Medicaid Work Requirements: What They Mean for Your Coverage
Updated September 2026
Starting no later than January 1, 2027, most adults covered through Medicaid's ACA expansion — plus some enrollees in a handful of 1115 waiver programs — will have to document at least 80 hours a month of work, school, job training, or community service to keep their coverage. This is the first work requirement in Medicaid's 60-year history, created by the 2025 federal budget reconciliation law (Public Law 119-21, often called the "One Big Beautiful Bill Act"). It is enacted federal law, not a state waiver, and no state can opt out of it. Here's exactly who it applies to, who's exempt, how compliance actually gets checked, and what to do if your coverage is at risk.
80 hrs/mo
Work, school, training, or community service required
Jan 1, 2027
Federal deadline for states to start enforcing
44 states
Required to implement the requirement
30 days
To fix a compliance problem before disenrollment
Who has to comply
The requirement applies to adults ages 19–64 who are covered through Medicaid's Affordable Care Act expansion group — generally, adults with income up to 138% of the Federal Poverty Level in states that adopted expansion — plus enrollees in certain Section 1115 waiver programs that CMS identified in June 2026 (Georgia, Tennessee, and Wisconsin, none of which have adopted full Medicaid expansion, plus expansion-state waiver programs in Hawaii, Massachusetts, New York, Oregon, and Utah).
CMS's June 2026 list puts a total of 44 states (including DC) on the hook: 36 states where only the expansion population is affected, 5 states where both expansion and a specific 1115 waiver population are affected, and 3 non-expansion states affected only through a waiver program. The remaining 7 states have no population currently subject to the requirement.
If you're not in one of these groups — for example, you qualify for Medicaid through a state's traditional, non-expansion pathway, or through a category like disability or SSI — this requirement generally does not apply to you at all, regardless of which state you live in.
What counts toward the 80 hours
- Paid work — including work done in exchange for goods or services, not just a traditional paycheck
- Participation in a recognized work or job-training program
- School at least half-time — college, a career or technical education program, high school, or a high school equivalency (GED) program
- Community service — unpaid work for community benefit through a structured program run by a public or nonprofit organization
- Any combination of the above that adds up to 80 hours in the month
There's also an income-based alternative: showing at least $580 in monthly earnings (the equivalent of 80 hours at the federal minimum wage) satisfies the requirement without tracking hours separately. States may let seasonal workers average their income over a 6-month period instead of meeting the threshold every single month.
Who's exempt
A large share of people who are technically in the expansion group never actually have to prove anything, because they fall into an exempt category. Some of these categories — like being under 19, or pregnant — mean the state isn't allowed to assess you for work requirements at all. Others require the state to verify your exemption status, similar to how it verifies compliance for everyone else.
The "medically frail" exemption is narrower than many expected
CMS's June 2026 rule requires medically frail applicants to show both a qualifying condition and that the condition actually impairs their ability to work — a two-part test that's stricter than the statute's original language suggested. States are still building the specific diagnosis lists and documentation standards used to evaluate this, so requirements can vary by state. If you think you may qualify, ask your state Medicaid agency directly rather than assuming you're automatically covered.
