Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements: 1115-waivers

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)

States may choose to implement work requirements prior to the required January 1, 2027 implementation date through a state plan amendment. Nebraska is the first state to announce that it will begin enforcing federal work requirements early through a state plan amendment, starting May 1, 2026. Two other states are also planning to implement before January 2027–Montana on July 1, 2026 and Iowa on December 1, 2026. Arkansas has announced that it plans to launch a soft implementation of work requirements on July 1, 2026 but will not disenroll individuals prior to January 1, 2027.

1115 Waivers

Since the start of the second Trump administration, several states have submitted waivers to implement work requirements. However, states are unlikely to be moving forward with proposed 1115 waivers at this time due to the passage of federal work requirements. States that plan to implement federal work requirements early will do so through a state plan amendment. 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. Georgia’s waiver will expire December 31, 2026; the state is required to come into compliance with the new federal requirements effective January 1, 2027.

Early Implementation and Waiver Status

The map below identifies states that have indicated they will implement federal work requirements early through a state plan amendment and the one state (Georgia) that has implemented work requirements through an 1115 waiver.