Beginning January 1, 2027, new federal Medicaid work requirements will apply to adults across the U.S. enrolled in Medicaid expansion programs.
You’ll also hear these requirements referred to as “Medicaid Community Engagement.” These requirements will require certain Medicaid recipients to participate in work, education, job training, or community service activities to maintain coverage.
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The new rules are part of the federal budget reconciliation bill (H.R.1) enacted in 2025. While implementation details will vary by state, the changes could affect eligibility and the stability of coverage for millions of Americans.
Understanding how Medicaid work requirements operate before they take effect can help prevent unexpected coverage disruptions.
Key Takeaways
- Beginning in 2027, many Medicaid expansion adults ages 19–64 must complete at least 80 hours per month of qualifying activities to maintain coverage.
- Many individuals will qualify for exemptions, including people with disabilities, caregivers, and pregnant individuals.
- States will verify compliance and may require documentation and reporting.
- Most Medicaid coverage losses historically occur because of paperwork and reporting failures.
- Understanding whether you are exempt, compliant, or subject to reporting requirements before 2027 can help protect your healthcare coverage.
- It’s essential to stay up to date on the most current information available from your state Medicaid agency.
What Is Changing Under the Medicaid Work Requirements?
Starting in 2027, certain adults enrolled in Medicaid will be required to demonstrate that they are working or participating in approved activities for at least 80 hours each month.
The new requirement applies primarily to adults receiving coverage through Medicaid expansion and certain 1115 Medicaid demonstration waiver programs. The Centers for Medicare & Medicaid Services (CMS) issued an interim final rule in June 2026 explaining how states must implement these new requirements.
States participating in Medicaid expansion generally must implement the rules by January 1, 2027, although some states may choose to begin earlier.
Who Is Subject to the New Medicaid Work Requirements?
Generally, the work requirement applies to adults who:
- Are between ages 19 and 64;
- Are not pregnant;
- Are not enrolled in Medicare; and
- Receive Medicaid through the adult Medicaid expansion program or certain 1115 Medicaid demonstration programs (or a combination of the two)
Not all Medicaid recipients will be affected. Some individuals will qualify for an exemption.
Who Is Exempt from the New Work Requirements?
Not everyone enrolled in Medicaid expansion will be subject to the 80-hour rule. Those who may qualify for an exemption include:
- Pregnant individuals and those receiving postpartum coverage;
- People who are disabled, medically frail, or have significant health limitations;
- Parents, guardians, or caregivers of children under age 14;
- Caregivers for individuals with disabilities;
- Former foster youth;
- American Indians and Alaska Natives;
- Certain veterans with a total disability rating;
- Individuals participating in substance abuse treatment or rehabilitation programs;
- Individuals already satisfying Temporary Assistance for Needy Families (TANF) work requirements; and
- Certain individuals who are incarcerated or were recently released.
Because exemption rules can be complex, you should carefully review state notices or seek qualified guidance if you are uncertain whether the requirement applies to you.
How Do I Meet the New Medicaid Work Requirements?
Those who are subject to the rule can satisfy the requirement in several ways.
For most people, this means completing at least 80 hours per month of one or more approved activities, including:
- Working for pay;
- Participating in approved job training or employment programs;
- Performing community service; or
- Attending school or another educational program at least half-time.
You may combine activities to meet the monthly requirement. In some situations, earnings alone may satisfy the requirement if federally established income thresholds are met.
Will I Have to Report My Activities?
Yes. States will be responsible for verifying compliance when you (1) first apply for Medicaid, (2) during annual renewals, and (3) potentially at additional intervals established by the state.
Your state must notify you if compliance cannot be verified and offer an opportunity to submit additional documentation.
What Happens If the State Cannot Verify Compliance?
If a state cannot confirm that you have met the requirement, you must receive notice and be given at least 30 days to provide additional information.
During that period, you may submit proof that you completed qualifying activities or demonstrate that you qualify for an exemption. If you do not respond or cannot establish eligibility, Medicaid coverage could be denied or terminated. Individuals who lose coverage due to noncompliance generally may reapply at any time.
Are There Temporary Hardship Exceptions?
