On June 1st, 2026, the Center for Medicare and Medicaid Services (CMS) issued an Interim Final Rule, providing guidance to states to implement Medicaid work requirements, which will go into effect in Illinois on January 1, 2027.
Contradicting its previous communication to states and, in some instances the statutory language of H.R.1, the CMS rule appears very restrictive and likely to pose such burdens to patients, providers, and states that eligible individuals, including those with serious medical conditions, will inevitably lose their Medicaid coverage during the maze-like implementation.
The most significant guidance in the rule appears to indicate that adults who are considered “medically frail” i.e. have cancer, HIV, kidney disease, etc., or their physicians will eventually need to provide documentation to prove that they are sufficiently ill that they are not able to comply with the work reporting requirements; self-attestation and/or a diagnosis alone from a medical provider may not be sufficient.
Additionally, while caretakers for minor children and disabled adults can qualify for work reporting exemptions, even if they are not related to or reside with the individual they are caretaking for, CMS issued no guidance to states for how individuals can document that they qualify.
Medical and social service providers already overburdened with paperwork may need to individually review patient cases to determine whether they meet a threshold of medical frailty in order to be exempt from work reporting requirements.
As we expressed to CMS before the release of the rule, states are not equipped to implement this level of complexity on such a short timescale. States began implementation planning in communication with CMS since H.R.1 was signed into law on July 4, 2025, and unless granted an extension, there is now less than 6 months to implement this new, contradictory guidance which will require significant overhauls to state systems and processes.
The Protect Our Care Illinois (POCIL) Coalition is concerned that many individuals will unnecessarily lose coverage due to the lack of awareness of exemptions from work reporting requirements or due to burdensome documentation requirements. Studies have shown that work requirements do not lead to an increase in employment, and that the vast majority of individuals receiving Medicaid are already working full or part-time, studying, caretaking, disabled, or are retired.
As a coalition of nearly 100 organizations representing Medicaid recipients, medical and social service providers, advocates, and community members, we commit to working with IL’s Medicaid agency, Department of Healthcare and Family Services (HFS), to mitigate the harms of implementation of H.R.1 in Illinois and ensure that as many of our community members as possible maintain their Medicaid coverage.