Medicaid Work Requirements 2027: Who Must Work and Who Is Exempt

Medicaid work requirements start on January 1, 2027 in most of the country, and a few states have already switched them on. The rule reaches adults ages 19 to 64 covered through the ACA expansion group.

Unless an exemption applies, they will need 80 hours a month of work, school, training or volunteering, or about $580 a month in earnings.

The details decide who keeps coverage. The federal rule now sits in the Code of Federal Regulations, a court changed part of it on October 29, 2026, and each state picks how many months it checks.

We read the regulation text and every state page named below on October 30, 2026, so the dates and lists here are current to that day.

If you are not sure which Medicaid group you are in, start with our Medicaid program guide. This page covers only the new 80-hour rule.

Key Takeaways

• The rule applies to adults 19 to 64 in the Medicaid expansion group, or in certain waiver programs, who are not pregnant and not on Medicare. CMS says 43 states and DC must run it.
• You meet it for a month with 80 hours of work, volunteering or a work program (or a mix), half-time school, or income of at least $580 that month.
• Ten federal groups are excluded, including parents and caregivers of a child 13 or younger, people who are medically frail, veterans rated 100% disabled, American Indians and Alaska Natives, and pregnant or postpartum adults.
• Nebraska started May 1, 2026 and Montana on July 1, with Montana denials only from October 2026. Iowa starts December 1, and Arkansas is in a no-penalty trial until January 1, 2027. A state can win a good-faith delay, but never past December 31, 2028.
• If the state cannot confirm you, it must send a notice and give you 30 days to answer. People cut off can reapply at any time.

What are the Medicaid work requirements?

They are a new condition of eligibility from H.R. 1, the 2025 budget law, which federal rules call “community engagement.” Covered adults must show 80 hours a month of work, volunteering, a work program or a mix, half-time school, or earnings of at least $580. States check at application and renewal.

CMS wrote the details into an interim final rule issued on June 1, 2026 and published in the Federal Register on June 3, 2026. The rule is now codified at 42 CFR 435.550 through 435.563, which is the text states have to follow.

Three points from that text shape everything else here. It is a test you pass month by month, not a weekly quota. The state has to look for proof in its own data before it asks you. And no Section 1115 waiver can remove it: the rule says CMS “will not approve” one that does.

The rule is also separate from the income test. You still need income within your state’s limit, which for expansion adults is 138% of the poverty level. Our Medicaid income limits guide has the state-by-state dollar figures.

Who has to meet the 80-hour rule?

The rule covers you, as an “applicable individual,” only if all of these are true: you qualify through the adult expansion group or a similar waiver, you are 19 to 64, you are not pregnant, you are not on Medicare Part A or B, and you do not qualify for Medicaid any other way.

That last condition matters more than it looks. Someone who gets Medicaid through SSI, a disability group or a parent group is not in the expansion group, so the rule does not reach them, even at age 30. Your eligibility notice names the group you were approved under.

According to the CMS fact sheet on the rule, 43 states and the District of Columbia have to run it, and the U.S. territories do not. KFF’s tracker, updated September 29, 2026, counts the same 44 and adds detail.

Eight states have waiver programs that pull in more people. In Georgia, Tennessee and Wisconsin, which have not adopted the full ACA expansion, only certain waiver enrollees are covered. Hawaii, Massachusetts, New York, Oregon and Utah have expansion adults plus some waiver enrollees in scope.

KFF counts seven states that neither expanded Medicaid nor run a covered waiver. Adults there do not face this rule because they have no expansion coverage to lose. Seniors 65 and older are outside it everywhere; our Medicare vs Medicaid guide explains how those programs work together.

Who is exempt from Medicaid work requirements?

Ten groups never have to log hours: former foster youth, American Indians and Alaska Natives, parents and caregivers of a child 13 or under or a disabled person, veterans rated 100%, medically frail people, people under TANF or SNAP work rules, people in addiction treatment, inmates, and pregnant or postpartum adults.

The table below gives the exact test for each group as written in 42 CFR 435.554. The wording matters, because states check you against these definitions, not against looser summaries.

