Who has to meet the Medicaid work requirement?
The work requirement in P.L. 119-21 (section 71119) applies to adults 19 to 64 who get Medicaid through the expansion adult group or a similar state program, aren’t pregnant and aren’t on Medicare.
That covers the 40 states and DC that expanded Medicaid, plus some state programs for adults, such as Georgia Pathways and Wisconsin’s BadgerCare Plus for adults without children. CMS’s July 2026 list of those programs also includes a TennCare group of parents in Tennessee, and TennCare says they automatically meet the requirement through income it has on file.
| Who | Does the requirement apply? |
|---|---|
| Adults 19 to 64 on Medicaid expansion | Yes, unless exempt |
| Georgia Pathways members and Wisconsin BadgerCare Plus adults without children | Yes, unless exempt |
| Children under 19 | No |
| Pregnant people and people with postpartum coverage | No |
| People on Medicare | No |
From 2027, Medicaid also renews expansion adults every 6 months instead of once a year (section 71107), and each renewal checks the work requirement.
What counts toward the 80 hours?
Each month, any one of these meets the requirement under section 1902(xx)(2) of the Social Security Act:
| Way to meet it | What counts |
|---|---|
| Work | 80 hours a month |
| Community service | 80 hours a month of unpaid work with a public or nonprofit organization that tracks your hours |
| A work program, such as job training | 80 hours a month |
| School | Enrolled at least half-time in school, such as college, a technical program or a GED program |
| A mix | Any combination of the above that adds up to 80 hours |
| Income | At least $580 a month, which is 80 hours at the $7.25 federal minimum wage |
| Seasonal work | Average income of at least $580 a month over the past 6 months |
CMS’s June 2026 rule (91 FR 33348) says states must use the federal minimum wage, not a higher state one. So the income test is $580 a month in every state.
Who is exempt from Medicaid work requirements?
Federal law treats these adults as meeting the requirement:
- Parents, guardians, caretaker relatives and family caregivers of a child 13 or younger or of a person with a disability
- Pregnant people and people with postpartum Medicaid coverage
- People who are blind or disabled, or medically frail: a substance use disorder, a disabling mental disorder, a disability that seriously limits daily activities, or a serious or complex medical condition
- Veterans with a disability rated as total
- American Indians, Alaska Natives and others eligible for the Indian Health Service
- Former foster youth under 26
- People who meet TANF’s work rules, or who get SNAP and are subject to SNAP’s work rules
- People in a drug or alcohol treatment program
- People in jail or prison, and for about 3 months after release
- People on Medicare, and anyone under 19
States may also excuse a month for a short-term hardship: a hospital or nursing home stay, living in a county with a federal disaster declaration or unemployment of at least 8% (or 1.5 times the national rate, if lower), or traveling far for serious medical care. Each state chooses whether to offer these.
Your state Medicaid agency decides who qualifies, using CMS’s standards. The law tells states to check data they already have, such as payroll records, before asking you for proof.
When do Medicaid work requirements start in each state?
| State | Start |
|---|---|
| Georgia | Pathways already requires 80 hours a month; its federal approval runs through Dec. 31, 2026 |
| Tennessee | 2027, for some TennCare parents, who TennCare says automatically meet it |
| Nebraska | May 1, 2026; current members are checked at renewals from July 31, 2026 |
| Montana | July 1, 2026, with denials from Oct. 1, 2026 |
| Arkansas | Checks from July 1, 2026; coverage can end from Jan. 1, 2027 |
| Iowa | Dec. 1, 2026 for applicants; current members at renewals from February 2027 |
| Wisconsin | Jan. 1, 2027 for BadgerCare Plus adults without children; current members at renewals from March 2027 |
| Every other state that expanded Medicaid | Jan. 1, 2027 |
A state can get a good-faith delay from CMS if it shows steady progress and serious barriers. CMS’s rule says a first approval lasts no more than 6 months, and no delay can run past Dec. 31, 2028. Coverage Decider found no approved delay as of Oct. 21, 2026. Medicaid.gov’s state finder links each state’s details.
How do you show you meet the work requirement?
- Keep your contact details current with your state Medicaid agency. Notices about the requirement come by mail and at least one other way, such as text or email.
- Keep proof of your hours each month: pay stubs, a volunteer log or a school enrollment letter. Keep medical records that show an exemption.
- When you apply, the state checks 1 to 3 months before the month you apply. Each state picks how many.
- At each renewal, you show at least one month since your last renewal. Some states ask for more.
- If the state can’t verify it, you get a notice and 30 days to show you meet the requirement or are exempt. Medicaid continues during those 30 days, and the state must check whether you qualify for coverage another way before it ends.
- If coverage ends, you can reapply at any time and ask for a fair hearing.
What does losing Medicaid do to the tax credit?
The same law treats someone who would qualify for Medicaid but for the work requirement as eligible for Medicaid when figuring the premium tax credit (section 1902(xx)(7)(B)). So there’s no tax credit for a Marketplace plan in those months. A full-price plan is still an option during 2027 open enrollment.
| Your situation in 2027 | Medicaid | Marketplace tax credit |
|---|---|---|
| Income under your state’s limit, meets the requirement or is exempt | Yes | No, because Medicaid comes first |
| Income under your state’s limit, doesn’t meet the requirement | No | No |
| Income over your state’s limit | No | Possible, up to 400% of the poverty line |
The bar lasts only while the work requirement is the sole reason you’re off Medicaid, under the IRS’s proposed rules of Oct. 15, 2026. In the IRS’s own example, a person denied Medicaid in January takes a new job in March that lifts income over the state’s limit, enrolls in March and gets advance credits from April. In expansion states the adult limit is 138% of the poverty line, $22,025 a year for one person at the 2026 guidelines: see Medicaid income limits by state.
How does Coverage Decider handle the work requirement?
Coverage Decider’s calculator asks about the work requirement only when an adult 19 to 64 lands in your state’s Medicaid range and none of the exemptions it asks about applies. If the answer is no, the result says federal law rules out both Medicaid and the tax credit for that person. How Coverage Decider calculates explains the rules it uses.
Your state Medicaid agency makes the final call on Medicaid. HealthCare.gov checks Medicaid first when you apply there, and free local help can walk you through either application.