Understanding Medicaid Work Requirements

It is important to gain an understanding of what will be required so that we can do our best as a community to help people understand, meet, and document so that they can retain coverage. It will require responsible and effective uses of technology, a comprehensive communication strategy, and a streamlined, user-friendly documentation and implementation system. States are required to implement the requirement by January 1, 2027, so it is important to get a head start now understanding what the law requires is a good first step.

Who Is Impacted? 

The population of Medicaid members aged 19-64 who are covered through the Affordable Care Act Medicaid expansion or an 1115 demonstration waiver are the impacted group.  Individuals in this group must (unless they fall into one of the exempted groups outlined below) demonstrate that they are engaged at least 20 hours a week, or 80 hours per month in employment, education, a work program, or community service to maintain their Medicaid eligibility. 

It is important to note that there are many groups that are exempted from Medicaid Work Requirements, including:

• Individuals under age 19
• Pregnant individuals entitled to or enrolled in Medicare Part A or B benefits
• Foster youth
• Individuals enrolled in the Parents and Other Caretaker Relatives eligibility group
• Individuals eligible for a mandatory eligibility group
• Individuals recently incarcerated in the previous three months
• American Indians, Alaska Natives, and California Indians
• Parents, guardians, or caregivers of dependent children 13 years or younger or disabled individuals
• Veterans with total disability ratings
• Former foster care youth under age 26
• Medically frail individuals or those with special medical needs [as defined by the Secretary of the United States Department of Health and Human Services (HHS)], including:
• Blind or disabled individuals
• Individuals with a substance-use disorder
• Individuals with a disabling mental disorder
• Individuals with a physical, intellectual, or developmental disability that significantly impairs their ability to perform one or more activities of daily living
• Those with serious or complex medical conditions
• Individuals complying with Temporary Assistance for Needy Families (TANF) work requirements
• Members of a household that is in receipt of Supplemental Nutrition Assistance Program (SNAP) and not exempt from SNAP work requirements
• Individuals participating in a drug addiction or alcohol treatment and rehabilitation program
• Inmates of public institutions
• Pregnant individuals or those receiving postpartum coverage

It is also possible that states may allow exemptions for extenuating circumstances, including individuals receiving care in hospitals, nursing facilities, psychiatric facilities, or other intensive care settings, individuals in a federally declared disaster area, individuals living in counties with unemployment rates higher than eight percent, or 1.5 times the national unemployment rate (pending permission from HHS secretary), and individuals or their dependents who are required to travel outside their home for medical care for an extended time.

What Are the Timelines?

In general, states are required to communicate to impacted beneficiaries in at least two modalities between June and September 2026.  Full implementation of the requirements will begin by December 31, 2026.  Timing may vary slightly as states may appeal to the federal government for adjustments to the requirements.

Are There Helpful Resources Available?

The Center for Health Care Strategies has created a helpful and concise tool (A Summary of National Medicaid Work Requirements) that captures the essentials and may be helpful to share with your team members.  As well, the Kaiser Family Foundation has prepared a helpful explainer that provides a closer look at the requirements.