Medicaid Work Requirements 2027: Who Must Report, Who Is Exempt, and Your Coverage Options

Starting January 1, 2027, most adults ages 19 to 64 who get Medicaid through the ACA expansion must show they work, volunteer, go to school or join a work program for 80 hours a month, or earn at least $580 a month. Parents of children 13 and younger, pregnant people, people who are medically frail and several other groups are exempt. If you lose Medicaid for not meeting the rule, you cannot get ACA premium tax credits for a Marketplace plan instead.

Medicaid Work Requirements at a Glance

Who Has to Meet the Work Requirement?

The rule comes from the 2025 budget law, H.R. 1, now Public Law 119-21. It applies to the ACA expansion group: low-income adults ages 19 to 64 who do not qualify for Medicaid another way, such as through pregnancy or disability. It also covers some people in similar state waiver programs.

About 20 million people were in the Medicaid adult group in fiscal year 2025. CMS projects the rule will cut enrollment by 2.3 million people in fiscal year 2027 and by 3.1 million to 3.3 million in later years. CMS also assumes 7% of people who are working, in school or exempt could lose coverage over paperwork.

How to Meet the Requirement Each Month

You meet the rule for a month if you do one of these:

• Work at least 80 hours.
• Do community service for at least 80 hours.
• Join a work program for at least 80 hours.
• Go to school at least half-time, including career or technical training.
• Mix these activities for a total of 80 hours.
• Earn at least $580 that month. That is the $7.25 federal minimum wage times 80 hours.

Seasonal workers can use their average monthly income over the past 6 months instead.

Who Is Exempt From Medicaid Work Requirements?

The law excludes these groups:

• Parents, guardians and caretakers of a child 13 or younger, and caregivers of a person with a disability
• People who are pregnant or postpartum
• American Indians and Alaska Natives
• People who are medically frail, such as people who are blind or disabled or have a substance use disorder, a disabling mental disorder or a serious medical condition
• Veterans with a total disability rating
• People who meet TANF work rules, or who live in a SNAP household and are not exempt from SNAP work rules
• People in a drug or alcohol treatment program
• Current and former foster youth up to age 26
• People in jail or prison, or released in the past 3 months

People on Medicare are also outside the rule. The CMS rule narrows the medically frail group: you must show your condition significantly limits your ability to meet the requirement. States may also excuse a month for a hospital stay, a disaster or high unemployment in your county, or long travel for serious medical care.

How States Will Check

When you apply. Your state can ask you to prove you met the rule for 1, 2 or 3 months in a row before you apply.

While you are enrolled. You must show you met the rule for at least 1 month between checks. Checks happen at renewal, and states may check more often.

Renewals every 6 months. Starting January 1, 2027, expansion adults renew every 6 months instead of every 12. American Indians and Alaska Natives are exempt.

Data first. States must try payroll records, Medicaid claims and other data before asking you for anything. In 2027, if the data is not enough, states may accept your own statement or ask for documents. Starting in 2028, states must ask for documents when they are reasonably available.

If the state cannot confirm. You get a notice and 30 days to show you met the rule or are exempt. Your coverage continues during that time. Before ending coverage, the state must check whether you qualify another way. You also have the right to a fair hearing.

State-by-State Status

Expansion states. KFF counts 41 states, including D.C., that have expanded Medicaid. All must apply the rule by January 1, 2027, unless CMS grants a delay.

Non-expansion states. Most adults here are not affected, because there is no expansion group. The exceptions are waiver programs in Georgia and Wisconsin, which cover part of the expansion population, and Tennessee, which covers a small group of adults.

Early starters. Nebraska began on May 1, 2026, according to CMS. Georgia has had its own work requirement since 2023, and KFF says it must follow the federal rules from January 1, 2027. KFF also lists early dates for Montana (July 1, 2026) and Iowa (December 1, 2026), and an Arkansas soft start with no one dropped before January 1, 2027.

