Nebraska launches Medicaid work requirements ahead of federal deadline
Nebraska became the first state in the nation to implement the Medicaid work and community engagement requirements enacted under the One Big Beautiful Bill Act (OBBBA), with new requirements taking effect May 1—months ahead of the federal statutory implementation deadline of Jan. 1, 2027.
The new rules apply to adults enrolled through Nebraska’s Medicaid expansion program and generally require affected beneficiaries to document at least 80 hours per month of work, education, job training or qualifying community engagement activities unless they qualify for an exemption.
Nebraska’s early rollout provides a preview of the significant administrative and operational challenges states face as they implement OBBBA’s mandatory work requirements nationwide. Among the significant implementation challenges will be designing and operationalizing exemption processes, such as for individuals with serious or complex conditions, developing accessible reporting and verification processes, and minimizing inappropriate coverage losses caused by administrative barriers or procedural errors.
The AMA continues to oppose Medicaid work requirements because of their potential to increase administrative burden and result in coverage losses. The AMA has developed a growing body of advocacy and implementation resources to support state and specialty medical associations and physicians navigating these changes, including analyses of the statutory framework (PDF) established by OBBBA, issue briefs on medical frailty exemptions (PDF) and optional short-term hardship exemptions (PDF), regular convenings with state and specialty medical associations, and ongoing technical assistance for state advocacy efforts. Additionally, in March, the AMA wrote (PDF) to the Centers for Medicare & Medicaid Services with recommendations for federal implementation of Medicaid work requirements.
As additional states move toward implementation ahead of the 2027 deadline, the AMA will continue working with Federation partners to advocate for policies that protect patient access to coverage and minimize disruptions in care.
