CMS projects that 2.3 million people will come off Medicaid in the first year of the new work requirement. The uncomfortable part is that a large share of them will still be eligible on the day their coverage ends.
Not because they were not working. Because a form did not arrive, or a data match failed, or a letter went to an old address. If you are covered through Medicaid expansion, this page is about making sure you are not one of them.
First: does this even apply to you?
It applies only if all four of these are true:
You are aged 19 to 64
You are not pregnant
You are not on Medicare
Your Medicaid comes through the adult expansion group or certain waiver programmes
Children, people over 65, and most people covered on the basis of disability or pregnancy are outside it entirely. If you are not sure which category you are in, your state Medicaid office can tell you in one call — and that is worth doing before December rather than after.
The rule, briefly
CMS issued the interim final rule on 1 June 2026, implementing a requirement created by H.R.1. Affected adults must demonstrate 80 hours a month of qualifying activity as a condition of eligibility. States must generally implement by 1 January 2027. Forty-three states and DC are affected; territories are not.
Renewals also change. Most expansion adults move from annual redetermination to every six months, and the state must confirm compliance for at least one month within each review period. New applicants face a look-back covering one to three months before applying.
There are six ways to hit 80 hours, not one
Qualifying activities under the June 2026 interim final rule.
The income route is the one people miss. If you earned at least $580 in a month — 80 hours at the federal minimum wage — that satisfies the requirement regardless of how many hours it took you. For anyone paid above minimum wage, the hours bar is effectively lower than it sounds.
Combining also matters more than it appears. Twenty hours of paid work, forty hours of study and twenty hours of volunteering is a compliant month. If your work is irregular, map the whole month rather than one job.
Where people are actually going to fall out
Georgia has run a work requirement since 2023, and procedural terminations have been the dominant failure mode there.
This distinction is the single most useful thing to understand about the new system. The rule is designed to test whether you are working. In practice, it mostly tests whether your state’s computer can see that you are working.
States are required to check electronic sources first — payroll records, Medicaid claims and encounter data — before asking you for anything. That is called ex parte verification and when it works, you may never hear about the requirement at all. It fails predictably: cash work, gig platforms, multiple short jobs, a new employer, a recent move, a name change.
Exemptions, including the ones people don’t claim
The statute exempts a long list of people. Several categories are routinely missed by the people they cover:
- Parents and caregivers of young children, or of a person with a disability. Unpaid family caregiving is care work, and it counts.
- Medically frail individuals, and people with disabilities. Note that CMS reads this more narrowly than in some earlier programmes, requiring that the condition significantly impairs your ability to comply.
- Veterans with a total disability rating.
- American Indian and Alaska Native enrollees.
- Former foster youth.
- Pregnant and postpartum individuals.
- Anyone already meeting SNAP or TANF work requirements — if you are complying there, you should not be asked to comply twice.
States may also offer optional hardship exemptions: living in a county with unemployment at or above 8% or 1.5 times the national rate, being affected by a federally declared disaster, being admitted to a hospital or nursing facility, or having to travel outside your community for care. These are optional, and not every state is offering them — Indiana and Iowa have said they will not.
Do not assume an exemption is already recorded. Some transfer automatically from existing data, such as a disability determination already held by the Social Security Administration. Others — caregiver status in particular — may need to be confirmed with your state Medicaid office. Assuming it is on file is one of the most expensive assumptions available here.
How you prove it, and the change coming in 2028
Georgia has required this since 2023; Nebraska began May 2026, Montana and Arkansas in July, and Iowa is scheduled for December.
Through the end of 2027, if the state cannot verify you from electronic data, you may generally self-attest — state your hours yourself, under penalty of perjury. From 1 January 2028 that changes: states must generally require documentation where it is reasonably available, though they must still accept self-attestation when it is not.
The practical read: 2027 is the forgiving year and 2028 is not. Start keeping pay stubs, schedules, enrolment letters and volunteer confirmations now, in one folder, rather than assembling them under a 30-day deadline later.
If a noncompliance notice arrives
Before terminating anyone, the state must issue a notice of noncompliance and allow 30 calendar days to make a satisfactory showing. Calendar days, not business days, and the clock starts at the notice date rather than the day you open the envelope.
Respond even if you think it is a mistake — especially if you think it is a mistake, because a data-match failure is exactly what the response window exists to fix. Send what you have: pay stubs, a letter from an employer, school enrolment confirmation, or documentation of an exemption. Keep a copy and a record of the date you sent it.
If coverage ends anyway, you can reapply at any time, and you have the right to appeal. Check the termination notice for your state’s appeal deadline, which is separate from the 30-day window.
The trap almost nobody has been told about
If you are income-eligible for Medicaid but lose it for failing to meet or prove the work requirement, you are not eligible for a premium tax credit to buy a marketplace plan instead. The usual fallback is not available. That is what makes the 30-day window worth treating as urgent rather than administrative.
What to do before January
Update your address and phone number with your state Medicaid office. Every warning in this system arrives by mail or portal message, and the most common reason people miss one is that it went somewhere else.
Find out whether you are in the expansion group, and if you might be exempt, confirm the exemption is recorded rather than assuming it.
Start the folder. Pay stubs, schedules, enrolment letters, volunteer hours. Monthly, as they arrive.
Check your state’s start date. Several states are ahead of the federal deadline, and a few are running early implementations with different rules during the transition.
One note on where this stands: the rule was issued as an interim final rule with a comment period that closed on 31 July 2026, and the details of implementation continue to develop at state level. Confirm anything specific to your situation with your own state Medicaid agency rather than relying on a national summary, including this one.
Keep reading
What a doctor visit costs without insurance — sliding-scale clinics and cash prices, if there is a gap in coverage.
Check whether a doctor is really in your network — worth doing whenever coverage changes.
Can a hospital make you pay before treating you? — your rights if a deposit is demanded during a coverage gap.
Are vaccines still free in 2026? — how Medicaid and CHIP fit into vaccine access.
Sources
- CMS — Interim final rule fact sheet (CMS-2454-IFC)
- Beyond the Basics — Work requirements and six-month redeterminations
- Center for Health Care Strategies — Summary of federal Medicaid work requirements
- Foley Hoag — Verification, self-attestation and the 2028 change
- Epstein Becker Green — Notice requirements and the medically frail standard
- Medicaid.gov — find your state agency
This article summarises federal rules as published and is not legal advice or a determination of your eligibility. Implementation details, exemptions and deadlines vary by state and are still being developed. Always confirm with your state Medicaid agency, and consider free help from a certified navigator or legal aid organisation if your coverage is at risk.
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