A separate list of “mandatory exceptions” treats you as compliant for any month in which, for at least part of the month, you were under 19 or on Medicare. The same applies if you could qualify through a mandatory Medicaid group, or if you left jail or prison within the prior three months.

States apply the release window a little differently in practice. Nebraska tells members “within 90 days of a qualifying month,” while Iowa’s page says released within the last four months. Read your own state’s notice for the exact window.

Who counts as caring for a disabled person?

The disabled person only has to meet the Americans with Disabilities Act definition. The rule says they “need not be eligible for Medicaid or other Federal programs on the basis of a disability.” An adult caring for a parent with dementia can qualify even if the parent gets no disability benefits.

The veteran exemption covers the veteran, not the family. A spouse caring for a disabled veteran would use the caregiver route instead. Our veterans Medicaid guide covers how VA ratings and Medicaid fit together.

What does medically frail mean for the work rule?

You count as medically frail if you fit one of five groups: blind or disabled under Social Security rules, a substance use disorder, a disabling mental disorder, a disability that limits daily tasks, or a serious or complex condition. Your state must keep a list of qualifying conditions and let you ask to add yours.

The substance use category leaves out people in “stable recovery,” which the rule defines as five or more years. The serious or complex condition category is broad. It covers conditions that are life threatening or seriously disabling, cause major pain, need frequent monitoring, or need several specialists.

Each state must keep an auditable list of qualifying diagnoses and update it. If your condition is not on the list, the state must give you a way to ask for the exemption anyway. Nebraska, for example, uses claims data where it can and lets members self-declare, under a process it updated on September 14, 2026.

What changed in court on October 29, 2026?

CMS’s rule added a second test: the condition also had to “significantly impair” your ability to meet the requirement. On October 29, 2026, the federal district court in Massachusetts declared that wording unlawful and vacated it in Massachusetts v. Oz.

The court’s order bars CMS from applying that test to the plaintiff states. Those are California, Massachusetts and New Jersey, which led the case, plus Arizona, Colorado, Connecticut, Delaware, DC, Hawaii, Illinois, Maine, Maryland, Michigan and Minnesota.

The rest of the plaintiff list is Nevada, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, Virginia, Washington and Wisconsin, plus the governors of Kentucky and Pennsylvania. It also bars CMS from penalizing those states for implementation errors or delays for six months.

What this means for you: in those states, having a listed condition should be enough without proving it limits your work.

The court vacated that wording outright, but only plaintiff states have an injunction, so other states may handle it differently. The order does not move the January 1, 2027 start date. The government may appeal, so check the New Jersey Attorney General’s summary and your state’s notices for updates.

What counts toward the 80 hours a month?

Four activities count: work, community service, a qualifying work program, and school. You can mix work, service and program hours to reach 80. Half-time school counts on its own. Earning at least $580 in the month also meets the rule, however few hours you worked, and seasonal workers can use a six-month average.

Each activity has its own fine print in 42 CFR 435.552. Here is what each one means in practice.

Work, paid or not

Work includes a job paid in money, work paid in goods or services, and unpaid work other than community service. Self-employment and gig work count. Iowa’s guidance says that if you earn under $580, your proof must show your hours, so keep a log if you are paid by the task.

The $580 income route

CMS sets the 2026 figure at $580 a month, which is 80 hours at the $7.25 federal minimum wage. Because it is an income test, a worker earning $16 an hour clears it with just over 36 hours in the month. States use Medicaid’s usual income rules (MAGI) to measure it.

Seasonal workers get a different test. If your work is seasonal, you meet the rule when your average monthly income over the preceding six months is at least $580.

For example, in October a landscaper who earned $4,200 from April through September averages $700 a month over those six months and passes, even with no October pay. By winter the six-month window holds fewer paid months, so the average can fall below $580.

Volunteering and community service

Community service means unpaid work with a structured program run under a public agency or nonprofit, such as a 501(c)(3). The group must oversee the work, keep it non-partisan, and track your dates, hours, activity type and a contact who can confirm them. Court-ordered service counts too.

