CMS touts Nebraska being first to launch Big Ugly Bill Medicaid work reporting requirements by misspelling the name of the state.

As of March 2025, around 72,000 Nebraska residents were enrolled in Medicaid via the ACA's expansion of the program.

Last summer, after Congressional Republicans passed their Big Ugly Bill, I warned people against assuming that the gutting of Medicaid wouldn't hit until after the 2026 midterms:

Over at The New Republic, Greg Sargent has taken this thinking one step further, noting that by delaying so much of the ugliness of the new law until 2027 or beyond...

Republicans know how unpopular all this will be. So they’ve structured the bill so the tax cuts land immediately, while many of the Medicaid cuts get going in 2027 and 2028. That’s meant to spare them in the midterms.

But there’s a wrinkle here worth appreciating. Those policies will start hitting right when JD Vance’s bid to succeed Trump is getting underway. For Vance—perhaps the most prominent evangelist for Trumpism’s supposed promise for the working class—to have to defend all of that carnage while running for president could yet prove a form of poetic justice.

Again, this is a fair statement, as far as it goes.

However, while I'm not an expert on any of the non-healthcare provisions, when it comes to the sections related to healthcare policy, a whole lot of the ugly will actually hit well before the midterms.

I went on to break out the actual effective date of every healthcare-related provision, including noting that...

IMPORTANT: Even the controversial & much-debated Medicaid work reporting requirements which have sucked up so much political & media attention, which everyone keeps saying "won't be implemented until after the midterms," could potentially go into effect before Election Day 2026 after all.

The actual wording of the relevant legislative text is:

"...the first day of the first quarter that begins after December 31, 2026, or, at the option of the State under a waiver or demonstration project under section 1115 or the State plan, such earlier date as the State may specify."

In other words, some states COULD potentially launch them BEFORE the midterms via a waiver if granted by the HHS Dept. This most likely refers to states like Arkansas, Indiana, New Hampshire & Ohio, where waivers were already approved by the first Trump Admin but were shut down by federal judges.

Well, it turns out I was right, although I was wrong about which state would be the first one to pull the trigger.

Yes, this is a real tweet...and it's been up for five days so far, so I'm guessing they aren't in a big rush to delete it:

The policy is going into effect starting May 1st, 2026...a full six months before November 2026, just as i warned.

(sigh) In any event, here's the official details from the Nebraska Dept. of Health & Human Services.

(To be clear, I'm strongly opposed to work reporting requirement for Medicaid eligibility for numerous reasons, but it is what it is, so it behooves me to provide as much information about how it's being implemented as I can to help as many people as possible keep their coverage):

H.R. 1 (the “One Big Beautiful Bill Act") was passed into federal law on July 4, 2025, and made many changes to the Medicaid program.

Starting May 1, 2026 Nebraska Medicaid will begin enforcing work requirements for new applicants and existing Medicaid members under Medicaid expansion. Some people enrolled in Nebraska Medicaid through Medicaid expansion may not have to complete work requirements (see list of exemptions below).

What is Medicaid Expansion?

Medicaid expansion includes people who are aged 19-64, have a low income, and get their health insurance through Nebraska Medicaid (also known as Heritage Health). They cannot get Medicare, and they cannot be pregnant or be eligible on the basis of a disability. They also must be a U.S. citizen or meet Medicaid immigration rules. Low income means people who earn up to 138 percent of the federal poverty level (about $21,610 per year for a single person, or $44,380 for a family of four).​

What are Work Requirements?

Work requirements are activities Medicaid members and applicants under Medicaid expansion must complete to get health insurance through Nebraska Medicaid.

Work requirement activities include:

• Working
• Attending school or an apprenticeship
• Participating in a work program
• Volunteering

Medicaid members and applicants must spend at least 80 hours in at least one qualifying month doing one of these activities or attending school or an apprenticeship at least half time. Or Medicaid members and applicants can combine any of these activities to get to 80 hours during a qualifying month.

Individuals can also meet work requirements if they are working and earn the federal minimum threshold in a qualifying month. This is the equivalent of 80 hours worked at the current federal minimum wage. As of December 2025, this is about $580 per month.​

When do Work Requirements Start?

Work requirements take effect on May 1, 2026. This includes people with Medicaid coverage under Medicaid expansion on this date or people who apply on or after this date.

Reporting Work Requirement Information

The Department of Health and Human Services (DHHS) will examine Medicaid members' case information to determine if they have met work requirements in a qualifying month or if they qualify for an exemption.

If DHHS does not have enough information to verify work requirements or an exemption, we will contact the individual and ask for more information. We will send the individual a form describing the information we need from them and how they can send it to us. If DHHS requests additional information from a member, they must submit the requested information within 30 days of receipt, or they may lose their Medicaid coverage.

Medicaid members should check their mail or email regularly in case DHHS requests more information from them. If a Medicaid member does not receive a request from DHHS, then they do not have to send additional information.

Exemptions

Some Nebraska Medicaid expansion adults may not need to complete work requirements if they meet one of the following exemptions:

• People under age 26 who aged out of foster care
• People who are members of recognized Native American tribes
• Parents, caretakers or guardians of children up to age 13 or of an individual with disabilities
• Veterans with a total disability rating
• People who are medically frail or have special medical needs, including:
  • Blindness or disability
  • Substance use disorder
  • Disabling mental disorder
  • Or other significant physical, intellectual or developmental disabilities
• People compliant with work requirements under the SNAP or TANF programs
• People who are participating in a drug addiction or alcoholic treatment program
• People who are incarcerated or have been incarcerated within the last 90 days
• Women who are pregnant or up to 12 months after the end of pregnancy

Other mandatory exceptions may apply.

DHHS will try to use information it already has available to see if members and applicants qualify for one of the exemptions listed above. If DHHS does not have enough information, we will contact the individual to ask for more information.

Temporary Hardships

Some people enrolled in Nebraska Medicaid through Medicaid expansion also may not need to complete work requirements if they have one of the following temporary hardship reasons:

• People who were hospitalized or lived in a nursing home since their last coverage renewal.
• People or a dependent who had to travel outside their community to receive care to treat a serious health condition since their last coverage renewal.
• People who lived in a county that was under an emergency declaration or in a county with a high unemployment rate since their last coverage renewal.

Members and applicants who have one of these temporary hardship reasons may need to make a request to DHHS in person, online, by phone, or through the mail.

Reporting Information to DHHS

Nebraska Medicaid members must report changes that impact their eligibility. This includes changes in income, home address, work status, and household size (such as marriage, divorce, pregnancy, or adoption). You can provide this information to DHHS in person, online, by phone, or through the mail.

If DHHS requests information from an individual or they need to report a change that affects their Medicaid eligibility, they can do so in the following ways:

• Online: at iserve.nebraska.gov

By mail: P.O. Box 2992
Omaha, NE 68103-2992

By phone:

• Phone Number: (855) 632-7633 (press option 3)
• Lincoln Phone Number: (402) 473-7000 (press option 3)
• Omaha Phone Number: (402) 595-1178 (press option 3)
• TTY Number: (402) 471-7256
• Fax: (402) 742-2351

In person: at a local DHHS office

Work Requirement Resources

Nebraska Medicaid Work Requirements Outreach Notice / Spanish
DHHS is mailing this outreach notice to all Medicaid expansion members.
DHHS is also emailing and texting Medicaid expansion members who opted in to receive electronic notifications.

Work Requirements Frequently Asked Questions / Spanish ​

​​​Job Seeking Assistance

​The Nebraska Department of Labor has resources available online​ for people that need help finding a job.

iServe Portal