Starting January 1, 2027, Medicaid expansion enrollees ages 19 to 64 in all 41 expansion states must complete at least 80 hours per month of work, education, job training, or community service to keep their coverage. Some states, like Nebraska, are enforcing these requirements as early as May 2026. The new federal mandate was signed into law on July 4, 2025 as part of the budget reconciliation package (H.R. 1), and the Congressional Budget Office estimates it will affect 18.5 million people annually. Use our free benefits screener to check your current eligibility and find out if you qualify for an exemption.
What Are the New Medicaid Work Requirements?
The 2025 budget reconciliation law introduced the first ever federal Medicaid work requirements. Previously, only a handful of states had attempted work requirements through individual waivers. Now, all states with Medicaid expansion must enforce them.
To maintain Medicaid coverage, non-exempt adults ages 19 to 64 enrolled through Medicaid expansion must verify at least 80 hours per month of qualifying activities:
| Qualifying Activity | Examples |
|---|---|
| Employment | Full-time, part-time, or self-employment |
| Work programs | Job training, vocational rehabilitation |
| Education | Enrolled at least half-time in a degree or certificate program |
| Community service | Volunteer work at qualifying organizations |
| Combination | Any mix of the above totaling 80 hours per month |
States must verify compliance at application and at renewal (at least every 6 months), though states can choose to verify more frequently.
Which States Are Implementing Medicaid Work Requirements Early?
While the federal deadline is January 1, 2027, states have the option to begin enforcement sooner. Several states are pursuing early implementation through 1115 demonstration waivers or state plan amendments.
| State | Implementation Status | Target Start Date |
|---|---|---|
| Nebraska | First state to announce early enforcement via state plan amendment | May 1, 2026 |
| Georgia | Pursuing work requirements through existing 1115 waiver | Before January 2027 |
| Arkansas | Previously implemented work requirements (2018-2019); preparing for federal mandate | January 2027 |
| All other expansion states (38 + DC) | Required to implement by federal deadline | January 1, 2027 |
| Non-expansion states (10) | Not affected (no expansion population) | N/A |
States that demonstrate a good faith effort but cannot meet the January 2027 deadline may request an extension from the HHS Secretary until December 31, 2028.
Who Is Exempt from Medicaid Work Requirements?
The law includes several exemption categories. If you fall into any of these groups, you are not required to meet the 80-hour monthly threshold:
| Exemption Category | Details |
|---|---|
| Pregnant individuals | Exempt during pregnancy |
| Medically frail individuals | Includes people who are blind, disabled, have a substance use disorder, disabling mental disorder, or serious medical condition |
| Caregivers | Parents, guardians, or family caregivers of a dependent child age 13 or under, or a disabled individual |
| Foster care youth | Current or former foster youth under age 26 |
| American Indians and Alaska Natives | Individuals eligible for Indian Health Service |
| Disabled veterans | Veterans with a total disability rating under Title 38 |
| Already meeting work requirements | People complying with TANF or SNAP work requirements |
| Full-time students | Enrolled at least half-time in education |
Not sure if you qualify for an exemption? Check your eligibility with our free screener to see what programs and protections apply to your situation.
What Are the Medicaid Income Limits for Expansion Adults in 2026?
Work requirements only apply to adults enrolled through Medicaid expansion. Here are the current income limits for Medicaid expansion eligibility:
| Household Size | Annual Income Limit (138% FPL, 2026) | Monthly Income Limit |
|---|---|---|
| 1 | $22,025 | $1,835 |
| 2 | $29,823 | $2,485 |
| 3 | $37,621 | $3,135 |
| 4 | $45,419 | $3,785 |
| 5 | $53,217 | $4,435 |
| 6 | $61,015 | $5,085 |
If your income is above these limits, you may qualify for subsidized Marketplace coverage instead. Use our screener to find the best option for your household.
What Happens If You Do Not Meet the Work Requirement?
Failing to meet or report the 80-hour monthly requirement has serious consequences under the new law:
- Coverage suspension or termination. States will suspend or end your Medicaid coverage if you do not verify compliance.
- No Marketplace subsidies. Unlike previous proposals, the law specifically bars people who lose Medicaid due to work requirements from receiving premium tax credits for ACA Marketplace coverage.
- Re-enrollment waiting periods. Re-enrolling after losing coverage may require demonstrating compliance for a period before coverage is restored. States may impose "look-back" periods to verify past compliance.