Casual help, like mowing a neighbor’s lawn, will not count unless it runs through an organization that tracks hours. Ask the volunteer coordinator before you start whether they can sign a monthly hours statement. Iowa’s page links to Volunteer Iowa’s list of places to volunteer.

Work programs and job training

Qualifying programs include WIOA Title I job training, Trade Adjustment Assistance, state employment and training programs (including SNAP E&T), Department of Labor or VA programs for veterans, and SNAP workforce partnerships.

Job searching on its own does not count. A program can include supervised job search only as a side part that takes less than half of its hours.

School and how credits convert to hours

Half-time enrollment in college, a career or technical program, high school or a GED program meets the rule outright. Your school decides your status, and it carries through normal breaks.

Under half-time, the rule converts credits to hours: each credit hour counts as 3 hours a week, multiplied by 4.33 weeks. A 3-credit class equals about 39 hours a month, so you would need about 41 more hours of work or volunteering. Students looking at short training may find our Workforce Pell Grant guide useful.

How many months will the state check?

It depends on your state. New applicants must show one to three consecutive months right before the month they apply. Current members must show at least one month, consecutive or not, between renewals. Each state picks its own number within those limits, so read your notice to see how many months your state checks.

That number is the single biggest difference between states. Nebraska asks applicants about the month before they apply and asks members for one qualifying month in the 12 months since their last renewal. Iowa asks members for any two months in that period.

Here is how the applicant look-back plays out. Say you apply in March 2027. In a one-month state you need February. In a three-month state you need December, January and February, back to back. A gap in January would sink the application, though you could reapply once you have the months.

Current members are checked at their first renewal on or after the state’s start date, under 42 CFR 435.559. Nobody is cut off on January 1 itself. A member whose renewal falls in August 2027 is checked in August, against the months the state picked.

States may also choose to check more often than at renewal. H.R. 1 separately moves expansion adults to renewals at least every six months, starting with renewals scheduled on or after December 31, 2026. Our Medicaid renewal guide walks through the renewal packet, deadlines and the 90-day window.

Can a short-term hardship excuse a month?

Yes, if your state offers hardship exceptions. They cover a month when you were in a hospital or nursing facility, lived in a county under a presidential disaster declaration or with high unemployment, or had to travel away from home for serious medical care for you or a dependent. States choose whether to offer them.

The unemployment test is precise: the county rate must be at or above the lesser of 8% or 1.5 times the national rate. For county-based hardships, the state cannot make you ask. It has to apply them on its own, per 42 CFR 435.555.

Nebraska shows how this works. On October 30, 2026 its work requirements page listed temporary hardships for 14 counties, Dawson for high unemployment from February 1, 2026 and others for wildfire and storm declarations.

The state said it would reprocess anyone cut off in those months, with no action needed from them.

For hospital stays and medical travel, you usually have to ask. Keep discharge papers or appointment records for any month you were admitted or traveling for care.

How will the state verify, and what happens if you get a notice?

The state must first check data it already has, such as wage records, SNAP files and Medicaid claims. Only if that fails can it ask you. It must then send a notice of noncompliance and give you 30 calendar days to show you met the rule or are exempt. Coverage continues during that time.

The clock starts when you receive the notice, and the rule treats a notice as received five days after the date printed on it. A notice dated March 10 counts as received March 15, so your answer is due by about April 13. You can answer online, by phone, by mail or in person.

If you do not respond in time, the state must still check whether you qualify for Medicaid another way before it denies you. It must also give advance notice and fair hearing rights. A current member can be disenrolled no later than the end of the month after the 30 days run out.

Being cut off has two more effects. Under 42 CFR 435.558, the state cannot bar you from reapplying, so you can apply again as soon as you have a qualifying month. But a denial or disenrollment for this reason also blocks premium tax credits on the Marketplace, KFF notes, so a subsidized ACA plan is not a fallback.

From January 1, 2028, states must require documents when their data comes up short and documents are reasonably available. Until then they have more room to accept your own statement. Nebraska, for example, uses a signed declaration form for volunteering, school, caregiving and medical exemptions.

