On May 1, Nebraska will become the first state to start enforcing Medicaid work requirements laid out in H.R. 1, aka, the One Big Beautiful Bill Act signed into law on July 4, 2025. Here are five insights to keep in mind as that deadline approaches.
— Nebraska is ahead of the official deadline. The work requirement’s official start date is Jan. 1, 2027, for adults in the Affordable Care Act (ACA) Medicaid expansion group “and enrollees in partial expansion waiver programs (Georgia and Wisconsin),” KFF noted.
— Not every state will be impacted. The American Association of People with Disabilities (AAPD) noted that Alabama, Florida, Kansas, Mississippi, South Carolina, Tennessee, Texas and Wyoming “do not participate in Medicaid expansion programs. The federal government is still determining if and how these requirements will apply in Wisconsin and Georgia.”
— In Nebraska’s case, KFF said most adults who would be impacted by the new requirement “are working already or attending school.” KFF said in a January 2026 report that its analysis revealed “roughly 65% of Medicaid adults without dependent children in Nebraska who could be subject to work requirements work 80 or more hours per month or are attending school.”
The KFF report added that many of the remaining enrollees “will likely qualify for exemptions,” which include being caregivers for dependent children under age 13 or for people with disabilities; being pregnant or under postpartum care; being foster or former foster youths under age 26; being “medically frail” or disabled veterans; receiving Supplemental Security Income (SSI); or being incarcerated or released from incarceration in the last 90 days, among others.
— Gov. Jim Pillen was quoted by Nebraska Public Media in December 2025 as saying the state would not hire extra staff to track work requirements once they go into effect. Politico reported on April 14 that other state health departments are hiring “dozens if not hundreds of new employees to determine who should remain enrolled and who should be booted from the safety net health insurance program.”
— Organizations who advocate for people with disabilities have pushed back on the work requirement.
“AAPD strongly opposes Medicaid work requirements because they do not meaningfully increase employment and instead create unnecessary barriers to health care,” the organization said in a February announcement. “Even though many disabled people are supposed to be exempt, work reporting requirements can still be harmful. Many qualified individuals may not realize they meet the requirements for an exemption because states may use confusing definitions.” AAPD also expressed concern over “confusing forms and notices” and “difficulty proving an exemption.”
“There is no way to ‘target’ work requirements to a specific group of low-income Medicaid enrollees who supposedly lack incentive to work, because that group does not exist,” the Center for Medicare Advocacy said in a January 2025 report, “Medicaid Work Requirements Harm People with Disabilities.” The organization said at that time, “The vast majority of Medicaid-enrolled adults are already in the paid workforce or they have really good reasons to not be. “The likely consequence of any federal Medicaid work requirement is the exact opposite of what proponents claim they want to encourage. People with disabilities would be more likely to abandon employment due to the existential risk of losing their benefits.”
An August 2024 fact sheet from the U.S. Department of Health and Human Services said adding work requirements “would add substantial bureaucratic red tape to Medicaid, putting coverage — and health — at risk for millions of Americans. Only one state has ever fully implemented these policies, and nearly one in four adults subject to the policy lost their health coverage — including working people and people with serious health conditions — with no evidence of increased employment.”
