Comment on CMS-2026-2047-0002
FGA ActionSupportAdvocacy
Summary: FGA Action expresses strong support for the CMS interim final rule implementing the Medicaid work requirement, praising its integrity protections and statutory alignment. However, the organization urges CMS to further strengthen enforcement by closing specific loopholes regarding self-attestation and state-level exemptions to prevent "gaming" of the system.
FGA Action strongly supports the Centers for Medicare and Medicaid Services’ interim final rule implementing the Medicaid work requirement. The rule contains core integrity protections that will keep the requirement meaningful and hold able-bodied adults to the standard Congress set. But FGA Action is concerned that states opposed to the work requirement, whether on policy or partisan grounds, will create and exploit loopholes to undermine its effectiveness, just as they have done with similar requirements for able-bodied adults receiving cash welfare or food stamps. FGA Action recommends additional changes and clarifications to strengthen enforcement in 2028 and beyond.
Please see the attached for FGA Action's full public comment.