Nebraska Implements Medicaid Work Requirements: Up to 40,000 Expected to Lose Coverage

Nebraska Becomes First State to Enforce Medicaid Perform Requirements, Risking Coverage for Tens of Thousands

Nebraska on May 1, 2026, became the first U.S. State to enforce Medicaid work requirements, eight months ahead of the federal deadline set by the One Big Beautiful Bill Act (H.R. 1), signed into law on July 4, 2025. The new rules require most able-bodied Medicaid enrollees between the ages of 19 and 64 to log at least 80 hours per month of employment, work program attendance, volunteering, or schoolwork to retain coverage. Critics warn that the policy could lead to tens of thousands of Nebraskans losing Medicaid eligibility, raising concerns about access to healthcare for vulnerable populations.

Under the new requirements, Medicaid beneficiaries who fail to meet the work or community engagement criteria face disenrollment. State officials estimate that between 20,000 and 40,000 individuals could lose coverage as a result of the policy, though advocates argue the actual number may be higher due to administrative hurdles and exemptions not being widely understood.

The policy is part of a broader federal push to impose work requirements on Medicaid recipients, a provision included in the 2025 budget reconciliation law. While most states were required to implement these rules by January 1, 2027, Nebraska chose to roll them out early, setting a precedent for other states. The move has drawn sharp criticism from healthcare advocates, who argue that the requirements disproportionately affect low-income individuals, many of whom already face significant barriers to stable employment.

Who Is Affected by Nebraska’s Medicaid Work Requirements?

According to the Nebraska Department of Health and Human Services (DHHS), the new rules apply to most Medicaid enrollees aged 19 to 64 who are not exempt due to disability, pregnancy, caregiving responsibilities, or other hardships. The state estimates that roughly 72,000 Medicaid enrollees could be impacted, though only a fraction of these individuals are expected to lose coverage if they meet the 80-hour monthly requirement or qualify for exemptions.

Still, critics point out that many enrollees—particularly those in low-wage jobs, part-time work, or seasonal employment—may struggle to meet the requirement. For example, a recent KFF analysis found that only about 65% of Nebraska Medicaid adults without dependent children currently work 80 or more hours per month or attend school. The remaining 35% could face disenrollment unless they qualify for exemptions or uncover additional work.

State officials have acknowledged operational challenges, including difficulties in verifying volunteer hours, educational activities, and work program participation. The AP News reports that Nebraska has not increased staffing levels to handle the new requirements, raising concerns about administrative delays and errors in eligibility determinations.

How the Policy Differs from Federal Guidelines

The Medicaid work requirements in Nebraska are stricter than those proposed in other states. While the federal law allows for exemptions—such as for medically frail individuals, caregivers, and students—the state’s implementation has faced scrutiny over its narrow definitions of acceptable activities. For instance, the state has not yet clearly defined how volunteer hours will be counted, leaving many enrollees uncertain about compliance.

Nebraska’s policy applies to new applicants as well as existing enrollees, unlike some other states that have proposed more limited rollouts. This broader application increases the risk of disenrollment for tens of thousands of Nebraskans who may not meet the new criteria.

Advocates, including the ACLU of Nebraska, have warned that the policy could push vulnerable individuals into uninsured status, particularly during a time when healthcare costs remain high and access to affordable care is limited.

What Happens Next?

As Nebraska implements its Medicaid work requirements, other states are watching closely. The state’s DHHS has indicated that it will continue to work with the Centers for Medicare & Medicaid Services (CMS) to refine implementation details, including data verification processes and outreach efforts.

Legal challenges are also possible. Advocacy groups have already signaled their intent to challenge the policy in court, arguing that it violates the spirit of Medicaid by imposing barriers to coverage for low-income individuals. Meanwhile, the state’s Medicaid Advisory Committee (MAC) will continue to monitor the rollout and address concerns raised by enrollees, providers, and stakeholders.

Key Takeaways

• Nebraska is the first state to enforce Medicaid work requirements, effective May 1, 2026. The policy requires enrollees aged 19–64 to log at least 80 hours per month of work, education, volunteering, or program participation.
• Estimates suggest 20,000–40,000 Nebraskans could lose Medicaid coverage. Critics warn the actual number may be higher due to administrative challenges and limited exemptions.
• The policy is part of the federal One Big Beautiful Bill Act (H.R. 1), signed into law in July 2025. Most states were required to implement these rules by January 2027, but Nebraska acted early.
• Operational hurdles remain. The state has not increased staffing to handle the new requirements, raising concerns about delays and errors in eligibility determinations.
• Legal challenges and advocacy efforts are expected. Groups like the ACLU have vowed to challenge the policy, arguing it disproportionately affects low-income individuals.

For updates on Nebraska’s Medicaid work requirements, visit the Nebraska DHHS Work Requirements page or follow developments from the Kaiser Family Foundation (KFF).

This story will be updated as new information becomes available. In the meantime, we welcome your comments and questions below.