OBBBA Piece-by-Piece: Combining Hours and Income to Meet Work Requirements

Executive Summary

On June 1, 2026, the Centers for Medicare & Medicaid Services (CMS) released a major Interim Final Rule (IFR) implementing key Medicaid eligibility and enrollment provisions enacted under the so-called One Big Beautiful Bill Act (OBBBA), also known as H.R. 1. The rule established the federal framework for new Medicaid work requirements, which states must implement for individuals enrolled in the Medicaid Expansion group or certain 1115 waiver demonstrations beginning January 1, 2027. Our “Piece-by-Piece” series takes a closer look at specific elements of the IFR so state advocates know the right questions to ask, even as we recognize that ultimately the best harm mitigation strategy for work requirements is repeal.

This piece focuses on how states calculate qualifying activity hours.