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Medicaid Work Requirements: Who Needs 80 Hours, Who’s Exempt, and What the July 2027 Delay Means

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The short answer

Starting Jan. 1, 2027, many adults ages 19 to 64 on Medicaid will have to show 80 hours a month of work, volunteering, a work program or school, or income of at least $580 a month, to get or keep coverage. Many people are exempt, including parents of children 13 or younger.

The start date didn’t move. What changed on Nov. 13, 2026 is that CMS let states hold off on cutting coverage for it until June 30, 2027. A state that takes the option still checks everyone from January, but won’t deny or end your Medicaid only for missing the hours.

The rule mostly reaches adults covered through Medicaid expansion: CMS counts 43 states and D.C.

General information, not legal advice. The agency that runs the program decides who qualifies and how much.

At a glance

Starts
Jan. 1, 2027 (states could start earlier)
The delay
Optional “hold harmless” through June 30, 2027: no denials or cutoffs only for this rule. States tell CMS by Dec. 11, 2026
Who
Ages 19–64 in Medicaid’s expansion adult group (or similar coverage under a waiver), not pregnant, not on Medicare
The test
80 hours a month of work, community service, a work program or a mix; or school at least half-time; or income of $580+ a month
Exempt
Parents and caretakers of a child 13 or younger, pregnant, medically frail, veterans rated 100%, American Indian or Alaska Native, and more
When checked
When you apply (1 to 3 months before) and at renewal; your state picks
If it can’t verify
You get a notice and 30 days to answer; you can reapply anytime
Where
43 states and D.C., CMS says; not U.S. territories
Last checked
Friday, Nov. 13, 2026, against the sources at the end of this page
Kentucky state career counselors at a table with brochures talk with a job seeker holding papers
Kentucky state career counselors at a career summit at Fort Knox, Ky., Sept. 22, 2026. Hours in state-approved job training programs count toward the 80. Photo: Eric Pilgrim, Fort Knox, via DVIDS

What CMS changed on Nov. 13

CMS sent states a letter (SMD 26-006) offering an optional “hold harmless” period through June 30, 2027. Here’s what it does and doesn’t do:

  • The rule still starts Jan. 1. States must still check whether you meet it or are exempt, for every application and renewal.
  • What pauses: denials and cutoffs only for not showing the 80 hours. It covers applications received and renewals started through June 30, 2027, or a shorter window a state picks.
  • What doesn’t pause: everything else. You can still lose coverage for income, age or not returning renewal paperwork.
  • It’s each state’s choice. States that want it from Jan. 1 are asked to tell CMS by Dec. 11, 2026.
  • After it ends, a state that can’t confirm you meet the rule must deny or end coverage, after the 30-day notice below.

Separately, the rule lets CMS give a state that shows a “good faith effort” more time, six months at a time and never past Dec. 31, 2028.

Who has to meet it

The rule covers adults 19 to 64 who get Medicaid through the expansion adult group (or similar coverage under a state waiver), who aren’t pregnant and aren’t on Medicare. CMS counts 43 states and D.C. with that coverage. The territories aren’t included.

If you get Medicaid another way, as a parent in your state’s parent group or through SSI, for example, the rule counts you as meeting it.

How to meet it

Any one of these works for a month:

Way to meet it What counts Rule of thumb
Work, 80 hours A paid job, work paid in goods or services, or unpaid work About 18.5 hours a week
Community service, 80 hours Unpaid work with a nonprofit or public program that oversees it and logs your dates and hours, with a contact who can confirm them. Nothing partisan Ask the organization for its hours log
Work program, 80 hours Job training under the federal workforce law (WIOA), Trade Act training, state-approved employment and training programs (including SNAP’s), and VA or Labor Department programs for veterans Job search counts only as a side part, under half the hours
School, at least half-time College, career and technical education, high school or a GED program. The school decides what half-time is Meets the rule by itself, no hours to add
A mix of the above Any combination adding up to 80 hours. Less than half-time school counts 3 hours a week per credit hour 6 credit hours = 77.9 hours a month
Income Monthly income of at least $580: 80 hours × $7.25, the federal minimum wage. Seasonal workers use their average over the last 6 months $580 a month, no matter the hours

The quickest test is income. At $580 a month before taxes, you meet the rule however many hours that took. If your state has no record of your hours, it may count them from your pay: income ÷ $7.25.

Who’s exempt

These people don’t have to meet the 80 hours at all:

You don’t have to meet it if you’re… Details
A parent, guardian or caretaker Of a child 13 or younger, or of a person with a disability. Family caregivers count too, including relatives who help regularly but live elsewhere
Pregnant or postpartum For as long as you have pregnancy or postpartum coverage
Medically frail Blind or disabled; a substance use disorder (unless in recovery 5+ years); a disabling mental disorder; a disability that limits daily activities; or a serious or complex medical condition. Each state keeps a list of conditions and must let you ask to be considered
American Indian or Alaska Native As Medicaid defines it
A former foster youth In Medicaid’s former foster care group
A veteran rated 100% disabled By the VA, temporary or permanent
In addiction treatment A drug or alcohol treatment and rehabilitation program; states may set a minimum time
Meeting SNAP or TANF work rules In a household getting SNAP and subject to its work rule, or complying with your state’s TANF work rules
In jail or prison, or out within 3 months Counted as meeting the rule for the 3 months after release
Under 19 or on Medicare For any month you were, even part of it

States may also excuse a month for short-term hardships, if they choose to offer it: a hospital or nursing home stay, living in a county under a presidential disaster declaration or with unemployment of 8% or more (or 1.5 times the national rate), or traveling far for serious medical care for you or a dependent.