States may choose to provide temporary hardship exceptions in certain circumstances, including hospitalization, intensive medical treatment, declared disasters, travel for specialized medical care, or periods of unusually high local unemployment. Because these exceptions are optional, availability may vary by state.
Which States Are Subject to Medicaid Work Requirements?
According to the CMS interim final rule, 43 states and the District of Columbia currently provide Medicaid expansion coverage and generally will be required to implement these new work requirements. U.S. territories are exempt.
At present, the following states are not required to implement Medicaid work requirements because they have not expanded Medicaid coverage:
- Alabama
- Florida
- Kansas
- Mississippi
- South Carolina
- Texas
- Wyoming
On June 23, 2026, U.S. health policy organization KFF published CMS’s list of states with 1115 waiver programs that include individuals subject to work requirements. The list identifies waiver programs in three non-expansion states, Georgia, Tennessee, and Wisconsin, as well as in five expansion states, Hawaii, Massachusetts, New York, Oregon, and Utah.
Because Medicaid policies continue to evolve, individuals should always review the most current information available from their state Medicaid agency.
Will the New Medicaid Rules Affect Non-Expansion States?
Families in non-expansion states should still remain informed. Federal Medicaid policy changes often influence future state-level decisions and may affect long-term planning for individuals with disabilities, chronic illnesses, or future long-term care needs.
Medicaid Planning, Health Care, and Elder Law Considerations
For states with expanded Medicaid, families have more flexibility to plan ahead to maintain coverage as income changes, without losing access to health care. This helps ensure that those with fluctuating incomes can maintain their Medicaid coverage as long as they stay below the income threshold.
For medically fragile adults, individuals with cognitive decline, family caregivers, and those living with chronic health conditions, proper exemption classification may be essential. Incorrect classification or missing documentation could result in the unnecessary termination of Medicaid coverage during a medical crisis. Planning ahead can help protect coverage and reduce risk.
In Texas and other states that have not expanded Medicaid coverage, Medicaid planning opportunities—such as for nursing home care and assisted living coverage—may be far more limited than in Medicaid expansion states. This often results in Texas Medicaid planning for long-term care being reactive (crisis mode) rather than proactive (planned).
Important: Medicaid expansion for working-age adults differs from long-term care Medicaid for seniors and individuals with disabilities. The 2027 work requirements primarily affect expansion coverage—including physician visits, hospital care, mental health services, and prescription medications—not traditional disability-based “nursing home” Medicaid.
Why Families in Every State Should Pay Attention Now
Medicaid is often misunderstood as a program people simply ‘end up on.’ In reality, Medicaid eligibility for working-age adults frequently depends on timing, documentation, proper classification, and compliance with state and federal rules.
As Medicaid work requirements take effect in 2027, administrative reporting will become increasingly important. Misclassification, missed notices, or paperwork failures could result in unnecessary coverage loss.
Don’t let coverage loss happen to you! Families should begin learning about these rules and reporting responsibilities now to avoid surprises later.
Get the Answers You Need Today
The public comment period for the CMS rule remains open through July 31, 2026, so additional guidance, administrative procedures, and implementation details may continue to evolve. As states prepare to implement these new requirements, staying informed will be essential. We’re here to help you stay ahead. Watch for additional Medicaid expansion updates as we release them.
Questions about Medicaid work requirements, exemption eligibility, or how these changes could affect your family?
Consider speaking with an attorney who focuses on Medicaid, disability, and estate law and benefits. Proactive planning can help you avoid unnecessary loss of coverage and protect access to essential medical care.
Sources:
- Centers for Medicare & Medicaid Services: Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC)
https://www.cms.gov/newsroom/fact-sheets/medicaid-community-engagement-requirement-certain-individuals-interim-final-rule-comment-period-cms - Federal Register; Medicaid Program; Community Engagement Requirement for Certain Individuals; A Rule by the Centers for Medicare & Medicaid Services on 06/03/2026
https://www.federalregister.gov/documents/2026/06/03/2026-11094/medicaid-program-community-engagement-requirement-for-certain-individuals - KFF: Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements; Updated on: Jun 23, 2026
https://www.kff.org/medicaid/medicaid-work-requirements-tracker-overview/
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