Medicaid Work Requirements 2027: The 80-Hour Rule, Exemptions, and State Deadlines

Medicaid work requirements are changing in 2027, but the new federal rule will not affect everyone enrolled in Medicaid. Beginning January 1, 2027, most affected states must require certain adults to demonstrate qualifying work, community service, job training, or educational activity to qualify for or maintain coverage. Some states have already started implementation.

The requirements come from Section 71119 of Public Law 119-21, enacted July 4, 2025. The Centers for Medicare & Medicaid Services (CMS) issued its implementing interim final rule in June 2026.

The most important first step is determining whether you belong to a Medicaid eligibility group covered by the rule. Your age, medical circumstances, caregiving responsibilities, existing benefits, and state’s implementation schedule can all matter.

Start with Medicaid.gov’s state-specific eligibility information and your state Medicaid agency. Do not assume that you must complete 80 hours simply because you receive Medicaid.

Medicaid work requirements 2027: At a glance

These requirements are explained in CMS’s June 2026 fact sheet and the federal interim final rule.

Who has to meet Medicaid work requirements in 2027?

The federal rule generally targets adults who meet all the relevant eligibility criteria:

• They are at least 19 and under 65.
• They are not pregnant and are not covered by a qualifying pregnancy-related or postpartum exclusion.
• They are not entitled to or enrolled in Medicare in a manner that excludes them under the rule.
• They qualify for or receive coverage through the ACA Medicaid expansion adult group or certain Section 1115 demonstration populations.
• They are not otherwise eligible under a Medicaid eligibility category that places them outside the applicable population.
• They do not qualify for an applicable exclusion or exception.

The precise eligibility category matters. Being between 19 and 64 and having a low income does not automatically make someone subject to the work requirement.

The rule primarily concerns adults covered through the ACA Medicaid expansion, which generally extends eligibility to adults with household incomes up to 138% of the federal poverty level. Certain people covered through Medicaid demonstrations are also included, even in states that have not adopted the standard expansion.

Traditional Medicaid eligibility groups are not automatically subject to the new requirement merely because a beneficiary is an adult. If you receive Medicaid based on a disability, pregnancy, parental status, age, or another eligibility category, ask your state how your specific coverage group is treated.

CMS identified 43 states and the District of Columbia as providing coverage to populations subject to the new requirements. The requirements do not apply to U.S. territories in the same way they apply to states. CMS specifically identifies Puerto Rico, the U.S. Virgin Islands, Guam, the Northern Mariana Islands, and American Samoa as outside these new rules. See CMS’s community engagement overview.

What is the 80-hour Medicaid rule?

If you are an applicable individual, you generally must demonstrate qualifying community engagement for the required month. You may satisfy the requirement through one permitted activity or a combination of activities.

1. Work

You can generally qualify by working at least 80 hours in a month.

Qualifying work may include employment and self-employment, subject to the applicable definitions and verification rules. Some work arrangements involving payment in goods or services may also count.

Keep records showing the dates and hours you worked, how you were paid, and the income you received. Ask your state whether it accepts employer statements, timesheets, self-employment records, or other evidence.

2. Community service or volunteering

Qualifying community service can satisfy the requirement when you complete at least 80 hours in the month.

The federal framework uses a defined community-service activity, so not every unpaid task automatically qualifies. Ask the agency whether your organization, activity, and method of recording hours meet the rules.

Useful records may include a signed statement from a participating organization, a service schedule, or a record of completed hours.

3. A qualifying work program

Participating in an eligible work program for at least 80 hours in the month is another route.

The activity must meet the governing definition. Ordinary job searching should not be assumed to count simply because it relates to employment. Confirm that the program itself is recognized and ask how participation hours are verified.

4. Education

Enrollment in a qualifying educational program at least half-time satisfies the requirement under the federal framework. The educational institution determines whether a student is enrolled at least half-time under the applicable rules.

Eligible programs can include qualifying secondary education, college, and career or technical education.

If you attend school less than half-time, your qualifying educational hours may be combined with other permitted activities to reach 80 hours.

5. Combining activities

You can combine permitted activities to reach 80 hours in a month, provided you meet the relevant definitions.

For example, if you complete 50 qualifying work hours and 30 qualifying community-service hours, the combined total is 80 hours.

However, a state may not combine educational hours with another activity when enrollment is already at least half-time, because that enrollment independently satisfies the requirement.

The permitted pathways appear in the federal rule’s community engagement provisions.

Can you qualify by earning $580 a month instead?

Yes. The federal framework provides a monthly-income alternative to completing 80 hours of work.

The calculation uses the federal minimum wage:

$7.25 × 80 hours = $580 per month.

An applicable individual who meets the qualifying monthly-income standard can satisfy the community-engagement requirement without demonstrating 80 hours of work.

The $580 figure is not a universal Medicaid income limit. It is not a cash benefit, and it does not replace the ordinary financial eligibility rules for Medicaid. You must still qualify financially and satisfy all other applicable eligibility conditions.

