Nebraska did not wait for permission. While most states are not required to enforce Medicaid work requirements until Jan. 1, 2027, Nebraska has already begun, making it the first state in the country to do so. The early rollout, launched eight months ahead of the federal deadline set by the Trump administration, is drawing sharp criticism from health care advocates who say the speed of the change is putting real people at real risk.
The policy affects an estimated 72,000 Nebraskans between the ages of 19 and 64 who are currently enrolled in Medicaid through the Affordable Care Act’s expansion. Of that group, roughly 25,000 residents who qualified under the expansion could lose coverage, according to estimates from the Urban Institute, a nonpartisan research organization.
What the new rules require
Under the new policy, individuals seeking to maintain their Medicaid coverage must show proof that they are working, volunteering or participating in community service for at least 80 hours per month. Enrollment in school or an apprenticeship program for at least half the standard time also counts. New enrollees must satisfy these conditions from the start. Those already enrolled have until at least the end of July to come into compliance.
Anyone who fails to submit the required documentation within a month of being notified faces denial or loss of coverage. Beginning next year, the state will also move to reviewing eligibility every six months rather than annually.
Exemptions exist for pregnant women, parents of young children and people with disabilities. However, qualifying as medically frail under the new criteria requires navigating a document of medical codes that runs nearly 300 pages, a reality that health advocates say makes the exemption process more obstacle than option.
Why Nebraska moved early
Gov. Jim Pillen and Centers for Medicare and Medicaid Services administrator Dr. Mehmet Oz jointly announced the state’s intent to move ahead of the federal timeline. State officials framed the early rollout as a workforce initiative, arguing that the requirements would push more residents toward employment and financial independence.
Jeff Powell, a spokesperson for the Nebraska health department, said the state began notifying Medicaid enrollees in December and has since run outreach campaigns across multiple media channels. He maintained that Nebraska was operationally prepared to move forward, and estimated that between 60% and 72% of current enrollees already meet the work requirements or qualify for an exemption.
Advocates warn of a paperwork trap
Health care advocates are not convinced the preparation has been enough. Sarah Maresh, healthcare access program director for Nebraska Appleseed, acknowledged that most Nebraskans are likely working or eligible for exemptions, but argued that the bureaucratic demands of proving it could trip up enrollees who have every right to stay covered.
Anthony Wright, executive director of Families USA, put it more bluntly. He called the federal timeline for implementing requirements of this scale insufficient on its own, and said Nebraska’s decision to move even faster serves no identifiable purpose beyond creating confusion.
Medicaid gaps can be dangerous
The concern is not just administrative. Dr. Adam Gaffney, a critical care physician, warned that even brief interruptions in Medicaid coverage can carry serious medical consequences for people managing chronic conditions or disabilities. A lapse of a few weeks in prescription coverage or follow-up care can cascade into something far harder to treat.
Allie Gardner, a senior policy analyst at the Center on Budget and Policy Priorities, added that people with legitimate medical exemptions may still lose coverage simply because the documentation process is too complicated to complete without assistance.
What comes next
Nebraska is now a test case for the rest of the country. As other states watch what happens here, the question is not only whether the policy achieves its stated workforce goals, but whether the state can prevent eligible people from losing coverage through a process that was designed to screen them in, not push them out.
The answer will come into clearer focus as the July compliance deadline approaches and the number of disenrollments begins to take shape.