- Estimated impact. CBO projects that by 2034, approximately 5.2 million adults will lose Medicaid coverage due to work requirements, with 4.8 million becoming uninsured.
How to Prepare for Medicaid Work Requirements: Step by Step
Follow these steps now to protect your coverage before work requirements take effect in your state:
Step 1: Determine If You Are Affected
Work requirements apply only to Medicaid expansion enrollees ages 19 to 64. If you receive Medicaid through a traditional eligibility category (disability, pregnancy, parent of young children), you may be exempt. Check your status with our screener.
Step 2: Check If You Qualify for an Exemption
Review the exemption categories listed above. If you are a caregiver, have a medical condition, are a veteran with a disability rating, or fall into another exempt group, gather documentation to support your exemption claim.
Step 3: Document Your Qualifying Activities
If you are not exempt, begin tracking your monthly hours of work, education, training, or community service. Keep records of:
- Pay stubs or employer verification letters
- School enrollment verification
- Volunteer hour logs signed by the organization
- Job training program participation records
Step 4: Stay Current with Your State Medicaid Office
Each state will implement its own verification process and reporting system. Watch for communications from your state Medicaid agency about:
- How to report your hours (online portal, phone, or mail)
- Reporting deadlines and frequency
- What documentation is accepted
Step 5: Respond to All Notices Promptly
One of the biggest risks identified from Arkansas's earlier work requirement program is that many enrollees lost coverage simply because they were unaware of the requirement or found reporting too difficult. Open and respond to every piece of mail or electronic notice from your state Medicaid office immediately.
Step 6: Explore All Your Options
If you may lose Medicaid, explore other coverage options now. You may qualify for:
- Employer-sponsored health insurance
- SNAP, LIHEAP, or other assistance programs
- State-specific programs for low-income residents
Use our free benefits screener to see every program you may qualify for in one place.
Key Dates and Timeline for Medicaid Work Requirements
| Date | Milestone |
|---|---|
| July 4, 2025 | Budget reconciliation law (H.R. 1) signed, establishing federal work requirements |
| December 8, 2025 | CMS issued initial implementation guidance to states |
| May 1, 2026 | Nebraska begins early enforcement |
| June 1, 2026 | HHS required to issue interim final rule with detailed implementation standards |
| January 1, 2027 | Federal deadline for all expansion states to enforce work requirements |
| December 31, 2028 | Latest possible extension deadline for states showing good faith effort |
How Many People Will Be Affected by Medicaid Work Requirements?
The Congressional Budget Office estimates that approximately 18.5 million people will be subject to Medicaid work requirements each year. Currently, over 20 million adults are enrolled in Medicaid through the expansion population across 41 states (including DC).
Research from KFF shows that most Medicaid adults under 65 are already working or face significant barriers to employment, including caregiving responsibilities, health conditions, or disability. The CBO has stated that work requirements are unlikely to meaningfully increase the number of Medicaid enrollees who are working.
Frequently Asked Questions
Do Medicaid work requirements apply in every state?
Work requirements apply in all 41 states (plus DC) that have adopted Medicaid expansion. The 10 states that have not expanded Medicaid are not affected because they do not have an expansion population. However, Georgia and Wisconsin are also subject to work requirements through their waiver programs.
Can states make work requirements stricter than the federal minimum?
Yes. States can impose requirements beyond the federal minimum, including more frequent verification, longer look-back periods, or additional reporting steps. Each state will have some flexibility in how it designs and enforces its program.
What if I am already working but do not report my hours?
Even if you are working 80 or more hours per month, you must verify and report your activities through your state's designated process. Failure to report, regardless of actual work status, can result in loss of coverage.
Will I lose Medicaid immediately if I do not comply?
The exact process depends on your state's implementation plan. Generally, states must provide notice and an opportunity to come into compliance before terminating coverage. However, the timeline for reinstatement may vary.
Can I get ACA Marketplace coverage if I lose Medicaid due to work requirements?
No. The law specifically makes individuals who lose Medicaid due to work requirement noncompliance ineligible for premium tax credits on the ACA Marketplace. This is a significant change from previous proposals and means noncompliance could leave you without any affordable coverage option.
Where can I check my eligibility for Medicaid and other programs?
Use our free benefits screener to check your eligibility for Medicaid, SNAP, LIHEAP, ACA subsidies, and dozens of other programs in minutes. It covers all 50 states and accounts for your specific household situation.
