NACHC Recommends CHCs as Volunteer Sites to Fulfill Medicaid Work Requirements — CMS Rule Expected June 2026

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.