A new federal law now requires many Medicaid enrollees to work, volunteer, or go to school to keep their coverage. If you are on Medicaid through the expansion program, this affects you.
Here is what is happening, whether you are affected, and exactly what to do.
What Changed
On July 4, 2025, the "One Big Beautiful Bill Act" was signed into law. (Source: ASTHO) For the first time, there is a national Medicaid work requirement. Before this law, no federal rule required Medicaid enrollees to work. Now one does.
The requirement: You must complete 80 hours per month of qualifying activities. That is about 20 hours a week. Qualifying activities include:
- Working at a job (full-time, part-time, or self-employment)
- Volunteering or community service
- Job training or a work program
- Going to school at least half-time
The timeline:
| When | What Happens |
|---|---|
| June 1, 2026 | HHS publishes detailed rules for how this works |
| June 30 -- August 31, 2026 | Your state sends outreach letters to affected enrollees |
| January 1, 2027 | Requirements take effect |
| Up to December 31, 2028 | States showing good-faith effort may get an extension |
(Source: KFF)
Am I Affected?
You are subject to the new requirements if all three are true:
- You are between ages 19 and 64
- You are enrolled in Medicaid through expansion coverage (not traditional/legacy Medicaid)
- You live in a state that expanded Medicaid (41 states plus Washington, D.C.)
About 20 million people are enrolled in expansion Medicaid. The Congressional Budget Office estimates 18.5 million will be subject to the requirements each year. (Source: KFF)
If your state has not expanded Medicaid, these requirements generally do not apply to you. Ten states have not adopted full ACA expansion: Alabama, Florida, Georgia, Kansas, Mississippi, South Carolina, Tennessee, Texas, Wisconsin, and Wyoming.
Important exception: Wisconsin and Georgia operate partial Medicaid expansion programs under federal waivers. If you are enrolled in Wisconsin's BadgerCare or Georgia's Pathways to Coverage, you are subject to the new work requirements even though your state has not adopted full ACA expansion.
If you are on traditional Medicaid (for example, because of a disability, pregnancy, or very low income before the expansion), these requirements do not apply to you either.
Am I Exempt?
Even if you are in the affected group, you may qualify for an exemption. The law creates nine mandatory categories that states must honor. You are exempt if you are:
- A parent or caretaker of a child age 13 and under, or of a person with disabilities — this includes families caring for a disabled child at home, even if you are working part-time
- Pregnant or recently gave birth -- this includes the full 12-month postpartum period
- Medically frail -- this covers blindness, disability, intellectual or developmental disabilities, substance use disorder, disabling mental health conditions, or serious and complex medical conditions
- A former foster youth under age 26
- An American Indian or Alaska Native eligible for Indian Health Service
- A disabled veteran
- Already meeting work requirements through TANF (cash assistance) or SNAP (food assistance) -- you do not have to prove it twice
- In treatment for a substance use disorder
- Recently released from incarceration -- within 3 months of release
States can also grant hardship exceptions beyond these categories. Watch for your state's specific rules once they are published.
(Source: CHCS)
Here is the part that matters most: KFF found that 92% of non-disabled Medicaid adults already work or have a qualifying reason for not working -- caregiving, illness, disability, or school. (Source: KFF) The real risk is not the work requirement itself. It is the paperwork.
What Happens If I Do Not Comply
This section is critical. Read it carefully.
Step 1: Notice. If the state determines you are not meeting the requirement, they must send you a non-compliance notice.
Step 2: 30-day cure period. You get 30 days to fix the problem -- submit documentation, start qualifying activities, or prove you are exempt.
Step 3: Disenrollment. If you do not fix it within 30 days, your Medicaid coverage ends by the end of the following month.
Step 4: Re-enrollment is not automatic. If you lose coverage, you must submit a full new Medicaid application. You are not simply reinstated. This means new paperwork, new income verification, and potential gaps in coverage.
The Premium Tax Credit Trap
This is the single most important thing in this article.
If you lose Medicaid because you did not meet the work requirement, you are not eligible for premium tax credits on the ACA marketplace. (Source: KFF)
That means you cannot fall back on a subsidized marketplace plan. You would have to pay full price for ACA coverage -- or go uninsured. For most people on Medicaid, full-price ACA coverage is not affordable. For a sense of what those premiums look like, see our guide to ACA premiums in 2026.
Do not assume there is a safety net under the safety net. There is not.
What Arkansas Taught Us
Arkansas was the only state to fully implement Medicaid work requirements before this law. The results were not encouraging.
Between 2018 and 2019, approximately 18,000 people -- about 25% of those subject to the requirement -- lost their Medicaid coverage. A study published in the New England Journal of Medicine found that the work requirement led to significant coverage losses but no measurable increase in employment. (Source: NEJM)
The problem was not that people refused to work. Most already were working. The problem was that people did not know about the reporting requirement, could not figure out the online portal, or missed paperwork deadlines. (Source: Health Affairs)
One improvement in the new law: states must use available data -- payroll records, SNAP work verification, TANF records -- to automatically verify compliance before asking you for documentation. This is better than the Arkansas model. But it does not eliminate the paperwork risk entirely.
The CBO projects that by 2034, 5.2 million people will lose Medicaid coverage under the new requirements, and 4.8 million will become uninsured. The difference shifts to other coverage, though likely at a higher cost. These requirements account for $326 billion in projected Medicaid savings over ten years. (Source: KFF)
What to Do Right Now
- Check if you are exempt. Review the nine categories above. If any apply to you, gather documentation now -- a child's birth certificate, a doctor's letter, school enrollment records.
- Watch your mail starting June 2026. States must send outreach letters between June 30 and August 31, 2026. Do not ignore anything from your state Medicaid office.
- Update your contact information with your state Medicaid agency. If they cannot reach you, you cannot respond to non-compliance notices.
- Keep records of your qualifying activities. Save pay stubs if you work. Get a letter from the organization if you volunteer. Keep enrollment verification if you are in school.
- Know your state's rules. The federal law sets the floor, but states may add hardship exceptions or differ on details. Check your state Medicaid website once rules are published in mid-2026.
- Do not wait for a non-compliance notice to act. By the time you get one, you have only 30 days to fix the problem.
- If you lose coverage, you will need to file a full new Medicaid application. Know your healthcare coverage options and what to do if you cannot afford a medical bill.
Frequently Asked Questions
Sources & Additional Resources
This article is for educational purposes only and does not constitute legal advice. Medicaid rules vary by state. Contact your state Medicaid office or a local navigator for help with your specific situation.
