The Centers for Medicare & Medicaid Services (CMS) has issued an Interim Final Rule with Comment Period (CMS-2454-IFC) implementing new Medicaid work requirements enacted by Congress through the One Big Beautiful Bill Act (OBBBA), referred to by CMS as the Working Families Tax Cut legislation.

Beginning no later than January 1, 2027, states must require certain adult Medicaid applicants and beneficiaries to demonstrate at least 80 hours per month of qualifying work, education, job training, community service, or other approved activities as a condition of Medicaid eligibility.

While the rule is directed at Medicaid beneficiaries rather than providers, the policy could have significant implications for Florida’s home care workforce, Medicaid recipients, and providers participating in the state’s Medicaid program.

Although Florida did not expand Medicaid under the Affordable Care Act (ACA), the rule could still affect certain Medicaid populations, family caregivers, and direct care workers who rely on Medicaid coverage. In addition, broader coverage losses and workforce disruptions could have downstream effects on access to home- and community-based services nationwide.

• CMS Press Release
• CMS Fact Sheet

What Does the Rule Require?

The new requirement generally applies to certain Medicaid beneficiaries between the ages of 19 and 64 who:

• Are not pregnant
• Are not entitled to or enrolled in Medicare
• Receive coverage through the Medicaid expansion adult group or certain Section 1115 demonstration populations

Individuals subject to the requirement must demonstrate one of the following:

• At least 80 hours per month of employment
• Participation in approved work programs
• Community service activities
• Enrollment in an educational program at least half-time
• A combination of qualifying activities totaling 80 hours per month
• Monthly earnings equal to at least 80 times the federal minimum wage

States must verify compliance during eligibility determinations and renewals and may conduct additional periodic checks throughout the year.

Individuals who cannot demonstrate compliance or qualify for an exemption could lose Medicaid coverage.

Who is Exempt?

The rule contains numerous exemptions, including:

• Pregnant individuals and those receiving postpartum coverage
• Individuals who are disabled or medically frail
• American Indians and Alaska Natives
• Former foster youth
• Family caregivers of dependent children under age 14 or individuals with disabilities
• Individuals participating in qualifying substance use treatment programs
• Individuals already meeting work requirements through the Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families (TANF)
• Certain veterans
• Other populations identified by federal law

States may also provide short-term hardship exceptions in limited circumstances, such as hospitalization, natural disasters, high unemployment areas, or travel for specialized medical treatment.

Potential Impact on Home Care Providers

Although Florida did not expand Medicaid under the ACA, the rule could still affect portions of Florida’s Medicaid population and may create indirect impacts across the home care continuum.

Workforce Concerns

One of the most significant concerns raised by long-term care and home care stakeholders is the potential impact on the direct care workforce.

Many home health aides, personal care aides, and direct support professionals rely on Medicaid for their own health coverage. Industry organizations have warned that workers with fluctuating schedules may have difficulty documenting compliance with monthly work requirements, even when they are actively employed.

Home care employment often differs from traditional full-time jobs because:

• Hours can vary significantly based on patient needs
• Cases may end unexpectedly due to hospitalization, institutional placement, or death
• Workers may experience gaps between assignments
• Documentation and reporting requirements can be complex
• Many caregivers also provide unpaid care to family members

If eligible workers lose Medicaid coverage due to administrative or reporting challenges, providers could face additional recruitment and retention pressures in an already strained workforce environment.

Potential Effects on Medicaid Beneficiaries

Stakeholders have also expressed concern that eligible Medicaid beneficiaries could lose coverage because of reporting, verification, or administrative challenges associated with the new requirements.

Should coverage losses occur, providers could see:

• Increased disruptions in patient eligibility
• Delays in service authorization and continuity of care
• Greater administrative burdens associated with eligibility verification
• Increased uncompensated care risks
• Reduced access to home- and community-based services for certain populations

National estimates cited by CMS project Medicaid enrollment could decline by approximately 3.1 to 3.3 million individuals nationwide over the next decade as a result of the policy.

Florida’s Family Home Health Aide Program

One area Florida providers should closely monitor is the interaction between the new federal work requirements and Florida’s Family Home Health Aide (FHHA) for Medically Fragile Children program.

The FHHA program was specifically designed to allow qualifying family caregivers to receive training and become employed by licensed providers to care for medically fragile children at home.

Because family caregivers participating in the FHHA program are employed and earning wages, many may satisfy work requirement obligations through their employment activities. However, implementation details will ultimately depend on future federal and state guidance.

Because family caregivers participating in the FHHA program are employed and earning wages, many may satisfy work requirement obligations through their employment activities. However, implementation details and any applicable exemptions will depend on future federal and state guidance.

Next Steps

States must implement the new work requirement framework by January 1, 2027, unless they elect to do so earlier.

CMS is currently accepting public comments on the Interim Final Rule through July 31, 2026. HCAF is actively reviewing the rule and its potential implications for Florida’s home care provider community and intends to submit comments to CMS before the deadline.

To help inform our comments, HCAF is seeking feedback from providers regarding the potential operational, workforce, access-to-care, and administrative impacts of the new requirements. Providers are encouraged to share their observations, concerns, and recommendations with HCAF no later than July 17, 2026, to allow sufficient time for consideration and incorporation into our submission. Please send feedback to Kyle Simon, Senior Director of Policy, Advocacy & Communications, at ksimon@homecarefla.org.

Additional analysis is underway as HCAF evaluates the potential operational, workforce, and access-to-care implications for Florida’s home care provider community. As federal and state implementation details continue to emerge, HCAF will share additional information, guidance, and advocacy updates with members.

HCAF will continue monitoring developments, analyzing potential impacts, and advocating on behalf of Florida’s home care provider community throughout the implementation process.