How Medicaid Requirements Could Fail Patients in Recovery – Behavioral Health Business
By Ashleigh Hollowell | August 11, 2026
The addiction treatment field often views recovery as an ongoing journey, but changes to Medicaid brought on by the One Big Beautiful Bill could threaten to turn recovery milestones into an insurance cliff for patients who rely on coverage to maintain stability.
Guidance from CMS
Released in June, the Centers for Medicare & Medicaid Services (CMS) interim final rule clarifies that beneficiaries must meet an 80-hour-per-month work requirement through employment, education work programs, community service, or a combination of these options. However, individuals exempt from this requirement must fit CMS’ definition of “medically frail.”
For the most part, actively treated patients and those in recovery are exempt from the work requirements. Patients who have received treatment for a substance use disorder (SUD) and are actively in recovery are exempt up to five years. After five years, individuals are considered to be in "stable recovery" and no longer eligible for this exemption.
“We believe that it is inappropriate to include individuals with an SUD who are in stable recovery…in the medically frail exclusion,” CMS states in the Federal Register.
Challenges Ahead
CMS defines early recovery as 12 months or less, sustained recovery as between one and five years, and beyond that, individuals fall under the "stable recovery" label. However, both payer organizations and providers question the arbitrary decision to cut off care after year five.
"The way that the rule is written right now, I think it’s going to be very challenging for a provider," Debbie Witchey, president and CEO of the Association for Behavioral Health and Wellness (ABHW), stated. “Unless they’ve had a long relationship with the patient…it will be really hard for them to figure out how to document that."