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Patient Rights
May 10, 26
8 min read

Medicaid Work Requirements: What Enrollees Need to Know

New Medicaid work requirements take effect January 1, 2027. Learn who must comply, who is exempt, and what to do now to keep your coverage.

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:

WhenWhat Happens
June 1, 2026HHS publishes detailed rules for how this works
June 30 -- August 31, 2026Your state sends outreach letters to affected enrollees
January 1, 2027Requirements take effect
Up to December 31, 2028States 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:

  1. You are between ages 19 and 64
  2. You are enrolled in Medicaid through expansion coverage (not traditional/legacy Medicaid)
  3. 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:

  1. 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
  2. Pregnant or recently gave birth -- this includes the full 12-month postpartum period
  3. Medically frail -- this covers blindness, disability, intellectual or developmental disabilities, substance use disorder, disabling mental health conditions, or serious and complex medical conditions
  4. A former foster youth under age 26
  5. An American Indian or Alaska Native eligible for Indian Health Service
  6. A disabled veteran
  7. Already meeting work requirements through TANF (cash assistance) or SNAP (food assistance) -- you do not have to prove it twice
  8. In treatment for a substance use disorder
  9. 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

January 1, 2027, for most states. Some states may receive extensions from HHS up to December 31, 2028, if they show they are making a good-faith effort to implement the requirements.
No. They apply only to adults ages 19 to 64 enrolled through the Medicaid expansion. Traditional Medicaid (for people with disabilities, pregnant women, children, etc.) is not affected. There are also nine categories of exemptions.
Employment (including self-employment), community service, participation in a work program, or enrollment in school at least half-time. You need 80 hours per month total across any combination of these activities.
If you lose Medicaid specifically because you did not meet work requirements, you are ineligible for premium tax credits on the ACA marketplace. That means you would pay full price for marketplace plans, which can cost hundreds of dollars per month without subsidies.
If you live in one of the 10 states that did not adopt full ACA Medicaid expansion, these requirements generally do not apply. However, Wisconsin (BadgerCare) and Georgia (Pathways to Coverage) operate partial expansion programs under federal waivers, and enrollees in those programs are subject to the new work requirements.

Sources & Additional Resources

KFF: A Closer Look at the Work Requirement Provisions in the 2025 Federal Budget Reconciliation Law
Detailed analysis of the Medicaid work requirement provisions, exemptions, PTC ineligibility, and implementation timeline
https://www.kff.org/medicaid/a-closer-look-at-the-work-requirement-provisions-in-the-2025-federal-budget-reconciliation-law/
KFF: 5 Key Facts About Medicaid Work Requirements
Research showing 92% of non-disabled Medicaid adults already work or have qualifying reasons for exemption
https://www.kff.org/medicaid/5-key-facts-about-medicaid-work-requirements/
CHCS: A Summary of Federal Medicaid Work Requirements
Policy summary of the work requirement provisions, exemption categories, and auto-verification requirements
https://www.chcs.org/resource/a-summary-of-national-medicaid-work-requirements/
ASTHO: One Big Beautiful Bill Act Law Summary
Summary of the law signed July 4, 2025, including Medicaid work requirement provisions
https://www.astho.org/advocacy/federal-government-affairs/leg-alerts/2025/one-big-beautiful-bill-law-summary/
NEJM: Medicaid Work Requirements — Results from the First Year in Arkansas
Peer-reviewed study finding coverage losses but no employment gains from Arkansas work requirements
https://www.nejm.org/doi/full/10.1056/NEJMsr1901772
Health Affairs: Medicaid Work Requirements in Arkansas — Two-Year Impacts
Two-year follow-up documenting paperwork barriers as the primary cause of coverage loss
https://www.healthaffairs.org/doi/abs/10.1377/hlthaff.2020.00538

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.

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