Early numbers show why answering matters. Healthcare Dive, citing Nebraska’s September Medicaid advisory committee, reported about 560 applicants denied, 84% because they could not supply verification. Among about 530 members cut at renewal, 92% had not answered the state’s request.

When do Medicaid work requirements start in each state?

The federal deadline is January 1, 2027. Four states moved early: Nebraska on May 1, 2026, Montana on July 1, Iowa on December 1, and Arkansas with a no-penalty trial from July 1. Montana issued no denials for this rule until October 2026. Good-faith delays can run no later than December 31, 2028.

Each state below was checked on its own agency site on October 30, 2026.

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Sources for the table: Nebraska DHHS, the Montana DPHHS FAQ, the Arkansas DHS soft-launch notice, and the Iowa HHS IHAWP page (updated October 23, 2026). Georgia’s status comes from KFF’s tracker.

Georgia is a special case. Pathways to Coverage has required 80 hours a month since July 2023, but under its own waiver. KFF reports the waiver expires December 31, 2026 and the state must follow the federal rules from January 1. In October 2026 Georgia asked CMS for a 90% federal match on Pathways.

Can a state delay past January 2027?

Only through a good-faith exemption under 42 CFR 435.560. CMS weighs the state’s progress, its barriers, its plan and timeline, and any emergencies. The first approval lasts no more than six months, extensions need quarterly reports, and no exemption can run past December 31, 2028.

On October 1, 2026, the governors of Oregon, California, Maine, New Mexico and Virginia wrote to HHS asking for more time, Oregon’s governor announced. As of October 30, 2026 we found no posted CMS approval of a good-faith exemption for any state. Until your state announces one, plan on January 1, 2027.

How is this different from SNAP work requirements?

They are separate rules. SNAP’s rule for adults without dependents is a time limit: miss the hours and food benefits stop after three months in three years. The Medicaid rule is a condition of eligibility checked at application and renewal, with no grace months and its own list of exemptions.

The two connect in one place. If you live in a SNAP household and are subject to a SNAP work rule, that alone excludes you from the Medicaid rule. You do not have to report the same hours twice. If SNAP exempts you, though, the Medicaid exclusion does not apply, and you need another route.

Our SNAP work requirements guide covers the food-benefit side, including its age ranges and waivers. The USDA SNAP work rules page is the federal source.

Do you have to cancel Medicaid if you get a job?

No. Getting a job does not end Medicaid by itself, and work now helps you meet the 80-hour rule. What can end coverage is income above your state’s limit. Report the new job to your Medicaid agency within the time your state requires, and it will then recheck whether you still qualify.

If the new pay pushes you over 138% of the poverty level, you may move to a Marketplace plan and can reapply for Medicaid if your income drops. Losing Medicaid because your income rose is not a work-rule denial, so it does not block premium tax credits.

Our ACA open enrollment guide covers the Marketplace dates.

Not reporting a job is the risky path. States compare wage data, and an unreported change can mean an overpayment claim or a coverage gap later.

What should you do before your first check?

Find out which group you are in, then match the next 3 months to your state’s look-back. If an exemption fits, report it now so it is on file. If not, keep proof for every month: pay stubs, a volunteer hours sheet, a school schedule or a training log. Update your mailing address, phone and email.

States had to send outreach notices at least three months, plus their look-back months, before the start date, by mail plus a call, text or portal message. If you are an expansion adult and never got one, your contact details may be out of date.

Use this short checklist as your next renewal approaches:

• Look at your approval notice and confirm you are in the adult or expansion group.
• Check the exemption table above and tell your agency about any that fit, with proof.
• Keep one folder per month with pay stubs, hours letters or class schedules.
• Open every letter, text and portal message from your Medicaid agency.
• Answer any noncompliance notice inside 30 days, and ask for a fair hearing if you disagree.

Related reading:

• How Medicaid renewal works
• Medicaid income limits by state
• SNAP work requirements
• Nebraska benefits hub