Delays. A state that shows a good faith effort can ask CMS for more time. CMS expects first approvals to last no more than 6 months. Extensions cannot go past December 31, 2028.

Your state Medicaid agency has your local dates. To compare states for low-income adults, see the best states for low-income health care.

What Happens to Marketplace Coverage If You Lose Medicaid?

If you would qualify for Medicaid except that you did not meet the work requirement, the law treats you as eligible for Medicaid. That blocks you from premium tax credits. CMS says these people are “precluded from eligibility for APTC and PTC.” You can still buy a Marketplace plan at full price, but for most people that will not be affordable.

If your income rises above your state’s Medicaid limit, or your household size changes, you may qualify for a Special Enrollment Period and a plan with a tax credit. People who lose Medicaid for other reasons, such as higher income, can also apply for savings. Our ACA subsidy calculator can show what you might get. If you already have a Marketplace plan, see what losing ACA subsidies in 2027 could mean for you.

What to Do If You Lose Medicaid

1. Read every notice. Keep your contact details current with your state Medicaid agency.
2. Answer within 30 days. Send proof of hours, income, school or an exemption. Keep pay stubs and volunteer logs.
3. Appeal if the state got it wrong. You have the right to a fair hearing. If you were dropped for not returning paperwork, you generally have 90 days to send it and get coverage back without a new application.
4. Check HealthCare.gov. If you lost Medicaid for another reason, such as higher income, apply at HealthCare.gov. You may qualify for a Special Enrollment Period if you lost coverage in the past 60 days or expect to lose it in the next 60 days. HealthCare.gov says people who lost Medicaid or CHIP in the past 90 days may qualify.
5. Use open enrollment. Open enrollment for 2027 runs November 1, 2026, to January 15, 2027. Enroll by December 15 for coverage that starts January 1. See our 2027 open enrollment guide and our guide to 2027 Marketplace plans.
6. Find low-cost care. Community health centers charge on a sliding scale.

Frequently Asked Questions

When do Medicaid work requirements start?

The federal deadline is January 1, 2027. Nebraska started on May 1, 2026. A state that shows a good faith effort can get a delay, but it must end by December 31, 2028.

Who is exempt from Medicaid work requirements?

Exempt groups include parents and caretakers of children 13 and younger, pregnant and postpartum people, American Indians and Alaska Natives, people who are medically frail or disabled, veterans with a total disability rating, and people who meet SNAP or TANF work rules.

How much income do I need to meet the Medicaid work requirement?

At least $580 a month. That is 80 hours times the $7.25 federal minimum wage. You can also meet the rule with 80 hours of activity or half-time school.

Can I get ACA subsidies if I lose Medicaid over the work requirement?

No. If you would qualify for Medicaid except for the work requirement, you cannot get premium tax credits for a Marketplace plan. You can buy one at full price. If your income later rises above the Medicaid limit, you may qualify for savings.

How often will I have to prove I meet the requirement?

At least at each renewal, which happens every 6 months for expansion adults starting in 2027. States may check more often.

This article is for general information only and is not legal advice. Rules and start dates vary by state.

Sources

• Public Law 119-21 (H.R. 1), Sections 71107 and 71119
• CMS, Medicaid Program; Community Engagement Requirement for Certain Individuals, Interim Final Rule, 91 FR 33348 (June 3, 2026)
• Beyond the Basics, Work Requirements and Six-Month Redeterminations
• KFF, Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements
• KFF, Medicaid Work Requirements Tracker: 1115 Waivers and Early Implementation
• KFF, Status of State Medicaid Expansion Decisions
• State Health and Value Strategies, CMS Releases Interim Final Rule on Medicaid Work Reporting Requirements
• healthinsurance.org, Medicaid Work Requirement
• HealthCare.gov, Special Enrollment Periods
• HealthCare.gov, Get Marketplace Coverage If You Lose or Are Denied Medicaid or CHIP
• HealthCare.gov, Medicaid Expansion and What It Means for You
• HealthCare.gov, Dates and Deadlines