Medicaid Work Requirements 2027: Do They Apply to You?

Last checked: November 2026. Rules described here apply starting in 2027 unless a date says otherwise.

Starting no later than January 1, 2027, the Medicaid work requirement applies only to adults ages 19 through 64 who get Medicaid through the ACA expansion "adult group" or through certain state waiver programs, and who aren't pregnant and don't have Medicare. Many of those adults are exempt, including parents and caretakers of a child 13 or younger, people who are pregnant or postpartum, people who are medically frail, and American Indians and Alaska Natives. If the rule does apply to you, you'll need 80 hours a month of work, community service, a work program, or a mix of these, or half-time school enrollment, or monthly income of at least $580 (80 times the federal minimum wage). Your state checks when you apply and when you renew.

Use the steps below to work out where you fit. Each step tells you where to go next.

The short answer

The requirement comes from Section 71119 of Public Law 119-21, the 2025 budget law. Medicaid.gov explains that beginning January 1, 2027, states must make "community engagement" a condition of Medicaid eligibility for the people the law targets, unless a state chooses to start sooner. CMS put the details into an interim final rule published in the Federal Register on June 3, 2026, effective July 31, 2026. "Interim final" means the rule is in force now but CMS can still revise it.

According to the CMS fact sheet on the rule, 43 states and the District of Columbia cover people in the affected groups and must carry out the requirement. U.S. territories aren't subject to it.

For people already enrolled, the rule says the state checks compliance at your first renewal that starts on or after your state's start date. So January 1, 2027 isn't the day everyone has to send proof. Your renewal month matters more.

Step 1: Are you in the group the rule covers?

Medicaid expansion adults vs. other Medicaid categories

Under the rule, you're an "applicable individual" only if you're eligible for or enrolled in the ACA adult group (or a covered waiver group) and you're:

at least 19 and under 65,
not pregnant,
not entitled to or enrolled in Medicare Part A, and not enrolled in Part B, and
not eligible for any other Medicaid category in your state.

That last point matters. If you qualify for Medicaid as a child, as a pregnant person, as a parent or caretaker under your state's parent category, through SSI or another disability category, or as an older adult, you aren't in the target group. Children's Medicaid and CHIP aren't affected.

Not in the adult group or a covered waiver group? The requirement doesn't apply to you. You can stop here, but keep reading your mail, because states have to screen people and send notices. In the adult group? Go to Step 2.

If your state never expanded Medicaid

If your state didn't adopt the ACA expansion and has no affected waiver group, it has no one the rule targets. A few states that never expanded do have waiver groups that count. Wisconsin is one: its Department of Health Services says the rule applies to BadgerCare Plus members ages 19 to 64 who aren't pregnant and don't have a dependent child living with them at least 40% of the time. In Georgia, CMS's rule notes that the state already runs its own work-linked program for some adults through a Section 1115 waiver.

Not sure whether your state is one of the 44 jurisdictions? Your state Medicaid agency's website or member services line can tell you whether your coverage group is subject to the rule.

States that started before 2027

States may start early. Nebraska did. The Nebraska Department of Health and Human Services says its work requirement began May 1, 2026 for Medicaid expansion members and applicants. It started checking members whose coverage periods ended on or after July 31, 2026, and members with May or June 2026 renewal dates won't be checked until their 2027 renewal. If you live in a different state, look at your state Medicaid agency's site for its start date, since other states could also start early.

Step 2: Check the exemptions first

Exemptions written into federal law

CMS lists these groups as exempt (the rule calls them "specified excluded individuals"). If any one fits you, you don't have to show hours:

Former foster care youth who meet your state's former foster care group definition (generally under age 26).
American Indians and Alaska Natives, as defined in Medicaid rules.
Parents, guardians, caretaker relatives, or family caregivers of a child 13 or younger, or of a person with a disability. The disabled person doesn't need to be on Medicaid or any disability program.
Veterans with a VA disability rating of 100% (total), temporary or permanent.
People who are medically frail or have special medical needs. This includes people who are blind or disabled, people with a substance use disorder (unless in stable recovery for 5 or more years), people with a disabling mental disorder, people with a physical, intellectual, or developmental disability that significantly impairs one or more activities of daily living, and people with a serious or complex medical condition.
People meeting TANF work requirements.
Members of a household getting SNAP who are not exempt from SNAP's work requirements.
People in a drug or alcohol treatment and rehabilitation program. States may set a minimum time commitment.
People who are inmates of a public institution.
People who are pregnant or getting postpartum coverage.

