CMS Rule Tightens Medicaid Work Exemptions
A pulmonologist argues that a new CMS rule on Medicaid work requirements will increase paperwork burdens for clinicians and threaten coverage for patients
A new federal rule from the Centers for Medicare & Medicaid Services (CMS) will make it harder for patients with serious health conditions to get exemptions from Medicaid work requirements. A pulmonologist warns this will worsen the profession's existing paperwork crisis and cause patients to lose vital coverage.
The author, a practicing pulmonologist, describes a career shift from patient care to administrative battles. Hours are now spent daily on prior authorizations, insurance denials, and reimbursement fights just to secure recommended treatments.
The New Rule's Impact
The interim final rule, released by CMS in June, applies work reporting requirements from H.R. 1, a law passed last summer with over $1 trillion in healthcare cuts. The rule specifically tightens standards for medical exemptions. Having a serious condition like lung cancer is no longer sufficient; state programs must now verify the condition "significantly impairs" the patient's ability to meet work requirements.
This creates new hurdles. A patient named Carla, who spoke to Congress in April 2025, illustrated the stakes. She lost her job just before a lung cancer diagnosis and relied on Medicaid for biomarker testing and treatment, crediting it with saving her life. Lawmakers had promised protections for such patients, but the new rule threatens them.
Unanswered Questions and Burdens
Major practical questions remain. It is unclear if physicians will be tasked with making the "significant impairment" determinations. Many clinicians may feel this falls outside their expertise. The process also promises a huge new administrative burden, pulling time away from direct patient care.
Patients with conditions like lung cancer, COPD, and pulmonary fibrosis already manage complex challenges including treatments, hospitalizations, and frequent appointments. Imposing confusing, repetitive paperwork will likely lead many to lose coverage when they need it most.
Broader System Consequences
Loss of coverage does not eliminate the need for care. Patients will still require treatment, often at a higher cost to a system already under strain. The author notes many hospitals, particularly in underserved rural and inner-city areas, already struggle financially. Eroding the health safety net puts everyone at risk.
State-level experiments with Medicaid work requirements have shown they strip coverage from eligible people, incur substantial administrative costs, and fail to increase employment. Nationwide implementation will likely repeat these results on a larger scale.
The pulmonologist concludes there is no way to implement such work requirements without harming access to care. The call is for Congress to take immediate action, urging CMS to fix the rule and protect patient access to Medicaid.
