On June 1, 2026, the Centers for Medicare & Medicaid Services (CMS), published the Interim Final Rule with Comment (CMS-2454-IFC, hereafter referred to as the IFR) “Medicaid Program; Community Engagement Requirement for Certain Individuals” as required by the 2025 Budget Reconciliation Law (hereafter referred to as H.R. 1). States that have expanded Medicaid to adults – whether through the Affordable Care Act (ACA, Section 1902(a)(10(A)(i)(VIII) of the Social Security Act) or a Section 1115(a)(2) waiver – must implement this consequential shift in policy, commonly referred to as work reporting requirements (WRR). Prior state experience has shown that requiring individuals to report work or qualifying activities results in significant coverage losses resulting from the confusion and the administrative burden for eligible and enrolled individuals. Notably, the IFR establishes a complex set of definitions and processes that are much harsher and more difficult to implement than was stipulated in H.R. 1.