Overview

• At least 14 states, including Georgia, Arkansas and Arizona, are revising or awaiting approval of 1115 waiver proposals to satisfy an 80-hour monthly work requirement under the new law.
• Arkansas’s application omits all exemptions and Arizona’s proposal adds a five-year lifetime benefit limit, both exceeding federal floors and ceilings.
• CMS is scheduled to publish implementation rules by June 2026, underscoring ongoing uncertainty about waiver flexibility.
• Legal scholars predict that even approved waivers with more stringent provisions will face court challenges.
• Advocates say work requirements will curb fraudulent enrollments while critics warn of bureaucratic hurdles that could reduce coverage.