| Who | Why they're exempt |
|---|---|
| Children and teens | Anyone under age 19 |
| Pregnant and postpartum people | Includes the 12-month postpartum coverage period now offered in every state |
| People with Medicare | Anyone entitled to or enrolled in Medicare Part A, or enrolled in Part B — this covers dual eligibles |
| Medically frail individuals | Blind or disabled, a substance use disorder, a disabling mental disorder, a physical/intellectual/developmental disability, or a serious or complex medical condition — and can show the condition limits their ability to meet the requirement |
| Caregivers | A parent, guardian, or family caregiver of a child age 13 or under, or of a person with a disability |
| Former foster youth | Under age 26, aged out of foster care while enrolled in Medicaid |
| Recently incarcerated people | Currently incarcerated, or released within the past 3 months |
| Disabled veterans | A VA disability rating of "total" under federal law |
| People already meeting SNAP or TANF work rules | No duplicate compliance is required |
| People in a qualifying substance use disorder treatment program | Program must meet SNAP-related federal standards |
| Indian Health Service-eligible individuals | Enrolled American Indian or Alaska Native individuals eligible for IHS services |
Children and teens
- Why they're exempt
- Anyone under age 19
Pregnant and postpartum people
- Why they're exempt
- Includes the 12-month postpartum coverage period now offered in every state
People with Medicare
- Why they're exempt
- Anyone entitled to or enrolled in Medicare Part A, or enrolled in Part B — this covers dual eligibles
Medically frail individuals
- Why they're exempt
- Blind or disabled, a substance use disorder, a disabling mental disorder, a physical/intellectual/developmental disability, or a serious or complex medical condition — and can show the condition limits their ability to meet the requirement
Caregivers
- Why they're exempt
- A parent, guardian, or family caregiver of a child age 13 or under, or of a person with a disability
Former foster youth
- Why they're exempt
- Under age 26, aged out of foster care while enrolled in Medicaid
Recently incarcerated people
- Why they're exempt
- Currently incarcerated, or released within the past 3 months
Disabled veterans
- Why they're exempt
- A VA disability rating of "total" under federal law
People already meeting SNAP or TANF work rules
- Why they're exempt
- No duplicate compliance is required
People in a qualifying substance use disorder treatment program
- Why they're exempt
- Program must meet SNAP-related federal standards
Indian Health Service-eligible individuals
- Why they're exempt
- Enrolled American Indian or Alaska Native individuals eligible for IHS services
Short-term hardship exceptions states can (but don't have to) offer
Separately from the exemption categories above, states have the option — but are not required — to grant temporary hardship exceptions. A state that adopts this option must offer all four categories together; it can't pick and choose.
- Living in a county under a federal disaster or emergency declaration
- Living in a county with an unemployment rate of at least 8%, or one that's below 8% but at least 1.5 times the national average
- Receiving care in a hospital, nursing facility, psychiatric facility, or similar inpatient setting
- You or a dependent must travel away from home for extended medical care
How compliance gets verified
When you apply, the state looks back at a period of 1 to 3 months immediately before your application month to check whether you met the requirement. Once enrolled, the state has to verify compliance for at least 1 month within every 6-month renewal cycle — some states may choose to check more often.
States are required to check their own data first — payroll records, SNAP or TANF case files, Medicaid claims and encounter data — before asking you for anything. If that data confirms you're compliant or exempt, you won't hear about it beyond a routine notice.
A documentation cliff is coming in 2028
Through the end of 2027, simply telling your state you worked, went to school, or qualify for an exemption (self-attestation) is generally enough. Starting January 1, 2028, if your state's own data can't confirm your status, it will generally have to require actual documentation — pay stubs, a school enrollment letter, a program record — before that changes. (Medically frail individuals and people with a mandatory exception are treated a bit more leniently.) It's worth keeping records of your hours or enrollment now, even if your state doesn't ask for them yet.
What happens if you fall short a month
If the state can't verify that you met the requirement or qualify for an exemption, it must send you a written "notice of non-compliance" — by mail, plus at least one other method such as text, email, or your online account.
-
1
Read the notice right away
The 30-day clock generally starts when the notice is sent, not when you open it.
-
2
Check exactly what wasn't verified
The notice should say whether it's a missing activity, missing hours, or an exemption the state couldn't confirm.
-
3
Submit proof
Pay stubs, a school or training enrollment record, or documentation supporting an exemption — through whatever method your state allows (online portal, mail, phone, or in person).
-
4
Confirm it was received
Save a confirmation number, portal screenshot, or certified mail receipt.
You have 30 days from the notice to show you're compliant or exempt. If you don't, your coverage is terminated.