For seasonal workers, a separate provision allows qualifying individuals to use average monthly income over the preceding six months. The person must meet the federal definition of a seasonal worker; the provision does not automatically apply to everyone whose income fluctuates.

States must follow the applicable federal income-calculation rules and any permitted state methodology. If you work irregular hours or earn seasonal income, ask the agency how it will calculate your qualifying monthly income.

See the federal rule on monthly income and seasonal workers.

Who is exempt from Medicaid work requirements?

Not meeting the 80-hour requirement does not automatically mean that you must lose Medicaid. Federal law excludes specific groups, and it also provides separate statutory and state-selected exceptions.

The categories below summarize important provisions, but they are not a substitute for a determination by your state Medicaid agency.

Mandatory exclusions and other statutory exceptions

Sources: CMS’s implementing fact sheet, the federal regulation, and CMS’s state-specific eligibility guidance.

Medical frailty is a defined category

Having a medical diagnosis does not automatically qualify you for the medical-frailty exclusion.

The federal rule identifies categories involving blindness, certain physical, intellectual, or developmental disabilities, disabling mental disorders, substance use disorders, and serious or complex medical conditions.

The rule’s substance-use-disorder category excludes individuals in stable recovery, defined as five or more years in recovery. A person may still qualify under another medical-frailty criterion or a separate exclusion.

For some disability-related criteria, the rule focuses on whether a condition significantly impairs the person's ability to perform at least one activity of daily living, such as bathing, dressing, or eating. The assessment must follow the relevant federal definition.

CMS also distinguishes medical frailty from participation in a qualifying substance-use treatment program. They are separate routes to exclusion, with different criteria.

A person should not decide they are ineligible for an exclusion simply because they do not receive disability benefits or because their condition is not on an informal list of diagnoses. Ask the state how it assesses medical frailty and which information it can use to determine eligibility.

CMS published additional information on medical frailty in September 2026 through its community engagement guidance page.

Receiving SNAP or TANF is not a blanket exemption

Receiving benefits from another assistance program does not automatically exempt someone from Medicaid work requirements.

The TANF-related category is tied to meeting the applicable state TANF work requirements. The SNAP-related statutory test is different: CMS interprets it to cover people in a household receiving SNAP who are not exempt from applicable SNAP work requirements, rather than requiring proof that they are actually complying with those requirements.

If you participate in SNAP or TANF, tell your Medicaid agency. The state may be able to use information from the other program to verify whether an exclusion applies.

Age and Medicare status matter

The federal definition generally covers adults ages 19–64 who are not entitled to or enrolled in Medicare under the relevant criteria. People outside this age range are not generally applicable individuals under this definition.

However, the reason a person qualifies for Medicaid and the category in which they are enrolled can also matter. Confirm your actual coverage category rather than relying on age alone.

What are Medicaid hardship exemptions?

Federal law permits states to offer certain short-term hardship exceptions. These are different from mandatory exclusions: a state may choose to offer the relevant options, and availability can vary by location and circumstance.

Under the federal rule, the principal hardship categories include:

• Certain inpatient or high-acuity care: A qualifying period receiving specified inpatient hospital, nursing facility, or other covered services of similar acuity may satisfy the requirement for that month if the state has adopted the exception.
• Disasters or emergencies: States may request a hardship exception covering people in affected locations during qualifying emergency or disaster circumstances.
• High unemployment: A state may request an exception for residents of a county or equivalent local area where the unemployment rate reaches the applicable federal threshold.
• Travel for necessary medical care: A qualifying person who must travel outside their community for an extended period to receive certain necessary medical services, or who must provide qualifying support for a dependent receiving that care, may meet the criteria.

For the unemployment exception, the federal threshold is the lesser of 8% or 1.5 times the national unemployment rate. The state must request CMS approval for the relevant county or local area. Where a state has adopted the relevant location-based exception, qualifying residents receive it automatically rather than having to prove their county’s unemployment rate individually.

Other hardship routes have their own eligibility conditions and may require the individual to request the exception or supply relevant information.

Read CMS’s federal rule on short-term hardship exceptions for the legal definitions.

Important: Do not assume that a hardship exception available in one state is also available in another. Before relying on a hospital stay, disaster, unemployment, or medical-travel circumstance, ask your state whether it has adopted the applicable exception and how to establish eligibility.

Which States Are Implementing Medicaid Work Requirements Early?

As of October 21, 2026, four states have the most important early implementation differences: Nebraska, Montana, Iowa, and Arkansas. Georgia also has an existing Medicaid demonstration program with work-related eligibility rules, although its position is different from the new federal rollout.

The following table distinguishes state-announced implementation from a confirmed CMS state-plan amendment and from a soft launch.

Nebraska’s date is supported by the CMS state-plan amendment database as well as the state agency. The other listed early-rollout dates are supported by the relevant state agencies, but they are not all documented in the same way in the publicly reviewed CMS amendment records.

