Former Medicaid Director KOL Recap; Work Requirements Expectations

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Former Medicaid Director KOL Recap; Work Requirements Expectations

USA | Healthcare Services EquityJuneResearch15, 2026

Former Medicaid Director KOL Recap; Work

Requirements Expectations

Last week, we hosted former VA Medicaid Director Cheryl Roberts to discuss

the recent final guidance on Medicaid work requirements. Key takes: 1) medical

frailty definitions are tighter, lowering exemption potential; 2) providers face

higher documentation burden and uncompensated care risk; 3) semiannual

eligibility is a key churn driver; and 4) acuity mix shifts likely pressure margins,

with expectation that disenrollment will track above CMS ests.

Work Requirements Policy Broadens Eligibility Paths, but Disenrollment Likely to Exceed CMS

Estimates. While the rule expands qualifying activities (i.e., gig work, education, community

engagement), Ms. Roberts believes outcomes will be driven by administrative execution rather than

policy design. Verification complexity and reporting burden are likely to limit compliance, particularly

in states with weaker data infrastructure. Our expert indicated CMS estimates likely understate

the impact, as they do not fully capture tighter medical frailty definitions and implementation

challenges.

Medical Frailty Definitions: More Restrictive, Function-Based Framework Raises Exemption

Hurdle. Our expert views the final rule as more restrictive than expected, with CMS shifting the

framework from diagnosis-based to a functional “ability to work” test layered on top of clinical

criteria. Conditions are no longer de facto exemptions (incl. cancer, MS), and states must now

build formal diagnosis lists, rely on a limited 12-month claims lookback, and independently validate

determinations rather than leaning on plan-level acuity flags.