On hot afternoons, DeAnna Brandon relishes time with her grandchildren and her three dogs in her backyard in Rockwell, North Carolina. These moments are cherished as a blood cancer survivor. But her future moments are uncertain due to new Medicaid work requirements starting next year.
Brandon expected to qualify for a medical frailty exemption, but new guidance from President Donald Trump’s administration has put this into question. The interim final rule from the Centers for Medicare and Medicaid Services means her extreme exhaustion and memory challenges may not exempt her from the new work requirements. Brandon will have to prove these symptoms “significantly impair” her ability to meet these mandates.
If rejected, she risks losing the coverage that funds her chemotherapy necessary to keep her multiple myeloma in remission. “Working is outside the realm of possibility for me,” she explained.
“I was always a push-through-it person. But it’s hard to explain to people you can’t push through it.”
Health analysts warn about the potential risks from this guidance. Experts claim it may lead to more Americans losing health insurance and force states to hastily implement changes. Adrianna McIntyre, a Harvard public health professor, noted, “This will mean more paperwork for Medicaid patients — especially for the sickest.”
The new Medicaid restrictions, criticized by Democrats, were part of Trump’s policy law in 2025. It targets those covered through an expansion that most states implemented to aid lower-income individuals. The new rules require enrollees aged 19 to 64 to work, volunteer, or attend school for at least 80 hours a month unless granted an exemption for being medically frail or involved in addiction treatment programs.
The announcement surprised states with an updated definition of medical frailty. Previous rules covered substance use disorders, disabilities, or serious medical conditions. But now, CMS requires proof that these conditions “significantly impair” work ability.
Brandon, having failed to access disability benefits during cancer treatment, fears the paperwork demands. “You may have to go through four doctors,” she said, noting the exhaustion of battling an illness while navigating bureaucratic processes.
States plan to use Medicaid claims data to automatically exempt eligible enrollees, a method endorsed by CMS Administrator Dr. Mehmet Oz. However, Medicaid officials express confusion over implementing rules without sufficient data.
“States are going to be asked to make a determination using information that doesn’t exist in their systems,” noted Kinda Serafi of Manatt Health.
Nebraska, beginning work requirements ahead of schedule, identified medically frail individuals through diagnostic codes. It might need to adjust its system, according to Sarah Maresh from Nebraska Appleseed.
Doctors already hesitant to accept Medicaid patients may become overwhelmed by added certifications needed for work ability. Preparing states for the January 1 kickoff is costly, with a $200 million federal grant and additional technology partnerships. However, the total expense might exceed $1 billion.
Republicans argue the new rules aim to preserve Medicaid for those who truly need it. They cite concerns over idle Medicaid enrollees, suggesting work requirements could change this behavior.
Critics like Mids Meinberg, a freelance writer with chronic depression and diabetes, point out misrepresentations. Although having meaningful careers, some are unable to meet work thresholds but aren’t fully recognized as disabled.
Brandon, emphasizing her contributions beyond work, hopes the government sees her value. “We’re valuable, and we can still contribute to our communities even if it’s not working,” she stated.

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