The work-requirement map, 6 months out: 4 states going early, Nebraska's freeze is the preview, and Georgia's 5% enrollment rate is the warning
With the CMS-2454-IFC comment period closing July 31 and full implementation due January 1, 2027, the state map has taken shape. Four states are going early: Nebraska (enforcing since May 1), Montana (July 1), Arkansas (soft launch July 1), and Iowa (December 1, with no high-unemployment hardship exception) — plus Idaho (Dec 31 statutory deadline with the nation's longest 3-month lookback) and Kentucky (HB 2's pre-enrollment proof requirement, enacted over the governor's veto).
Nebraska's 'soft start' is producing the first hard national data: ZERO new Medicaid enrollees in May versus a typical ~15/month at the state's health centers (a pure chilling effect — termination checks don't even begin until July 31), with 20,000-28,000 of ~70,000 expansion enrollees flagged for documentation. Georgia's Pathways — the only mature work-requirement program — has enrolled ~16,183 people in three years, about 5% of its potential population.
Two mitigations worth copying: Utah exempted homeless individuals (FQHC-designed, NACHC-endorsed), and Oregon exempted FQHC visits from new cost-sharing. The operational takeaway repeats Nebraska's lesson everywhere: the chilling effect arrives before the disenrollments do, and clinics' navigation capacity is the rail it all runs on.
Key takeaways
- Nebraska's May data: 0 new Medicaid enrollees (vs ~15/month typical) BEFORE any termination checks — the chilling effect outruns the policy.
- Georgia's 3-year-old Pathways program enrolled only ~5% of its potential population — the only real-world benchmark for January 2027.
- Utah's homeless exemption (FQHC-designed) and Oregon's FQHC cost-sharing exemption are the two replicable mitigations on the map.
Primary source
Georgetown CCF / CBPP / KFFFQHC Talent. (2026, June 10). The work-requirement map, 6 months out: 4 states going early, Nebraska's freeze is the preview, and Georgia's 5% enrollment rate is the warning. Primary source: Georgetown CCF / CBPP / KFF. Retrieved June 11, 2026, from https://www.fqhctalent.com/intel/medicaid-work-req-state-implementation-map-june-2026
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