Medicaid work requirements: who they apply to and what starts in 2027

What the law says

A federal budget law signed on July 4, 2025, Public Law 119-21, created the first nationwide work requirement for Medicaid. The law is often called the One Big Beautiful Bill Act, and CMS refers to it as the Working Families Tax Cut legislation. The law calls the rule a "community engagement" requirement.

Under it, certain adults must show they work, volunteer, go to school or take part in a work program for at least 80 hours a month to get or keep Medicaid, unless they qualify for an exemption. CMS issued an interim final rule on June 1, 2026, that explains how states must carry it out.

Who it applies to

The requirement applies to adults ages 19 through 64 who get Medicaid through the Affordable Care Act's expansion group. That's the group that covers low-income adults who don't qualify through pregnancy, disability, age or caring for children. It also applies to similar groups that some states cover through special waivers. CMS has identified such groups in eight states: Georgia, Hawaii, Massachusetts, New York, Oregon, Tennessee, Utah and Wisconsin.

It does not apply to people who get Medicaid because they are 65 or older, have a disability that qualifies them in another Medicaid group, are pregnant, or are children. It also does not apply to people enrolled in Medicare.

How to meet the requirement

You can meet the 80 hours a month in any of these ways, or by combining them:

• Working for pay.
• Doing community service or volunteer work.
• Taking part in a work program, such as job training.
• Going to school at least half-time.
• Earning at least what 80 hours at the federal minimum wage would pay, which works out to $580 a month. Seasonal workers can use an average of their income over six months.

Who is exempt

The law lists groups that don't have to meet the requirement. According to CMS, they include:

• Parents and caregivers of a child age 13 or younger, or of a person with a disability.
• People who are pregnant or postpartum.
• People who are "medically frail," which can include people with serious or complex medical conditions, disabilities, or substance use disorders.
• Veterans with a total (100%) disability rating.
• Former foster youth, and most American Indians and Alaska Natives.
• People already meeting the work rules for SNAP or TANF, and people in a substance use disorder treatment program.
• People released from jail or prison within the past three months.

Short-term hardship exceptions

States may also excuse people for a short time during a hardship. Examples include a hospital stay or similar inpatient care, living in an area under a federal disaster declaration, living in a county with high unemployment, or having to travel far for specialized medical care. Ask your state Medicaid agency whether it offers these exceptions.

When it starts and how it's checked

States must begin the requirement no later than January 1, 2027. States may start earlier, and CMS says Nebraska already has. KFF reports that Montana and Iowa also planned to start before 2027, and Georgia has run its own work requirement program under a waiver. The federal government can give a state more time if it shows a good-faith effort to comply, but no later than December 31, 2028.

States will check compliance when you apply and when you renew. When you apply, a state can look back one to three months. Adults in the expansion group will also have their eligibility renewed every six months instead of once a year. States must first try to confirm your hours using data they can already check, such as work records, so some people may not need to send paperwork.

If the state can't confirm you meet the rule, it must send you a notice and give you 30 days to respond. If you don't show you comply or are exempt, and you don't qualify for Medicaid another way, your coverage can be denied or ended. You keep the right to ask for a fair hearing.

Legal challenges and open questions

As of late October 2026, the requirement is still scheduled to begin in most states on January 1, 2027. Parts of how it will work are being challenged in court. In a case brought by 25 states and the District of Columbia, a federal judge on July 29, 2026 declined to temporarily block parts of CMS's rule, while setting a faster schedule to decide the case on its merits before the January 1 start. The court's final decision, and any other lawsuits, could change how the rule works, so check with your state.

There is also a link to the Marketplace. Starting in 2027, people who are denied or lose Medicaid only because they did not meet the work requirement can't get a premium tax credit for a Marketplace plan.

What enrollees can do now

If you're an adult with Medicaid through the expansion group, these steps can help you avoid losing coverage by mistake:

• Update your mailing address, phone number and email with your state Medicaid agency, and open every letter from it.
• If you think you're exempt, such as being a parent of a young child or having a serious health condition, tell your state and ask what proof it needs.
• Keep pay stubs, school enrollment records, or volunteer hour logs in one place.
• If you get a notice saying your hours couldn't be verified, respond within the 30 days.
• If your coverage is ended and you disagree, ask for a fair hearing right away.

Where to get free help

Your state Medicaid agency is the official source for how the rule works where you live. You can find it through Medicaid.gov. Local legal aid offices, community health centers and Navigators, reachable at localhelp.healthcare.gov or 1-800-318-2596, can also help you understand your options.