NACHC Recommends CHCs as Volunteer Sites to Fulfill Medicaid Work Requirements, CMS Rule Expected June 2026
Issue
NACHC issued updated guidance on Medicaid work requirements (80 hrs/month, effective Dec 31, 2026). Key recommendation: states should permit patients to volunteer at health centers to fulfill work requirements — preserving patient volumes AND satisfying the mandate.
CBO estimates 10.9M patients will lose coverage. Arkansas precedent: 18,000 lost coverage (28% of target population). Georgia: only 20% of work requirement program funding went to health services.
Implementation costs projected at hundreds of millions per state. CMS interim final rule expected by June 2026.
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Part of
- Medicaid work-requirement implementation
The federal rule (CMS-2454-IFC) · State implementation and early enforcement
FQHC Talent. (2026, March 20). NACHC Recommends CHCs as Volunteer Sites to Fulfill Medicaid Work Requirements, CMS Rule Expected June 2026. Source: NACHC. Retrieved October 6, 2026, from https://www.fqhctalent.com/intel/nachc-work-requirements-volunteer-site-strategy