Separately, you're treated as meeting the requirement for a month if, for any part of that month, you were under 19, had Medicare, or were eligible for another mandatory Medicaid group. You're also treated as meeting it if you were an inmate of a public institution at any point in the three months before that month.

About "medically frail": CMS's rule also required that your condition "significantly impairs" your ability to comply. On October 29, 2026, a federal district court in Massachusetts ruled that this extra test was contrary to law. The court struck that language from the rule, permanently barred its enforcement, and gave the plaintiff states about six months, to late April 2027, during which CMS can't penalize them over how they handle these determinations. The court also said its order doesn't change the January 1, 2027 deadline. CMS has said publicly that it plans to appeal, and the ruling stays in effect unless a court pauses it. If you believe you're medically frail, tell your state and ask how it's handling these determinations now.

Short-term hardship exceptions your state may offer

States can choose to excuse you for a month if you:

received inpatient hospital care, nursing facility care, or similar high-level care,
live in a county under a presidential emergency or disaster declaration,
live in a county where unemployment is at or above 8%, or at or above 1.5 times the national rate, whichever is lower (the state has to ask CMS to approve this), or
had to travel outside your community for an extended time for medical care for a serious or complex condition, for yourself or a dependent.

For the county-based hardships, the state can't make you file a request. For the medical ones, you usually have to ask. Nebraska shows how this works: its DHHS page lists counties under temporary hardship exemptions and says it reprocesses cases for people in those counties without them taking any action.

How to show you're exempt

Under the rule, your state must first check the data it already has before asking you for anything. That includes its own case records, payroll data, other state agencies, and your Medicaid claims from the past 12 months. Only if that doesn't settle it can the state ask you for more. Until January 1, 2028, states may accept other information in place of documents. After that date, they must require documents whenever documents are reasonably available. Even then, a state can't deny you just because no document exists.

Exempt? Watch for a notice confirming it, and go to "What to do this month" below. Not exempt? Go to Step 3.

Step 3: If you're not exempt, what counts toward 80 hours

Work, self-employment, and gig work

The rule defines work broadly. It covers paid work, work in exchange for goods or services (like a building superintendent who gets reduced rent), and unpaid work. In its explanation of the rule, CMS says self-employment, owning a business, and independent contracting all count as work. That includes rideshare, delivery, and other app-based jobs.

Community service, work programs, and school

Community service means unpaid work through a structured program run by a public or nonprofit organization. The organization must oversee the activity and track your dates and hours, with a contact person who can confirm them. Partisan activity doesn't count.
Work programs include WIOA job training programs, Trade Act programs, state-approved employment and training programs (including SNAP Employment and Training), and VA or Labor Department programs for veterans. Supervised job search counts only as a smaller part of a program, not by itself.
School counts on its own if you're enrolled at least half-time, as your school defines it, in college, career and technical education, high school, or a state-approved high school equivalency program. Your status carries through normal breaks.

The earnings route

You also meet the requirement for a month if your monthly income is at least the federal minimum wage times 80 hours. CMS puts that at $580 per month in 2026 ($7.25 × 80 = $580). Seasonal workers can instead use their average monthly income over the past six months.

Two details from the rule are easy to miss. First, states measure this income using Medicaid's MAGI rules, and CMS says that means income for your MAGI household, not just your own paycheck. Second, MAGI follows tax rules, so self-employment income is generally counted as net profit after business expenses. HealthCare.gov describes the same approach for Marketplace applications. Ask your state how it will count gig income before you rely on this route.

Mixing activities in one month

You can add work, community service, and work program hours together to reach 80. If you're in school less than half-time, those school hours can be added in too. For credit-based programs, the rule counts each credit hour as 3 hours a week, times 4.33 weeks. One 3-credit class counts as about 39 hours a month (3 × 3 × 4.33 ≈ 39).

Step 4: When your state checks: application, renewal, and look-back months

When you apply: your state looks at 1 to 3 consecutive months right before the month you apply. Each state picks the number. Nebraska and Wisconsin, for example, look at the month before you apply.
When you renew: you must have met the requirement in at least 1 month (your state can require more) between your last approval and your renewal. Wisconsin says it will check whether you met the requirement in one month since you were last approved, and that current members won't face the check until their next renewal, starting March 2027.
Between renewals: states may choose to check more often.

Renewals are also changing. CMS's rule reminds states that starting January 1, 2027, most adults in the expansion group will renew every 6 months instead of every 12. American Indians and most waiver-group enrollees stay on 12-month renewals.

