Rules And Dates

The frailty rules in one place, as they stand after the October 29, 2026 ruling.

RuleDetail
Work requirements beginJanuary 1, 2027, in most states 
Data look-backClaims and encounter data from the preceding 12 months 
Member statements, through 2027States may accept them 
Member statements, from January 1, 2028Once per enrollment period, then data or documentation 
ReverificationAt least every 12 months 
Impairment testStruck down on October 29, 2026, with its scope still being clarified 
Pending caseTaylor v. Kennedy, which challenges the limit on self-declaration 

Caseworker Quick Reference

A one-page decision flow for checking whether a member is medically frail: Is This Member Exempt? (PDF).

Sources