The federal list of exemptions from new Medicaid work requirements does not include homelessness, and clinics that serve unhoused patients are now working out how to document eligibility through other categories before enforcement begins.
The Centers for Medicare and Medicaid Services confirmed to KFF Health News that states must adhere to the federal exemption list. At least four states, Montana, Arizona, Kentucky, and Utah, had previously proposed policies that included homelessness as an exemption. Montana lawmakers had also intended to excuse people fleeing domestic violence and caregivers of hospitalized family members, two more groups the federal list omits. Montana plans to begin removing enrollees who cannot demonstrate compliance in October 2026.
