Medicaid work requirements take effect without a homelessness exemption, leaving some enrollees uncertain about coverage
The Trump administration finalized federal Medicaid work requirements that oblige enrollees to prove they are working, volunteering, or attending school to keep their coverage, with states required to begin checks by January 2027. The rules exempt specific groups — including people with disabilities, those over 64, pregnant individuals, and Native Americans — but do not include homelessness as a standalone exemption. Montana, Arkansas, and Nebraska have already begun implementing the requirements, with Montana set to begin removing non-compliant enrollees from coverage in October 2026.
Single source · Not corroborated
The Trump administration's Medicaid work requirements, finalized in the spring, set out a federal list of exemptions that states must follow. Several states — including Montana, Arizona, Kentucky, and Utah — had proposed policies that would have added homelessness to that list, but federal officials confirmed to KFF Health News that states cannot go beyond the federal exemptions. The Centers for Medicare and Medicaid Services declined to provide an on-the-record comment.
Homelessness in the United States increased 27% between 2013 and 2025, according to Department of Housing and Urban Development data, with approximately 746,000 people experiencing homelessness last year. In 2023, 55% of patients served by one of the nation's roughly 300 Health Care for the Homeless programs were enrolled in Medicaid, according to NPR's reporting. Jennifer Tolbert, deputy director of KFF's Program on Medicaid and the Uninsured, said the federal regulations were stricter than many states had anticipated, including those that supported work requirements. "It took everyone by surprise," Tolbert said.
CMS administrator Mehmet Oz described the regulations at a June press conference as a "path to prosperity," stating, "We need to get people to try to work." In June, 25 mostly Democratic-led states sued the Trump administration over the regulations, arguing the medical frailty standard would be too hard for enrollees to meet and for states to administer. The Congressional Budget Office projected the requirements would increase the number of uninsured people nationwide by more than 5 million by 2034.