What happens if the state says you didn't comply

You get a notice of noncompliance. It must tell you which months are being reviewed, how to show you met the requirement or are exempt, the deadline, how to send information, and what happens if you don't respond.
You have 30 calendar days to respond. The clock starts when you receive the notice. The rule treats a notice as received 5 days after the date printed on it unless you show otherwise. If you're enrolled, your coverage continues during this period.
If you don't show compliance, the state must check whether you qualify for Medicaid some other way. If you don't, it must send advance written notice with fair hearing rights. It can then deny the application, or end coverage no later than the end of the month after the month your 30 days ran out.
You can reapply at any time. The state can't add waiting periods or other limits because of a past denial for this reason.

There's a Marketplace catch. HealthCare.gov says that if you lost or were denied Medicaid because you didn't meet your state's work requirement, you may be able to get Marketplace coverage, but you won't qualify for savings to lower the cost of your plan.

Four example situations

These are hypothetical people, not real cases. Figures use the 2026 amount CMS published.

Example 1: A 34-year-old rideshare driver in an expansion state, no kids

She drives about 15 hours a week. Monthly hours: 15 × 52 weeks ÷ 12 months = 65 hours. That's 15 short of 80.

Option A is to add hours. If she volunteers 15 hours a month with a nonprofit program that logs her hours, she reaches 65 + 15 = 80. Option B is the earnings route, which needs at least $7.25 × 80 = $580 in monthly MAGI-based household income. Say her app shows $900 in payouts for the month and $420 in mileage and other business costs. Her net self-employment income is $900 − $420 = $480. On her own, that's below $580, so the earnings route alone may not work unless other household income counts toward it. Either way, she should keep the app's trip logs, which show her hours, along with weekly earnings statements.

Example 2: A 41-year-old parent whose youngest child is 10

A parent or caretaker of a child 13 or younger is exempt. He should make sure his state's records show the child living with him, and check his approval notice to confirm the exemption is listed. The exemption is tied to the child's age. Once his youngest turns 14, he would need another exemption or would have to meet the requirement.

Example 3: A 45-year-old on SNAP who has to follow SNAP's work rules

If she lives in a SNAP household and isn't exempt from SNAP's work requirements, she's excluded from the Medicaid requirement. Note how this is worded: a SNAP household member who is exempt from SNAP's work rules doesn't get this particular exclusion and would need a different one, or would need to meet the 80 hours.

Example 4: A 30-year-old in a state that never expanded Medicaid

If his state has no expansion group and no affected waiver group, there's nothing for the rule to attach to. He likely doesn't have Medicaid as a childless adult in the first place. If he's on Medicaid through another category, such as disability, that category isn't the target. HealthCare.gov says adults in non-expansion states with income below the poverty level may fall into a coverage gap. It still recommends filling out a Marketplace application and points to community health centers that charge on a sliding scale.

What to do this month

Update your contact information with your state Medicaid agency: mailing address, phone, and email. Nebraska's DHHS, for one, says the most important thing is to check your mail, email, and texts in case it asks for information.
Find your renewal month. That's usually when your first check happens.
Tell your state about any exemption you think applies, such as a child 13 or under, pregnancy, a health condition, caregiving, or SUD treatment, so it shows up in their records.
Keep proof of hours and income: pay stubs, gig app earnings and trip logs, and school enrollment records.
For volunteering, use a program that tracks dates and hours and has a contact person who can confirm them.
Respond to any notice within 30 days, and use any submission method listed: online, phone, mail, or in person.

FAQ

Does gig work or self-employment count toward the 80 hours?

Yes. CMS says independent contractors and self-employed people meet the rule's definition of work, so hours spent driving, delivering, or running a small business count. If you use the $580 income route instead, states count income under MAGI rules, which for self-employment generally means profit after expenses. Keep records of both hours and earnings.

If I lose Medicaid for not meeting the requirement, can I reapply right away?

Yes. The rule bars states from restricting reapplication because of a past denial or disenrollment for noncompliance. When you reapply, the state will look at your activity in the month or months right before you apply. If you send the missing information during your state's reconsideration period after disenrollment, the state must reconsider your eligibility.

Do the work requirements apply to my children or to people on Medicare?

No. The requirement covers adults 19 through 64, so children aren't subject to it. Anyone entitled to or enrolled in Medicare Part A, or enrolled in Part B, is outside the group the rule covers.

AidPlain builds every post from official agency pages and law text; you can read how we source and check information. Sources for this article: CMS, Medicaid.gov, the Federal Register, HealthCare.gov, the Nebraska and Wisconsin Medicaid agencies, and the October 29, 2026 court opinion in Massachusetts v. Oz.

This article is general information, not legal or tax advice. Your state Medicaid agency decides eligibility and exemptions; check with them or a qualified professional for your situation. See our Disclaimer.