MOHActive

Will CMS issue OBBBA Medicaid work requirements guidance or approve state waiver applications by Q3 2026?

Resolves October 15, 2026(231d)

IG: 0.80

Current Prediction

78%

Likely Yes

Model Agreement88%

Predictions9 runs

Last UpdatedFebruary 5, 2026

Why This Question Matters

OBBBA implementation is the most consequential pending regulatory catalyst. Work requirements effective December 2026 could reduce Medicaid membership by 8-15% based on Arkansas precedent, but actual impact depends on CMS guidance and state-level waiver decisions. If CMS issues strict guidance and key states proceed without broad waivers, it escalates REGULATORY_EXPOSURE toward EXISTENTIAL. If states receive broad waivers or CMS delays, it de-escalates regulatory concern.

REGULATORY_EXPOSUREREVENUE_DURABILITY

Prediction Distribution

0%25%50%75%100%

opus

sonnet

haiku

Range: 68% – 87%Aggregate: 78%

Individual Predictions(9 runs)

opusRun 1

87%

OBBBA signed July 4, 2025 with work requirements effective December 2026. CMS has ~14 months from enactment to effective date — agencies typically issue guidance 6-12 months before effective dates. States need lead time; CMS delay past Q3 would make December compliance impossible. Two pathways (guidance OR waiver) increase YES probability.

Enacted law with Dec 2026 effective date creates strong CMS pressureStates need lead time — CMS delay past Q3 makes Dec compliance impossibleTwo pathways to YES resolution

opusRun 2

82%

CMS has strong institutional obligation to issue guidance well before December 2026 effective date. With ~11 months between signing and Q3 2026 deadline, and statutory deadline creating urgency, CMS will likely publish formal guidance even if no specific waiver has been approved. No guidance as of Jan 2026 introduces some uncertainty but legal mandate creates strong pressure.

Enacted law with Dec 2026 effective date creates CMS obligationNo guidance yet as of Jan 2026 suggests some delayTwo pathways (guidance OR waiver) increase probability

opusRun 3

82%

Enacted law with December 2026 effective date creates binding obligation for CMS to act. Q3 2026 deadline gives CMS 15 months from signing — within normal federal guidance timelines. States cannot implement without CMS guidance, creating external pressure. Political complications and resource constraints introduce meaningful uncertainty.

Binding statutory obligation for CMS15 months from signing within normal timelinesExternal pressure from states needing guidancePolitical/resource constraints as risk

sonnetRun 1

72%

OBBBA is enacted law with December 2026 implementation deadline creating institutional urgency. However, CMS regulatory processes are notoriously slow, and states like CA/NY may actively resist waiver applications. Historical Arkansas precedent shows feasibility but also litigation risk.

December 2026 deadline creates urgencyCMS regulatory delays and complexityPolitical resistance from progressive statesHistorical Arkansas precedent

sonnetRun 2

78%

With OBBBA effective December 2026, CMS faces strong statutory pressure to issue guidance well before the effective date. Nine months to resolution provides adequate runway for either formal guidance or waiver approval in at least one major state. Multiple resolution pathways increase probability.

Statutory deadline creates regulatory imperative5-month buffer between resolution and effective dateMultiple resolution pathways (guidance OR waiver)Major states have ideological motivation to seek waivers

sonnetRun 3

82%

OBBBA is enacted law with concrete December 2026 effective date creating regulatory urgency. CMS must issue guidance for states to comply, and 14 months from enactment to Q3 2026 deadline provides sufficient runway. September 30, 2026 cutoff precedes December implementation by only 3 months, making agency action nearly certain.

Statutory mandate, not discretionary policy14-month runway exceeds typical rulemaking timelinesRegulatory vacuum would create compliance crisisAlternative waiver path as fallback

haikuRun 1

72%

CMS faces strong institutional and legal pressure to issue guidance before Dec 2026 effective date, with ~10 months remaining. States cannot implement without guidance. CMS guidance issuance more probable than state waiver approvals but OR condition favors probability.

Mandatory statutory requirementStates cannot implement without guidance~10 months remainingOR condition increases probability

haikuRun 2

68%

CMS guidance is likely by Sep 30 to meet Dec 2026 implementation deadline (6-month lead time is standard). Waiver approvals less certain but possible with political momentum. The OR condition favors probability.

Regulatory guidance timelines 6-12 months post-enactmentDec 2026 deadline creates pressurePolitical momentum from OBBBACMS competing priorities may delay

haikuRun 3

78%

OBBBA is enacted law effective December 2026, requiring CMS implementation guidance. CMS typically issues guidance 3-6 months before effective date, placing Q3 2026 at or near the expected guidance window. State waiver applications likely from key states; combined OR probability elevated.

CMS guidance expected by Sept-Oct 2026State waiver applications likely from CA/TX/WA/NYSection 1115 waiver timeline fits Q3 window~9 months remaining for CMS/state action

Resolution Criteria

Resolves YES if by September 30, 2026, either: (1) CMS publishes formal guidance on OBBBA Medicaid work requirements implementation, OR (2) CMS approves at least one state's Section 1115 waiver application explicitly implementing OBBBA work requirements in CA, TX, WA, or NY. Resolution based on CMS.gov/Medicaid.gov waiver database, Federal Register notices, or official CMS press releases. Resolves NO if neither occurs by end of Q3 2026.

Resolution Source

CMS Medicaid.gov Section 1115 waiver database, Federal Register, CMS official press releases

Source Trigger

OBBBA state implementation — CMS guidance + state waiver applications; key states CA, TX, WA, NY

regulatory-readerREGULATORY_EXPOSUREHIGH

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