Medicaid Work Requirements: Who Is Covered and When They Start

Figures here are for general information. Wages, amounts and dates can change or differ from the official values. Always confirm them with the official state or federal agency before you rely on them.

A 2025 federal law (H.R. 1) requires some adults on Medicaid to show that they work, study or volunteer. The government calls this “community engagement.” Most states must start by January 1, 2027. This guide uses the rule that the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register on June 3, 2026.

The rule is an “interim final rule.” It took effect on July 31, 2026, and CMS accepted public comments until the same date. Your state also makes some choices, so check your state Medicaid agency for local details.

Key dates

Who is covered

The requirement applies to adults aged 19 through 64 in the Medicaid expansion adult group. The rule calls them “applicable individuals.” It also covers some adults in certain state waiver programs that give similar coverage.

What counts: the 80-hour standard

In a month, you show that you meet the requirement if you do any one of these:

• Work at least 80 hours.
• Do at least 80 hours of community service.
• Take part in a work program for at least 80 hours.
• Are enrolled in school at least half-time.
• Do a mix of work, community service and a work program that adds up to at least 80 hours.
• Earn at least the federal minimum wage times 80 hours in a month. The rule gives $580 a month as the figure.
• Work as a seasonal worker and average that much income over the last 6 months.

States must make all of these options available.

Who is exempt

Some people do not have to meet the requirement. The rule calls them “specified excluded individuals.” They include:

• Former foster care children who qualify under that Medicaid group.
• Pregnant women and women entitled to postpartum coverage.
• People who are medically frail or have special medical needs, as the rule defines.
• Parents and caretakers of a dependent child aged 13 or under.

The rule lists other groups too. Read the full rule or ask your state Medicaid agency to see if you are on the list.

States can also excuse a month for a short-term hardship. One example is a stay in a hospital or nursing facility.

How your state checks

When you apply, your state looks at your activity in the months before you applied. If you are already enrolled, the state checks it at renewal, and it can check more often if it chooses.

States must first try to confirm your activity with data they already have. They should not ask you for proof when they can avoid it.

If the state cannot confirm you meet the rule

The state must send you a notice of noncompliance. You then have 30 calendar days to show that you meet the rule or that it does not apply to you. The notice must tell you how to do this. How you report depends on your state, so follow the steps on your notice.

If you do not respond, the state can deny your application or end your coverage. You get notice and fair hearing rights.

If you get a notice, answer it right away. Use the phone number or website printed on it.

Can a state start early or late?

A state may start before January 1, 2027. A state that cannot be ready in time can ask CMS for a “good faith effort” exemption. CMS looks at each request on its own. A granted exemption ends no later than December 31, 2028.

Common questions

When do Medicaid work requirements start?

States must start no later than January 1, 2027. Some states may start earlier. A state with an approved exemption can start later, but no later than December 31, 2028.

How many hours do I need?

You need 80 hours a month of work, community service, a work program, or a mix. Being in school at least half-time also counts. So does earning at least the federal minimum wage times 80 hours.

Who has to meet the requirement?

Adults aged 19 through 64 in the Medicaid expansion adult group, unless an exclusion applies.

What if I am a caregiver?

The rule excludes parents and caretakers of a dependent child aged 13 or under. Check the rule or your state for other caregiver cases.

What if I lose coverage?

The state must send a notice and give you 30 calendar days to respond first. You also have fair hearing rights.

Sources

• Centers for Medicare & Medicaid Services, “Medicaid Program; Community Engagement Requirement for Certain Individuals,” Federal Register, June 3, 2026