Optional state hardship exemptions to Medicaid work requirements: New issue brief explores key opportunities for physician and medical association engagement
The One Big Beautiful Bill Act of 2025 (OBBBA) brings substantial changes to Medicaid, introducing mandatory work and community engagement requirements set to take effect Jan. 1, 2027.
OBBBA requires exemptions for certain individuals, such as those with serious or complex medical conditions, and permits—but does not mandate—states to grant “short-term hardship exemptions” to those facing acute challenges, including individuals who:
Receive inpatient hospital, nursing facility, or comparable high-acuity services
Must travel outside their community for extended periods to obtain medical care not locally available for themselves or a dependent
Reside in a county under a presidential emergency/disaster declaration
Live in a county with high unemployment rates
States' approaches to these optional exemptions will critically impact access to coverage for vulnerable populations. A new AMA issue brief (PDF) outlines key advocacy opportunities for physicians and medical associations to help ensure these short-term hardship exemptions are available, accessible, and clearly defined. Key priorities include:
Urge states to offer every optional exemption to help ensure patients do not lose coverage when they need care most
Help establish clinically grounded definitions for exemptions related to hospital or other facility stays or traveling for care
Advocate for streamlined and accessible exemption request processes
Promote use of existing data and self-attestation to reduce administrative burden on patients and physician practices
Advocate for fair exemption renewal and transition processes to avoid coverage disruptions
The AMA remains opposed to Medicaid work requirements as an eligibility criterion and advocates for flexibility, streamlined processes, robust monitoring and physician engagement in shaping exemptions to minimize disenrollments. As implementation approaches, the AMA supports state and specialty medical societies with technical assistance, federal updates and advocacy guidance. Please contact the AMA Advocacy Resource Center for more information.
