Tag: Medi-Cal Work Requirements

Understanding the New Medicaid Work Requirements Interim Final Rule

By Julie Schurman, Esq., Director of Public Policy, The Arc & UCP California Collaboration

The Centers for Medicare & Medicaid Services (CMS) has released an Interim Final Rule that explains how states must implement the new Medicaid work requirements created by H.R. 1, the One Big Beautiful Bill Act (OBBBA). Beginning January 1, 2027, many adults ages 19 to 64 who receive Medi-Cal through the Medicaid expansion program will be required to work, volunteer, attend school, or participate in other qualifying activities for at least 80 hours each month to keep their health coverage. Unlike a traditional rulemaking process, this rule takes effect before CMS reviews public feedback, although the public still has an opportunity to comment through July 31, 2026.

While many people with disabilities are exempt from these requirements, the new rule significantly narrows how those exemptions are applied. People who receive Medi-Cal through SSI, what is known as the “traditional Medicaid eligibility pathway” are not subject to the work requirements. However, many Californians with disabilities receive Medi-Cal through the Medicaid expansion program because they qualify based on income rather than SSI eligibility. These individuals may need to qualify for an exemption as “medically frail.” The final rule makes that much harder by requiring states to determine not only whether someone has a physical, intellectual, developmental, mental health, or other serious medical condition, but also whether that condition substantially limits their ability to meet the 80-hour monthly work requirement. In many cases, a diagnosis alone will no longer be enough to qualify for an exemption.

This approach creates significant barriers for people with disabilities. Many people want to work but face discrimination, inaccessible workplaces, inconsistent part-time schedules, or a lack of reasonable accommodations. Others experience periods when their health worsens or require surgery and rehabilitation, making it impossible to consistently meet an hourly work threshold. Ironically, access to healthcare is often what enables people with disabilities to work in the first place. Requiring people to prove they cannot work in order to keep their health coverage risks discouraging employment rather than supporting it. For many Californians with disabilities, Medi-Cal is also the only way to access the Home and Community-Based Services that make independent living and employment possible.

There is still time to make your voice heard. CMS is accepting public comments on the Interim Final Rule through July 31, 2026 at 11:59 p.m. ET., and public input can influence future changes to the rule. The Arc of the United States has developed resources explaining the issues and providing guidance on how to write and submit comments. Click HERE to view tips for writing and submitting public comment by the Autistic Self Advocacy Network. You can submit comments through the Federal Register.

The rule is also facing a significant legal challenge. A coalition of 25 states and the District of Columbia has filed a lawsuit arguing that CMS unlawfully narrowed the “medically frail” exemption in ways that could cause people with disabilities and other individuals with serious health conditions to lose Medicaid coverage. The lawsuit asks the court to block these provisions before they take effect, highlighting the serious concerns many states share about the impact of the final rule on people with disabilities.

Proposed Budget Changes Could Affect Access to State-Funded Medi-Cal Coverage

By Julie Schurman, Director of Public Policy, The Arc & UCP California Collaboration

In January, Governor Gavin Newsom released a proposed state budget that includes changes to Medi-Cal eligibility rules for certain Californians. The proposal would impose work requirements and more frequent eligibility checks, every six months, on individuals enrolled in the state-only funded Medi-Cal program.

State-only funded Medi-Cal provides health coverage for Californians who are NOT eligible for federally funded Medicaid (California’s Medi-Cal). This includes immigrants with unsatisfactory immigrant status.

Under the proposal, individuals enrolled in this program would be required to demonstrate work activity and renew their eligibility every six months in order to maintain coverage.

Why Work Requirements Are Problematic for Everyone

Research consistently shows that work requirements in safety net programs do not significantly increase employment. Instead, they create administrative barriers that cause people to lose coverage even when they remain eligible.

The proposal would also require Medi-Cal enrollees to renew their eligibility every six months. Frequent renewals make it harder for people to stay enrolled and increase the workload for already stretched county eligibility offices.

For immigrants without satisfactory immigration status, these requirements create an additional and unique barrier. To verify work activity, employers must certify employment. Many employers are unlikely to provide that certification. As a result, the requirement effectively creates an impossible standard for many people to meet.

Privacy and Safety Concerns

Requiring additional documentation related to employment also raises serious concerns about privacy and safety. Recent federal guidance allows certain information collected through public programs to be shared with federal immigration authorities.

Advocates warn that collecting employment and work authorization information could expose families to additional risks and discourage people from seeking health care altogether.

These concerns extend beyond immigrants without satisfactory immigration status. Fear of enforcement actions can deter immigrants who are legally allowed to be in the U.S. and even U.S. citizens in mixed status families from accessing health services.

Impact on People with Disabilities

Immigrants with disabilities and their families could face additional challenges under this proposal.

While some individuals with medical conditions can be exempt from work requirements under certain circumstances, people must report their disability status to qualify for those exemptions. Many individuals may hesitate to share sensitive information with government agencies due to privacy concerns and fears about immigration enforcement.

This creates another barrier to care for a population that already faces significant challenges accessing services.

A Broad Coalition Is Speaking Out

More than 70 organizations have signed a letter urging the Legislature to reject this proposal. The coalition includes health providers, immigrant rights groups, disability advocates, and civil rights organizations.

The Arc of California and El Arc de California joined this effort alongside organizations such as Western Center on Law and Poverty, Disability Rights California, Health Access California, and the California Foundation for Independent Living Centers.

Together, these groups warn that the proposal would increase administrative costs, reduce access to care, and harm immigrant communities without improving employment outcomes.

Medi-Cal & CalFresh Work Requirements for People with Disabilities Explained

Recent passage of the federal budget law known as H.R.1 includes new “community engagement” or work requirements for certain people who receive CalFresh food assistance and Medi-Cal health coverage. These changes have raised understandable concern across California’s disability community.

In the latest Arc Beacon, The Arc of California Executive Director Jordan Lindsey explains what these new rules mean, when they are expected to take effect, and—most importantly—who is excluded.

Here are a few key points:

      • CalFresh work requirements are expected to begin June 1, 2026
      • Medi-Cal work requirements are expected to begin January 1, 2027
      • Many people with disabilities are exempt, including those receiving SSI, SSDI, regional center services, IHSS, Medicare/Medi-Cal, and others
      • Family caregivers may also qualify for exclusions
      • California is currently building systems to automatically identify and protect eligible individuals, though some people may need to request exemptions when implementation begins

This Arc Beacon update provides clear, factual guidance to help families understand what’s changing—and what protections remain firmly in place.

Click HERE to Watch the Arc Beacon update.

The Arc of California will continue monitoring implementation closely and sharing updates as more details become available. Our commitment remains the same: protecting access to essential services and ensuring no one is harmed by administrative barriers.

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