For the latest implementation information, use Medicaid.gov’s state selector, then follow the links to the state agency. The KFF Medicaid work-requirements tracker is also useful for following policy decisions, but its September 29, 2026 update should be read alongside newer state announcements.

How will states verify the 80-hour requirement?

States must verify community engagement or an applicable exclusion at application and during renewal. The federal rule permits states to conduct additional verifications more frequently than the minimum schedule.

At application

States must require an applicable individual to demonstrate compliance for at least one and no more than three consecutive months immediately before the application month. The state selects the applicable review period.

That means two states may examine different numbers of preceding months. If a state requires three months, an applicant must meet the applicable requirement in all three months, not just one.

At renewal

At renewal, the federal rule generally requires at least one qualifying month during the review period. States can require more than one month and may conduct additional verifications between regular renewals.

For many affected Medicaid beneficiaries, renewal occurs every six months under the new framework, although some people enrolled through certain demonstrations may have different renewal schedules. Ask your state which months it will examine and when it expects you to provide information.

Automatic verification and documentation

States must use reliable information already available to them where the federal rules require it. That can include available employment, program-participation, education, or eligibility records. Automatic data matching may establish compliance or an exclusion without requiring the beneficiary to submit paperwork.

If the information is missing, inconsistent, or insufficient, the state may ask the individual for additional information or documentation. The specific verification process can vary by state and activity.

See the federal rule’s application and renewal provisions.

What documents should you keep?

There is no single document that every state must accept for every qualifying activity. The safest approach is to keep a simple monthly record and ask your state which evidence it will recognize.

Do not send sensitive medical records unless they are requested through an appropriate official process. Ask the agency which documents it needs and whether it can verify your status through existing records.

For each submission, retain a copy of what you sent, the date, any confirmation number, and a record of relevant calls or online communications.

What happens if you do not meet the Medicaid work requirement?

If a state determines that an applicable individual cannot demonstrate compliance and no exclusion or exception applies, it can deny an application or terminate existing coverage under the relevant rules.

However, an initial failure to verify hours does not automatically mean permanent ineligibility.

The federal interim final rule requires a notice of noncompliance and a 30-calendar-day period for the individual to respond with information or documentation addressing compliance or an applicable exclusion. If the state subsequently makes a negative eligibility decision, it must provide a written decision and the applicable fair-hearing rights. An eligibility termination generally requires at least 10 days' advance notice, subject to the governing rules.

Read the entire notice carefully. The dates on your own notice matter, and the process may differ depending on whether you are an applicant or an existing beneficiary.

If you think the state made a mistake, contact the agency promptly. Explain which activity you completed, which records support it, or why you believe an exclusion applies. Ask for the reason for the decision and how to request a review or fair hearing.

Do not assume that coverage will continue while an appeal is pending. Ask the agency whether coverage can remain in place during the review and what deadlines or conditions apply.

The applicable notice, eligibility, and hearing provisions are set out in the federal interim final rule.

What should you do now to help protect your coverage?

The most useful steps are practical and relatively simple.

1. Confirm your eligibility category. Ask whether your Medicaid coverage is through the expansion adult group or a specified Section 1115 demonstration. Do not assume the rule applies merely because you are an adult Medicaid beneficiary.

2. Check for an exclusion. Review the categories above, particularly medical frailty, qualifying caregiving, pregnancy or postpartum coverage, veteran disability status, and relevant SNAP or TANF rules. Tell your agency if you believe a category applies.

3. Update your contact information. Make sure your Medicaid agency has your current mailing address, phone number, and email address. Verify your preferred way to receive notices.

4. Start keeping monthly records. If you may be subject to the requirement, maintain a record of qualifying hours, income, school enrollment, training, and community service. Do not wait for your renewal to start documenting activities.

5. Read every official notice. A letter or online message may tell you which months the state is reviewing, whether it believes an exclusion applies, and what information it still needs.

6. Contact the state when something is unclear. Ask about accepted proof, reporting methods, review periods, exclusions, hardship options, and how to correct inaccurate information.

Use Medicaid.gov’s state Medicaid and CHIP office directory to locate the correct agency.

What if your Medicaid coverage ends?

If you lose Medicaid, promptly check whether you can enroll in other coverage.

For people using the federal Health Insurance Marketplace, losing Medicaid or CHIP can qualify them for a Special Enrollment Period. Under current HealthCare.gov rules, you can generally select a Marketplace plan up to 60 days before your Medicaid coverage ends or within 90 days after it ends. Documentation may be required, and you should follow the instructions and deadlines provided during enrollment.

If you qualify for a Marketplace plan, whether you receive financial assistance depends on the applicable eligibility requirements and your circumstances. Do not assume that a particular subsidy or plan is guaranteed.

You can learn more through HealthCare.gov’s Medicaid and CHIP coverage transition information.

Frequently asked questions

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