States Diverge on Adopting Medicaid Work Requirement Hardship Exceptions
In a weekly post, Georgetown University's Center for Children and Families examines how states are deciding whether to adopt short-term hardship exceptions to Medicaid work reporting requirements (WRRs), which offer expansion enrollees a temporary reprieve from proving compliance during events like high county unemployment, federally declared disasters, hospitalization, or travel for medical care. CMS's Interim Final Rule requires states that elect the exception to adopt all four hardship events, though states are not required to activate the high unemployment exception even where conditions qualify. Missouri reversed course in October 2026 and will not adopt any short-term exceptions; Colorado plans to adopt the exception in 2027 but not by "go live"; and Indiana and New Hampshire passed laws barring or restricting use of the exception. Nebraska, which launched WRRs on May 1, received CMS approval to adopt all four hardship events and is the first state to begin activating them, having put three exceptions in place across 14 counties for different months. States will formalize their choices through Medicaid State Plan Amendments submitted to CMS.