MEDICAID UPDATE
Medicaid Work Requirements 2027: Who Must Report 80 Hours
A new Medicaid community-engagement rule may affect some adults in January 2027. Check your state’s notices. This is not a rule for every Medicaid member.
Who may be affected
CMS says the rule generally applies to non-pregnant adults ages 19 through 64 who are not enrolled in Medicare and are in the Medicaid adult expansion group or certain section 1115 coverage. CMS says 43 states and Washington, D.C. operate these coverage groups; U.S. territories are not subject to this rule. States generally must implement it by January 1, 2027, though a state may start earlier.
Ways to meet the requirement
An affected person may show 80 hours a month of work, an approved work program, community service, or at least half-time education. A combination can count. CMS also says a person may meet the test with monthly income of at least 80 times the federal minimum wage—$580 in 2026.
Exemptions to check first
These are the most important details to review with your state. CMS lists exceptions that may cover people who are:
- pregnant or in a postpartum period;
- a parent, guardian, or caretaker of a child under 14 or a person with a disability;
- disabled or medically frail;
- American Indian or Alaska Native;
- a former foster youth;
- a veteran with a total disability rating;
- already meeting TANF or SNAP work requirements;
- in drug or alcohol treatment; or
- currently or recently incarcerated.
See CMS’s full rule summary for the official exception categories.
Important protections
If a state cannot verify compliance, the federal rule requires a notice and 30 calendar days to show compliance or an exemption before a final decision. The notice must explain how to reapply if coverage ends. States may also offer short-term hardship exceptions for hospital care, certain medical travel, disasters, and qualifying high-unemployment areas.
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