If your coverage is terminated for non-compliance
A termination for a work-requirement issue carries the same fair-hearing rights as any other Medicaid termination. You can request a hearing within the deadline printed on your termination notice, and in most states, filing before your coverage actually ends lets you keep receiving benefits while the appeal is pending.
For the full appeal process — deadlines, what to bring to a hearing, and what happens if you were terminated by mistake — see our guide on Medicaid Renewal, which covers termination appeals in depth.
Already meeting SNAP or TANF work rules? You're covered
If you're already complying with work requirements for SNAP (food assistance) or TANF (cash assistance), you're specifically excluded from having to prove Medicaid compliance separately — the two systems aren't supposed to make you document the same hours twice. If you're not enrolled in either program, though, this exclusion doesn't apply to you by default; you'd still need to meet the Medicaid requirement on its own terms.
State-by-state implementation timeline
The federal deadline is January 1, 2027, but a handful of states are enforcing work requirements earlier through a state plan amendment, and one state already has a separate waiver in place. States that can show a good-faith effort but aren't ready by the deadline may get an extension from HHS, to no later than December 31, 2028.
| State | Status |
|---|---|
| Nebraska | Live since May 1, 2026 — the first state to enforce the federal requirement, via a state plan amendment |
| Montana | Enforcement began July 1, 2026 |
| Arkansas | A "soft launch" started July 1, 2026 — compliance is being tracked, but no one is being disenrolled for non-compliance before January 1, 2027 |
| Iowa | Enforcement begins December 1, 2026 |
| Georgia | Already enforcing work requirements under a separate 1115 waiver in place since 2023; must transition to the federal rule by January 1, 2027 when that waiver expires |
| Every other required state | Must begin enforcement no later than January 1, 2027, unless granted a good-faith extension |
Nebraska
- Status
- Live since May 1, 2026 — the first state to enforce the federal requirement, via a state plan amendment
Montana
- Status
- Enforcement began July 1, 2026
Arkansas
- Status
- A "soft launch" started July 1, 2026 — compliance is being tracked, but no one is being disenrolled for non-compliance before January 1, 2027
Iowa
- Status
- Enforcement begins December 1, 2026
Georgia
- Status
- Already enforcing work requirements under a separate 1115 waiver in place since 2023; must transition to the federal rule by January 1, 2027 when that waiver expires
Every other required state
- Status
- Must begin enforcement no later than January 1, 2027, unless granted a good-faith extension
Frequently asked questions
Does this affect Medicare, or people who have both Medicare and Medicaid?
No. Anyone entitled to or enrolled in Medicare Part A, or enrolled in Part B, is specifically exempt. The requirement targets the Medicaid expansion population, not dual eligibles, and Medicare itself has no work requirement of its own.
Does this apply to children or CHIP?
No. The requirement only applies to adults ages 19–64 covered through Medicaid expansion or certain 1115 waiver groups. Children and CHIP enrollees are not affected.
I'm pregnant — do I have to comply?
No. Pregnant and postpartum individuals — including through the 12-month postpartum coverage period now offered in every state — are specifically excluded from the requirement.
What if I can't find 80 hours of paid work?
The requirement counts more than a paid job — school, job training, and community service all qualify, and you can combine activities to reach 80 hours. If none of that is realistic because of a health condition, ask your state Medicaid agency about the medically frail exemption.
Can I just tell my state I'm complying, or do I need proof?
Through the end of 2027, self-attestation is generally allowed. Starting January 1, 2028, if your state's own data can't confirm your status, you'll generally need to show documentation — so it's worth keeping records now.
What happens if I miss a compliance check?
You'll get a notice of non-compliance and 30 days to show you're compliant or exempt before your coverage ends. If it's terminated, you have the right to request a fair hearing.
States mentioned in this guide
Medicaid rules vary by state
Find your state's specific income limits, application steps, and covered benefits.
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