Has my state expanded Medicaid or added waivers that change 2026 eligibility or enrollment procedures?

Checked on December 9, 2025
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Executive summary

Many states already expanded Medicaid under the ACA; 41 states (plus DC) had expanded by 2025 and individual state actions continue (KFF, NCSL reporting) [1] [2]. Major federal law changes in 2025 (the “One Big Beautiful Bill” / H.R.1) add new statewide options and national requirements — notably work requirements for expansion adults beginning in late 2026 and the ability for states to pursue waivers to implement changes earlier — meaning some states are pursuing 1115 waivers that could change eligibility or enrollment processes before 2026 [3] [4] [5].

1. What the federal floor now is — and what it lets states do

Congress rewrote large parts of Medicaid in 2025: the reconciliation bill requires work requirements for adults in the ACA expansion group beginning no later than January 1, 2027, but it also allows states to implement similar rules sooner using Section 1115 waivers; CMS will set application deadlines and guidance for states [3] [6] [7]. The law also changes matching funds and administrative rules that affect states’ incentives to keep expansion as-is [4] [7].

2. Waivers are the vehicle most states are using to change rules

States use Section 1115 and other waiver authorities to test policies that diverge from federal statutory rules — everything from managed care mandates to eligibility conditions like work requirements and cost sharing [8] [9]. KFF and MACPAC track approved and pending waivers; KFF notes states can use 1115 waivers to implement work requirements earlier than the federal deadline [3] [8].

3. Who’s actually filed or received work‑requirement waivers so far

As of the latest trackers, Georgia is the only state with an active Medicaid work‑requirement 1115 waiver in place after litigation; that waiver was temporarily extended and is set to expire December 31, 2026 [10]. Other states have filed or signaled interest: advocacy and clinical groups report multiple states pursuing waivers and legislative moves tied to work rules, with some filings and proposals under review by CMS [11] [10].

4. How this will change 2026 eligibility and enrollment procedures in practice

Federal changes create two tracks: mandatory federal requirements that states must adopt by the statutory deadlines (e.g., work requirements by Jan. 1, 2027) and optional earlier implementation through approved waivers. States with approved waivers can impose work or reporting rules and more frequent redeterminations, which will add administrative steps — such as monthly/quarterly reporting of hours, exemptions processing, and more frequent eligibility checks — before the federal deadlines if CMS approves them [3] [5] [6].

5. Examples and signals from states (North Carolina, Colorado, others)

North Carolina expanded Medicaid in December 2023 and reports more than 690,000 newly eligible enrollees under expansion — a reminder that state expansion remains consequential even as federal rules shift [12] [13]. Colorado’s Medicaid office is already preparing for federal changes and federal grant programs created by H.R.1 (RHTP) and has been active in submitting state proposals that interact with the new law’s limits on state‑directed payments [14]. These state-level moves illustrate how expansion status and state policy choices determine whether and how enrollment procedures change [12] [14].

6. What to watch in your state — a practical checklist

  • Check your state Medicaid agency and the federal Medicaid.gov waiver list for any new or pending 1115 submissions that would affect eligibility or reporting procedures [15] [3].
  • Track KFF’s waiver tracker for approved/pending work‑requirement waivers and state-by-state updates [3] [10].
  • Watch local state announcements (e.g., press releases from governors or health departments) for implementation timelines and outreach plans — North Carolina’s press release illustrates the level of official communication states use [12] [13].

7. Competing perspectives and the political stakes

Supporters argue waivers let states tailor programs and promote employment; opponents and many health‑policy groups warn that work requirements and more frequent redeterminations increase churn and coverage losses, and that cuts to federal match risk reversing expansion gains [3] [5] [16]. Legal battles and administrative guidance from CMS will determine how far states can go before the federal deadline; Georgia’s litigation history shows the potential for court intervention [10].

Limitations: available sources do not list every state’s current pending waiver filings in full detail; to know whether “your state” has a waiver that will change 2026 eligibility or enrollment procedures, consult your state Medicaid website and the federal waiver list for the most recent filings [15].

Want to dive deeper?
Which states have Medicaid expansion changes taking effect in 2026 and what are the new eligibility rules?
How do 1115 waivers approved in 2024–2025 affect Medicaid enrollment processes in 2026?
Will work or reporting requirements for Medicaid adults be added or removed in my state in 2026?
How do state changes to Medicaid premiums, lockouts, or asset tests impact 2026 coverage renewals?
Where can I find official state-by-state updates and deadlines for Medicaid enrollment and renewals in 2026?