from the Centers for Medicare & Medicaid Services on how states can verify medical frailty.

What KFF found

• Many SSI applicants lean on expansion Medicaid. In 2023, 223,000 SSI applicants aged 19 to 64 had Medicaid while waiting for a decision, including more than 106,000 covered through the Affordable Care Act expansion.
• Expansion states depend on it most. In expansion states, 76% of new SSI enrollees in that age range had other Medicaid coverage first, including 42% through expansion. In non-expansion states the share was 33%.
• The wait is long. As of May 2026, initial disability decisions took 184 days on average, and about 862,000 people were waiting, counting SSI and Social Security disability together.
• Approval ends the risk. Once someone is approved for SSI, the work requirements no longer apply to them.

Where the frailty test comes in

The work rules require 80 hours a month of work, community service or similar activity in 44 states. Someone applying for SSI generally earns too little to work that much, so they would need the medical frailty exclusion. KFF says the June 2026 interim final rule uses a two-part definition that can be hard to document. Expansion enrollees will also be renewed every six months starting in 2027, often before Social Security has ruled.

The CMS guidance lays out an optional tiered approach that lets states identify frail enrollees from claims and other data before asking for paperwork. KFF says that may reduce but won't remove the risk. Self-attestation is allowed in 2027, but from 2028 it can be used only once per continuous enrollment period.

Why this matters for providers and DSPs

Young adults with developmental disabilities often apply for SSI at 18 or after leaving school, and some will be on expansion coverage during the wait. Supports coordinators and provider agencies can check which people they support have an SSI application pending while on expansion Medicaid, and help them gather doctors' records before renewal. Losing Medicaid during that gap could also interrupt HCBS planning and services that depend on it.