How Medicaid MCOs Should Prepare for January 2027 Work Requirements and Narrow Medical Frailty Exemptions

CMS's interim final rule on Medicaid work requirements takes effect January 2027, requiring 80 hours monthly of qualifying activities from most non-pregnant working-age adults. The medical frailty exemption is narrower than expected—requiring both a serious condition and impairment in at least one activity of daily living—meaning many chronically ill enrollees may lose coverage. Avalere estimates 7.8 million could become uninsured by 2034, creating urgent operational and care continuity challenges for MCOs serving affected populations.

Managed Care

This is outside commentary from Avalere, not part of Medicaid Monitor's independently scored news coverage.

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