When your state checks, and what happens if it can’t confirm

  • When you apply: you show 1 to 3 months in a row just before the month you apply. Your state picks how many.
  • At renewal: at least one month since your last renewal. States can also check more often.
  • Already enrolled? Your first check comes at your first renewal on or after your state’s start date.
  • Records first: the state must look at what it already has (payroll data, SNAP and other agency records, medical claims) before asking you for anything.
  • If it still can’t confirm: it sends a notice and gives you 30 calendar days to show you meet the rule or are exempt. If you don’t, the application is denied or coverage ends.
  • You can reapply at any time. You’ll be checked again when you do.

What to do now

  • Make sure your state Medicaid office has your current address, phone and email. The notice is the clock.
  • If you’re exempt, say so when you’re asked, especially for a medical condition the state may not see in its records.
  • Keep a record of your hours from January: pay stubs, a volunteer log, program attendance.
  • Watch for news from your state by Dec. 11 on whether it takes the hold-harmless option.
0:48
New Medicaid rule could make coverage harder to keep KCEN News · June 8, 2026KCEN on the June 2026 rule, before CMS offered states the hold-harmless option.

How we did the math

A month counts as 4.33 weeks, the factor the rule itself uses for credit hours, so 80 hours a month is about 18.5 hours a week. $580 is 80 hours times $7.25, the federal minimum wage; CMS uses the same figure for 2026. Less than half-time school: credit hours × 3 × 4.33 (6 credits = 77.9 hours).

What we don't know yet

  • Which states will take the hold-harmless option. CMS asked for notice by Dec. 11, 2026.
  • How many months each state will check at application (1 to 3) and at renewal.
  • Which part of the rule a federal court set aside on Oct. 29, 2026 (Massachusetts v. Oz). CMS says states don’t have to carry out the vacated portion; we haven’t read the decision.
  • Whether Congress changes the requirement before or after it starts.

When any of this is confirmed, it goes into the page and the update history below.

Questions people ask

When do Medicaid work requirements start?

Jan. 1, 2027, in the 43 states and D.C. that cover the Medicaid expansion adult group. Some states could start earlier. The start date didn’t change on Nov. 13.

Were Medicaid work requirements delayed to July 2027?

Not the requirement itself. CMS let states choose a hold-harmless period through June 30, 2027, when they check compliance but don’t deny or end coverage only for missing the 80 hours.

How many hours do you have to work for Medicaid?

80 hours a month of work, community service, a work program or a mix, which is about 18.5 hours a week. School at least half-time, or income of at least $580 a month, also meets it.

Does volunteering count for Medicaid work requirements?

Yes, if it’s unpaid community service with a nonprofit or public organization that oversees it and keeps a log of your dates and hours. Partisan activity doesn’t count.

Are parents exempt from Medicaid work requirements?

Yes, parents, guardians and caretakers of a child 13 or younger, or of a person with a disability, are exempt. So are pregnant people, the medically frail, veterans rated 100% disabled and several other groups.

What happens if I can’t prove my hours?

Your state must first check its own records. If it still can’t confirm, it sends a notice and gives you 30 days. If you don’t answer, it can deny or end coverage, but you can reapply at any time.

Does the work requirement apply to people on Medicare or SSI?

No. People on Medicare, and those who get Medicaid through another group such as SSI, are counted as meeting it.

Sources

  1. CMS press release: hold harmless period for the Medicaid work requirement (Nov. 13, 2026), checked Nov. 13, 2026
  2. CMS State Medicaid Director letter SMD 26-006, Optional Hold Harmless Period (Nov. 13, 2026), checked Nov. 13, 2026
  3. CMS fact sheet: Community Engagement Requirement interim final rule, CMS-2454-IFC (June 1, 2026), checked Nov. 13, 2026
  4. Federal Register: Medicaid Program; Community Engagement Requirement for Certain Individuals (June 3, 2026), 42 CFR 435.550–435.563, checked Nov. 13, 2026

Update history

  • Published with CMS’s Nov. 13 letter to states and the June 2026 rule.

Edited and signed by

Bruno Monteiro founded Price Folk and edits every page on it. He has spent more than 15 years building content platforms read by millions, including six and a half years at Empiricus, a financial research publisher with more than 400,000 paying subscribers, where he rose to director of IT.

Every price, date and condition on this page was checked against the sources above. Bruno reads every page line by line and signs it; what his review changes goes into the update history.

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