CMS Still Reviewing Which 1115 Demos Will Be Subject To Work Reqs

By Dorothy Mills-Gregg / December 10, 2025

Medicaid expansion adults or those enrolled in similar programs created via 1115 waivers must meet work reporting requirements by Jan. 1, 2027, but CMS says in a newly released guidance it hasn’t decided which states with expansion-like 1115 waivers will be subject to the new requirements.

At issue are the forthcoming national Medicaid work requirements created by the GOP megabill, One Big Beautiful Bill Act. These new reporting requirements will apply to two groups of adults aged 19 to 64, either those enrolled in Medicaid expansion or in a similar program established via an 1115 waiver.

Medicaid beneficiary advocates assumed this second group was mostly created to apply the requirements to Wisconsin and Georgia, which each have an 1115 waiver to partially expand Medicaid and cover adults up to 100% of the federal poverty level -- though the Peach State has already tied enrollment in its program to work requirements.

But the Trump administration says in a Monday (Dec. 9) guidance, “CMS continues to evaluate which existing state section 1115 demonstration populations meet the definition of an ‘applicable individual.’”

Georgetown University’s Center for Children and Families Executive Director Joan Alker said she expected CMS to know by now which beneficiaries enrolled in 1115 waiver demonstrations would have to meet the new work requirements.

“[T]he surprising part is that CMS did not clarify which states this provision will apply to -- obviously the 41 states and DC that have taken the match, [Georgia], and presumably Wisconsin,” Alker told Inside Health Policy in an email. “But this does not seem like a hard question and it is concerning that they could not answer the question -- a few of the remaining states may in some cases cover a limited group of parents beyond the mandatory parents they have to cover.”

CMS has been gradually releasing details on how the administration expects states to meet the forthcoming Medicaid work requirements. Its lengthy guidance from Nov. 18 explained the permanent and hardship exemptions states will have to follow while implementing the OBBBA’s national Medicaid work requirements.