New Medicaid requirement leaves recipients worried and states confused

DeAnna Brandon, a 48-year-old blood cancer survivor, cherishes the simple moments of splashing in a kiddie pool with her grandchildren.
Yet, these precious afternoons are overshadowed by a looming fear: new Medicaid work requirements, set to begin next year, could jeopardize her health coverage and the life-saving treatment keeping her multiple myeloma in remission.
Brandon, who lives in Rockwell, North Carolina, had anticipated qualifying for a medical frailty exemption. But new guidance introduced last week by the Trump administration has cast doubt on her eligibility.
The interim final rule, released by the Centers for Medicare and Medicaid Services, stipulates that her extreme exhaustion and memory challenges, direct consequences of her treatment, may no longer be sufficient to bypass the work mandates. She will now be required to attest, and subsequently prove, that these symptoms “significantly impair” her ability to fulfill the requirements.
Should her case not be accepted by the government, Brandon faces the prospect of losing her coverage and the crucial twice-monthly maintenance chemotherapy.
“Working is outside of the realm of possibility for me,” she said. “I was always a push-through-it person — you know, ‘Oh, you’re tired. Push through.’ It’s hard to explain to people you can’t push through it.”
Health analysts have voiced significant alarm over the Republican Trump administration’s latest guidance, which deviates from states’ expectations. Experts warn that the changes will place more Americans at risk of losing their health insurance and force states into a frantic scramble to implement the new rules on schedule.
“This will mean more paperwork for Medicaid patients — specifically for the sickest Medicaid patients,” commented Adrianna McIntyre, a professor at Harvard University’s school of public health. She added that this “is going to push in the direction of more people needlessly losing coverage.”
The new Medicaid restrictions, which Democrats have criticized, were part of Trump’s big tax and policy law in 2025. The change affects those covered through an expansion in most states that gave more lower-income people access to the government’s safety net healthcare program.
Expansion enrollees age 19 to 64 will have to show that they work or do community service at least 80 hours a month or are in school at least half the time. There are exceptions for those considered medically frail or in addiction treatment programs, among others.
Last week’s announcement from CMS caught states off guard with a new definition of medical frailty. The law had said medically frail people include those who have substance use disorders, disabilities or serious medical conditions. But the CMS rule went further, saying someone’s condition must “significantly impair” their ability to work, volunteer or attend school at the rates required in the law for them to be granted an exemption.
In 2027 and once in 2028, the patient can attest that they meet this definition. But when they try to renew coverage in 2028, they’ll need to prove it.
Advocates said it is unclear what kind of documentation could prove that point. They said doctor notes may be required — something some providers don’t feel comfortable writing. Medicaid enrollees fighting disease may carry the bureaucratic burden.
Brandon, who tried to prove she couldn’t work to access disability benefits during her active cancer treatment and failed, said she’s worried about the hoops she and other patients may need to jump through.
