On June 3, 2026, the Centers for Medicare and Medicaid Services (CMS) posted Interim Final Rules for the Medicaid Program with respect to the Community Engagement Requirement for Certain Individuals. The interim final rules define Medicaid work requirements. See 2026-11094.pdf
These rules include definitions of “work” requirements that include community activities that expand beyond work as employees. The regulations note that “If the unemployment insurance job search activities are conducted in a manner that is consistent with the requirements of the work program, then they will count towards meeting the community engagement requirement. We encourage States to work with their State workforce agencies to establish data sharing and align job search activities and requirements.”
The expanded Medicaid coverage in recent years has increased the number of individuals who may qualify for Medicaid and Unemployment Compensation. The addition of the work program for some Medicaid recipients increases the number of individuals who may be obligated to seek work with different definitions under both programs as a condition of eligibility. States should be careful to apply the unique definitions for each of these programs while recognizing that work search activities for unemployment insurance in some cases may be counted to meet the work requirements for Medicaid. Note, however, that activities to be eligible for Medicaid are not substitutes for the requirements of UI that claimants be able to work, available to work and actively seeking work each week claimed as a condition of being paid unemployment compensation for such week. The Medicaid definition requires 80 hours per month with no specific weekly requirement and includes activities that would not be acceptable as work search for UI purposes.
This interim final rule with comment period (IFC) interprets and implements the community engagement requirement in Medicaid under section 1902(xx) of the Social Security Act. States are required to implement the new requirement no later than January 1, 2027.
Comment date: To be assured consideration, comments must be received at one of the addresses provided below, by July 31, 2026.
UWC is reviewing the CMS rules for impact on UI work search requirements and RESEA plans. It should be clear that “work” activities as defined to meet Medicaid requirements are not synonymous with the work search requirements for UI.
