December 10, 2025  – A new national survey of state Medicaid agencies shows that expansion states anticipate extensive administrative and financial hurdles as they prepare for the federal government’s upcoming Medicaid work requirements. The findings arrive as officials nationwide begin planning for the sweeping eligibility changes mandated under House Resolution 1, signed into law on July 4, 2025.

The policy, which applies to 43 Medicaid expansion states, requires non-disabled, childless adults between the ages of 19 and 64 to document at least 80 hours per month of employment, education, or job training to maintain health coverage. Federal rules state that the requirements must be fully in place by January 1, 2027, though states may choose to roll out the changes sooner.

According to the survey, Challenges with Implementing Work Requirements: Findings from a Survey of State Medicaid Programs, published by KFF, state officials are preparing for major strains on eligibility systems and staffing. Many agencies also warn that the required pace for implementation could lead to administrative errors or gaps in coverage.

One of the most significant concerns involves large-scale system changes. States reported they will need to adjust eligibility systems, build new data-sharing mechanisms, and upgrade or redesign infrastructure to track monthly work verification. These changes extend beyond the work requirements themselves, since H.R. 1 also mandates six-month eligibility redeterminations for expansion enrollees, restricts eligibility for certain lawfully present immigrants, and limits retroactive Medicaid coverage.

Officials also expressed concerns about the compressed implementation timeline. For many agencies, the window between rulemaking and rollout is narrower than what is typically needed for major policy changes. Another major barrier involves staffing and training. State Medicaid offices are already under pressure due to ongoing eligibility redeterminations following the end of the COVID-19 public health emergency. Several survey respondents said they expect to hire new staff or reassign current employees. Agencies also expect to conduct broad internal training, as the new rules will affect operations across multiple departments.

The survey further highlights financial concerns. System modernization, expanded communications, and additional staff hours are expected to increase administrative costs at a time when many state budgets are tightening. Some states warned that they may not have funding available to meet both federal requirements and their existing obligations.

While work requirements have long been a subject of political debate, the research suggests that the practical demands of implementing the policy may be as significant as the larger ideological disputes. The study concludes that states will need clear federal guidance and substantial lead time to minimize disruptions for the millions of adults whose coverage may be affected.

As the 2027 deadline approaches, states are bracing for a challenging transition, underscoring the scale of administrative change required to enforce the nation’s newest Medicaid eligibility rules.