Medicaid work requirements start January 1, 2027

By the MedicaidCalc Editorial Team · Published October 5, 2026 · Updated October 5, 2026

The 2025 reconciliation law (Public Law 119-21) made “community engagement” a condition of Medicaid eligibility for adults in the ACA expansion group, and CMS spelled out the details in an interim final rule published June 3, 2026 and effective July 31, 2026.^[1][2] States must apply it to Medicaid furnished on or after January 1, 2027; they may start earlier, and CMS may grant a state a temporary good-faith exemption that cannot run past December 31, 2028.^[1]

Who has to meet it

An “applicable individual” is someone age 19 through 64 who is eligible for or enrolled in the expansion adult group (or in a Section 1115 waiver giving similar coverage to that population, such as Georgia Pathways), is not pregnant, is not on Medicare Part A or B, and is not otherwise eligible under the state plan.^[1][3] Children, pregnant people, people 65+, parents in the regular parent/caretaker group and people on SSI-related Medicaid are not affected.

What counts: 80 hours, or the income equivalent

For each month the state checks, you meet the requirement if you did any of these:^[1]

• worked at least 80 hours (paid, in-kind, or unpaid work other than community service);
• completed at least 80 hours of community service with a public or nonprofit organization that tracks hours;
• took part in a qualifying work program (WIOA, Trade Act, SNAP employment and training, veterans’ programs) for at least 80 hours;
• were enrolled at least half-time in college, career and technical education, high school or a high-school-equivalency program;
• combined those activities to reach 80 hours; or
• earned at least the federal minimum wage times 80 hours in the month — $580 at $7.25 an hour — or, for seasonal workers, averaged that over the past six months.

Who is exempt

States must treat you as meeting the requirement for any month in which you were, for part or all of it:^[1]

• under 19, on Medicare, or eligible under a mandatory Medicaid group;
• an inmate of a public institution at any point in the three months before;
• pregnant or within the postpartum period;
• a parent, guardian, caretaker relative or family caregiver of a child 13 or younger or of a person with a disability;
• a former foster youth in the former-foster-care group, or American Indian or Alaska Native;
• a veteran with a total (100%) disability rating;
• medically frail — including blindness or disability, a substance use disorder (unless in stable recovery for five or more years), a disabling mental disorder, a disability that significantly limits daily activities, or a serious or complex medical condition;
• meeting TANF work requirements or in a SNAP household and not exempt from SNAP’s work rules; or
• in a drug or alcohol treatment and rehabilitation program.

States may also grant short-term hardship exceptions — for a hospital, nursing-facility or similar inpatient stay, or living in a county under a federally declared disaster or emergency, among others.^[1]

How states check

At application, a state must look at one to three consecutive months before the month you apply (the state chooses). At renewal it looks at one or more months since your last determination. The state must first try its own data — payroll records, SNAP and TANF files, Medicaid claims — before asking you for proof. Until January 1, 2028 a state may accept your statement in place of documents; after that it must require documents when they are reasonably available, but it cannot deny you for lacking documents that do not exist.^[1]

If the state cannot verify compliance, it must send a notice and give you 30 days to show you met the requirement or are exempt, and an enrolled person keeps coverage during that period.^[1]

Other changes for expansion adults

• Six-month renewals. For renewals scheduled on or after January 1, 2027, states must redetermine expansion adults every six months instead of every twelve, which the current regulation otherwise requires for MAGI groups.^[2][5]
• Shorter retroactive coverage. For applications made on or after January 1, 2027, Medicaid can pay bills back to the month before the application month for expansion adults, and back two months for everyone else (it used to be three).^[2]
• Cost sharing from October 1, 2028. Expansion adults above 100% of the poverty line will face copays of up to $35 per service, with primary care, mental health and substance use services and care at community health centers excluded.^[2]
• Immigrant eligibility from October 1, 2026. Federal Medicaid funding is limited to citizens and nationals, lawful permanent residents, Cuban and Haitian entrants, and people living in the U.S. under a Compact of Free Association, outside emergency care.^[2]

Georgia already does this

Georgia Pathways has required 80 hours a month since it began. Its own page says that from January 1, 2027 it moves to the federal rules, adding the $580 income test and the parent-of-a-child-13-or-under exemption, and dropping some of its old qualifying activities; current members are affected at their 2027 renewal.^[4]

What the calculator does with this

The calculator decides income eligibility only. When it finds an adult likely eligible through the expansion group, it adds a dated note about the requirement and six-month renewals; for Georgia Pathways it marks the row “income fits — other rules apply.” It never treats the work requirement as part of the income math. Check a household.