Work Requirements and How They Can Impact Medicaid Beneficiaries 


work requirementsWork Requirements and How They Can Impact Medicaid Beneficiaries

Medicaid work requirements are changing, and some adults will need to meet new eligibility rules to keep their health coverage. Under a federal law passed in 2025, certain Medicaid beneficiaries must complete qualifying work or other activities each month, unless they meet an exception. Most states must implement these requirements by January 1, 2027, although some are starting earlier.

Not everyone receiving Medicaid will be affected. Understanding who must meet the requirements, what activities count, and how your state verifies eligibility can help you prepare for the changes and avoid potential interruptions in coverage.

What Are The Work Requirements?

The new Medicaid work requirements generally require certain adults to complete at least 80 hours of qualifying activities each month to maintain their eligibility. However, that does not mean you need to work a traditional full-time job to keep your coverage.

Qualifying activities include working, volunteering, participating in an approved job-training program, or attending school. You can also combine activities to meet the monthly requirement. For example, working 60 hours and completing 20 hours of volunteer service could satisfy the 80-hour requirement.

You may also meet the requirement by earning at least $580 per month, even if you work fewer than 80 hours. Students enrolled at least half-time in an eligible educational program may also satisfy the requirement without completing 80 hours of activities.

Who Must Meet Medicaid Work Requirements?

According to KFF’s September 2026 implementation tracker, the new federal work requirements will apply in 43 states and Washington, D.C.

The requirements do not apply to every Medicaid beneficiary in these states. They primarily affect certain adults enrolled through Medicaid expansion or qualifying demonstration programs.

The new work requirements generally apply to adults ages 19 through 64 who receive Medicaid through the Affordable Care Act’s Medicaid expansion program. Certain adults who qualify for Medicaid through other state coverage programs may also be subject to the requirements.

However, not everyone receiving Medicaid will need to meet the monthly activity requirement. Children, adults age 65 or older, and people who qualify for certain exemptions are not subject to the new rules. Your eligibility category and personal circumstances will help determine whether the requirements apply to you.

Who Is Exempt From Medicaid Work Requirements?

Federal law provides exemptions for people in certain circumstances, including:

  • Pregnant women and individuals receiving postpartum Medicaid coverage.
  • Parents, guardians, and caregivers of children age 13 or younger or individuals with disabilities.
  • People with qualifying disabilities, serious medical conditions, or other special medical needs.
  • Veterans with a total disability rating from the Department of Veterans Affairs.
  • Certain individuals receiving treatment for substance use disorders.

Other exemptions apply to qualifying former foster youth, certain American Indian and Alaska Native individuals, and people who meet specific Medicare, SNAP, or TANF eligibility criteria.

Some exemptions may be verified automatically, while others may require additional information. Contact your state Medicaid agency to confirm whether you qualify for an exemption and whether you need to provide any documentation.

When Do Medicaid Work Requirements Take Effect?

Most states must implement the new Medicaid work requirements by January 1, 2027. The exact date the requirements apply to you will depend on your state’s implementation schedule and your Medicaid eligibility.

As states prepare for these changes, Medicaid beneficiaries should pay attention to notices from their state Medicaid agency. These notices may explain when the requirements begin, whether you need to report qualifying activities, and what information you may need to provide.

You can contact your state Medicaid agency to confirm when the new requirements take effect and whether you need to take any action to maintain your coverage.

How Can Work Requirements Affect Your Medicaid Coverage?

Meeting the monthly activity requirement is only one part of maintaining your Medicaid coverage. Your state must also verify that you meet the requirements or qualify for an exemption. In some cases, the state may already have the information it needs. In others, you may be asked to provide additional documentation.

If your eligibility cannot be verified, your state will send you a notice explaining what you need to provide. You will have an opportunity to respond, but failing to resolve the issue could lead to a denial of your application or the loss of your existing coverage.

Losing Medicaid does not necessarily mean you have to wait until the next Open Enrollment Period to find new health insurance. Depending on your circumstances, you may qualify for a Special Enrollment Period that allows you to enroll in a Marketplace plan. Learn more about how Special Enrollment Periods work  and what options may be available if you lose your coverage.

What Should You Do to Prepare for Medicaid Work Requirements?

If you’re concerned about how the new requirements could affect your coverage, there are a few things you can do now to prepare.

  1. Keep records of your qualifying activities, including work hours, volunteer service, or educational participation.
  2. Make sure your Medicaid agency has your current mailing address, phone number, and other contact information.
  3. Review any notices you receive and provide requested documentation by the stated deadline.
  4. Contact your state Medicaid agency if you have questions about your eligibility or believe your information is incorrect.

If you believe your coverage was denied or terminated incorrectly, contact your state Medicaid agency to learn about your appeal rights and the steps available to resolve the issue.

You can find your state’s Medicaid information and additional resources at Medicaid.gov.

Final Thoughts

The new Medicaid work requirements make understanding your eligibility an important part of managing your health coverage. Whether you need to report qualifying activities, verify an exemption, or respond to an eligibility notice, knowing what is expected of you can help you avoid unnecessary coverage problems. Stay informed about your state’s requirements, keep your information current, and address any questions about your eligibility before they become larger issues.

If you have questions about your health insurance or need to explore other coverage options, Empower Brokerage is here to help. Our licensed insurance agents can walk you through your options and help you find coverage that fits your needs.

 


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