Medicaid Work-Requirement Implementation and Coverage Risks
CMS's three-tier medical-frailty verification framework relies on claims data and likely manual reviews as states prepare for January 1 implementation of new Medicaid work requirements. California's September 14 Medi-Cal legislation offers an early state-level implementation signal, while administrative capacity, litigation, and procedural disenrollment could determine how many eligible beneficiaries lose coverage.
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Updated Sep 15, 2026