About the Course
Introduction
This CLE webinar will examine the One Big Beautiful Bill Act's (OBBBA) Medicaid work requirements and the recently issued CMS Interim Final Rule (IFR) clarifying key policy points and administrative obligations for state programs. The panel will discuss qualifying community engagement activities and exemptions, address questions left open by the IFR, and offer best practices for compliance.
Description
CMS recently issued an IFR to clarify the new Medicaid work requirements (the community engagement requirements) established by OBBBA to be implemented by states for covered individuals ages 19-64 by Jan. 1, 2027.
Under OBBBA, covered individuals must complete at least 80 hours per month of qualifying community engagement activities to be verified by the state unless they are eligible for a statutory exemption. Qualifying community engagement activities include working at least 80 hours, performing at least 80 hours of community service, participating in a work program for at least 80 hours, being enrolled in an educational program for at least half of the time, or some combination of these amounting to at least 80 hours. Alternatively, covered individuals may meet this requirement by demonstrating a monthly income of the national minimum wage multiplied by 80 hours. OBBBA requires that covered individuals document their participation in the work requirements before enrolling in Medicaid or during eligibility renewals.
As also required by OBBBA, CMS issued a recent IFR clarifying policy and laying out the framework and requirements for states to follow when designing their programs. The IFR: (1) clarifies the standards for qualifying for the medical frailty exemption; (2) explains how Medicaid managed care organizations (MCOs) may assist states with implementation; and (3) places substantial new administrative and operational obligations on the states when implementing their programs.
Listen as our authoritative panel examines OBBBA's Medicaid work requirements and the recent CMS IFR clarifying key policy points and administrative requirements for state programs. The panel will also look at questions left remaining after the IFR and discuss the potential impact on Medicaid enrollees and the states.
Presented By
Ms. Evans’ legal practice is focused on fraud and abuse, Medicare and Medicaid reimbursement, and regulatory compliance. She advises large health systems, emerging companies in healthcare and entities focused on behavioral health serving commercial and safety net patients. Ms. Evans served as Deputy Director of the Colorado Department of Health Care Policy and Financing, the single state agency responsible for administering Medicaid and the CHP+ programs. At Colorado Medicaid she was responsible for Administration & Operations including audit, program integrity, provider enrollment, claims payment and information technology. Ms. Evans previously served as Legislative Director and Legislative Assistant for Health Care in the U.S. Senate and U.S. House of Representatives. She is a Member of the Board of Directors of the American Health Law Association.
Managed care organizations trust Mr. Malone to help them understand and navigate their most difficult legal, compliance, and strategic risks and opportunities. He draws on more than a decade of experience working at the highest levels of healthcarehealthcare financing policy and law to help managed care organizations navigate the web of federal and state regulations and program policies governing the health care financing system. Mr. Malone is a go-to lawyer on issues concerning the Mental Health Parity and Addiction Equity Act (the federal parity law), delivery systems for Medicare-Medicaid dually eligible beneficiaries (such as special needs plans and the Programs of All-Inclusive Care for the Elderly (PACE)), and demonstration models for Medicare and Medicaid. He also advises providers ranging in size from large hospital systems to start-up health and telehealth companies on legal and strategic matters involving corporate formation, licensing, and third-party payment and coverage with a particular focus on value-based payment strategies. Provider organizations rely on his experience with managed care organizations and government regulators to develop successful strategies for market entry and growth.
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
-
Date + Time
- event
Wednesday, September 9, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Introduction
A. OBBBA IFR requirement
B. Purpose
II. OBBBA Medicaid work requirements
A. Covered individuals
B. Qualifying community engagement activities
C. Exemptions
III. CMS Interim Final Rule
A. Medical frailty exemption
B. MCOs
C. State administrative and operational obligations
D. Remaining questions
IV. Potential impact
A. On Medicaid enrollees
B. On the states
V. Key takeaways
The panel will review these and other important considerations:
- What are qualifying activities to satisfy OBBBA's Medicaid work requirements?
- What are exemptions to the work requirements? How does the IFR clarify the qualifications for the medical frailty exemption?
- What is the potential impact of the Medicaid work requirements on the states? On enrollees?
Related Courses
Fair Market Value and Commercial Reasonableness in Hospital and Physician Transactions: Complying With Anti-Kickback and Self-Referral Laws
Wednesday, September 2, 2026
1:00 PM ET/10:00 AM PT
