Five governors asked the federal government on October 1 to delay the January 1, 2027 start of the Medicaid work requirement in the law President Trump signed in 2025. They are Tina Kotek of Oregon, Gavin Newsom of California, Janet Mills of Maine, Michelle Lujan Grisham of New Mexico and Abigail Spanberger of Virginia. No delay has been reported granted.
What the five governors asked HHS for
The letter went to Health and Human Services Secretary Robert F. Kennedy Jr., and Oregon’s governor announced it the same day in a statement from her office. Kotek led the group. The governors asked for more time before the new Medicaid requirements take effect, with fewer than 100 days left.
Becker’s Payer reported that they asked HHS to use its enforcement discretion and tie the compliance date to “demonstrated state readiness rather than a fixed calendar date.” They wrote that states “cannot implement the rules responsibly in the fewer than 100 days that remain.” They did not seek an indefinite postponement and proposed no replacement date, Healthcare Finance News reported.
Their complaint centers on a June 1 interim final rule from the Centers for Medicare & Medicaid Services. Becker’s reports the governors say it reversed guidance states had followed for a year, with a definition of medical frailty that goes beyond the statute, new compliance tasks that need form and system changes, and a verification order that checks work status before exemptions.
For adults 19 to 64 covered through Medicaid expansion, the January 1 date stands until HHS answers. Healthcare Dive’s October 15 update reports no HHS response to the letter and no delay. Whether a given adult must report hours or can claim an exemption is the question that follows.
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What the rule asks of enrollees
North Dakota’s Department of Health and Human Services says Medicaid expansion adults must work, volunteer, attend school or do job training for 80 hours a month beginning January 1, 2027. Delaware puts the same rule as earning at least $580 a month or completing 80 hours, for adults 19 to 64.
Delaware lists the exemptions: people under 26 who were in foster care, members of federally recognized tribes, parents or caregivers of a child 13 or younger, caregivers for a person with a disability, veterans with a 100 percent disability rating, people with serious health needs documented on a doctor’s form, people meeting SNAP or TANF work rules, people in treatment, and pregnant or postpartum women.
Delaware also says first-time applicants must show they met the requirement for at least one month before applying. Temporary hardship exemptions may apply after a recent hospital or nursing home stay, a declared emergency or high local unemployment. Both Delaware and North Dakota add that expansion enrollees renew every six months from 2027.
Under the CMS rule, as Healthcare Finance News describes it, states must verify compliance at application and at renewal. If they cannot, they must give the person 30 calendar days to prove compliance or an exemption. Failure can lead to denial or loss of coverage, so the burden of paperwork falls on the enrollee.
What happened when Nebraska went first
Nebraska started enforcing work requirements in May 2026. Healthcare Dive reports that about 560 new applicants were subject to them and roughly 470, or 84 percent, were denied for failing to provide verification information. Among people renewing under the rules, about 530 were disenrolled, 92 percent for not responding to verification requests.
Becker’s reports the governors point to two other figures. The Congressional Budget Office estimates that roughly half of expected coverage losses will come from paperwork and reporting failures. And more than 95 percent of people who lost coverage under Arkansas’s 2018 work requirement were later found to have met it or to qualify for an exemption.
The policy reaches roughly 21 million people who gained eligibility through the Affordable Care Act expansion, according to Healthcare Dive. Kotek said one-third of Oregon families, including seniors, disabled Oregonians and children, rely on Medicaid, and that the new rules “will lead to people losing their healthcare.”
Oregon is training eligibility workers, and Kotek’s office says warning letters are already arriving in mailboxes. Her announcement says Oregon wants people who are eligible to have a pathway to stay insured. It also says the Trump administration did not act on a May letter in which she and five other governors asked for a revised timeline.
Does HHS have room to say yes?
The Association of State and Territorial Health Officials, in its summary of the law, says states must implement work requirements by December 31, 2026, or earlier at state option. It adds that the HHS secretary may exempt states that show a good-faith effort until December 31, 2028.
CMS Administrator Dr. Mehmet Oz said the rule “helps Americans build skills and independence through work, education, job training, or community service.” CMS cited $200 million in grants and more than $600 million in committed support from private technology vendors for eligibility systems and outreach, Healthcare Finance News reported.
The governors’ states are also among the 25 states and the District of Columbia that sued over the rule on June 29, Becker’s reports. Healthcare Dive says a judge let the rule stay in effect while the case proceeds. The governors asked for the delay through HHS enforcement discretion, not through the courts.
The open question is what happens if HHS stays silent. The governors named no new date, so even a yes would need one. Until then, expansion adults in states without an exemption face January 1, and the next notice from a state agency is the one that says which category they are in.
Does the January 1 Medicaid work rule reach this household?
If HHS says no to the governors, expansion adults 19 to 64 face an 80-hour monthly rule and six-month renewals on January 1, and proof of an exemption has to reach the state on time. Nebraska’s early numbers show how often the paperwork, not the work, decides who is dropped.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, with a renewal document checklist, a renewal and reporting calendar and 51 state packs. Part 6, The New Medicaid Work Rule, and the 90-Day Rescue, walks through the rule household by household.
Get the Medicaid work-rule exemption guide and reporting calendar in one organizer →
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
David M. Keller is a finance writer based in Columbus, Ohio, covering personal finance and consumer-focused economic topics. He earned his degree in journalism from Ohio University and began his career reporting on local business and economic trends for a regional media outlet. Since then, he has contributed to a variety of online publications, focusing on clear, practical coverage of topics such as cost of living, debt, and everyday financial decision-making.
