---
type: source
title: "OBBBA Medicaid Work Requirements: 7 States With Pending Waivers, December 2026 Federal Mandate Deadline"
author: "Ballotpedia News / Georgetown CCF / NASHP / AMA"
url: https://news.ballotpedia.org/2026/01/23/mandatory-medicaid-work-requirements-are-coming-what-do-they-look-like-now/
date: 2026-01-23
domain: health
secondary_domains: []
format: news
status: processed
priority: medium
tags: [obbba, medicaid, work-requirements, vbc, belief-3, structural-misalignment, enrollment-stability, vbc-attractor-state, state-policy]
---

## Content

As of January 23, 2026, implementation progress on OBBBA's Medicaid work requirements:

**Federal mandate:** All states must implement work requirements by **December 31, 2026**. States that need more time can request HHS extension to 2028.

**Work requirement terms:** Ages 19-64 must work or participate in qualifying activities ≥80 hours/month to maintain eligibility. Exemptions: parents of children ≤13, medically frail, and others.

**State-level progress (as of Jan 2026):**
- **7 states with pending Section 1115 waivers:** Arizona, Arkansas, Iowa, Montana, Ohio, South Carolina, Utah. All still pending at CMS as of January 23.
- **Nebraska:** Implementing via state plan amendment (without waiver), ahead of federal mandate.
- **Early implementation states** can proceed immediately; others have until December 31, 2026, or 2028 with extension.

**Federal funding:** $200M for HHS implementation, $200M for states in FY2026. Required state outreach to beneficiaries: June–August 2026.

**Scale context:** CBO projected 5.3M people losing Medicaid coverage; implementation timeline confirms this affects 2027 coverage losses (January 1, 2027 mandatory start date was confirmed in Session 8 analysis).

Supporting sources: Georgetown Center for Children and Families (CCF) analysis of how OBBBA changed the waiver landscape (July 2025); NASHP state-level policy update; AMA changes to Medicaid and ACA overview; King & Spalding detailed healthcare industry review.

## Agent Notes

**Why this matters:** The work requirements implementation timeline is on track for the disruption to VBC enrollment stability that Session 8 identified as the primary mechanism by which OBBBA threatens the attractor state thesis. The December 2026 deadline means observable effects will begin January 2027. The 7-state waiver pipeline shows early-mover states are actively pursuing implementation — this is not administrative stall.

**What surprised me:** The Nebraska precedent — implementing without a waiver via state plan amendment. This suggests states don't even need CMS waiver approval to proceed; they can use a state plan amendment if the OBBBA statutory requirement is self-executing. This accelerates the timeline.

**What I expected but didn't find:** Any substantial state-level resistance or legal challenges blocking implementation. The OBBBA work requirements appear to be proceeding through regulatory channels without the court injunctions that blocked Obama-era waiver work requirements. The political landscape has shifted.

**KB connections:**
- Directly extends Session 8 finding on OBBBA + VBC enrollment stability (Belief 3)
- The December 2026 deadline means VBC plan enrollment disruption begins Q1 2027 — this is the window to watch for BALANCE model implementation being tested against enrollment fragmentation
- Connects to OBBBA's 5.3M coverage loss (CBO) — these are disproportionately working-age adults with chronic conditions, exactly the population VBC risk-bearing plans need for prevention economics
- The June-August 2026 required state outreach is a potential signal point: if states fail to effectively notify beneficiaries, coverage loss will exceed CBO estimates

**Extraction hints:**
- This is an implementation status update for the Session 8 OBBBA claim — update the existing claim with: "seven states have pending waivers, Nebraska proceeding without waiver, December 2026 mandatory deadline confirmed"
- Primary new claim: "OBBBA Medicaid work requirements are on track for December 2026 implementation with 7 states seeking early waivers and Nebraska proceeding via state plan amendment — enrollment disruption for VBC prevention economics begins Q1 2027"
- Don't create a new claim; update the existing OBBBA source with this timeline confirmation

**Context:** Ballotpedia News provides nonpartisan tracking of state/federal policy; Georgetown CCF is the leading Medicaid policy research center. AMA and NASHP provide clinical/public health perspective. Cross-source consistency confirms the timeline.

## Curator Notes
PRIMARY CONNECTION: Belief 3 "structural misalignment" + OBBBA enrollment stability mechanism from Session 8
WHY ARCHIVED: Implementation update confirming that the December 2026 OBBBA enrollment disruption is on track — the KB needs to update confidence from "projected" to "in-progress"
EXTRACTION HINT: Update the existing OBBBA claim rather than creating a new one; the observation period is Q1 2027 when work requirements take full effect
