Medicaid work requirements are now federal law. The One Big Beautiful Bill Act, signed on July 4, 2025, mandates that able-bodied adults in Medicaid's expansion population complete at least 80 hours per month of qualifying activity to keep their coverage. States must have systems in place by January 1, 2027, though several states started enforcing requirements earlier in 2026. This tracker covers which states are already live, which are preparing, and what exemptions protect millions of current enrollees.
What the Law Actually Requires
The requirement applies to non-pregnant adults between ages 19 and 64 who are enrolled in the ACA Medicaid expansion group or certain Section 1115 waiver programs. To stay enrolled, they must complete at least 80 hours per month of one or more qualifying activities.
Qualifying activities include:
- Employment (paid or unpaid)
- Job training or vocational education
- Community service or volunteer work
- Enrollment in a work or education program (TANF, SNAP E&T, etc.)
- Half-time enrollment in an educational institution counts on its own
States must verify compliance at application, at renewal (every 6 months for most states), and in some states more frequently. If verification fails, the state sends a noncompliance notice giving the enrollee 30 calendar days to demonstrate compliance or claim an exemption.
Who Is Exempt
Exemptions are broad, and most analysts expect a large share of the current expansion population to qualify for at least one. Federal law mandates exemptions for:
| Category | Details |
|---|
| Pregnant individuals | Exemption continues through the postpartum period (typically 60 days after birth) |
| Disabled individuals | Those receiving SSI, SSDI, or who qualify as medically frail |
| Medically frail | CMS June 2026 rule requires demonstrating impaired ability to work, not just a qualifying condition |
| Caregivers | Parents or caretakers of a child under 14, or a person with disabilities |
| Full-time students | Enrolled half-time or more in an accredited program counts as meeting the 80-hour requirement |
| American Indians and Alaska Natives | Fully exempt under the law |
| Already subject to work requirements | Individuals in TANF or SNAP E&T programs are deemed compliant |
| Substance use disorder treatment | Active participation in a qualifying SUD treatment program |
| Incarcerated individuals | Exempt during incarceration |
States may also offer optional hardship exemptions for people in high-unemployment counties (unemployment at or above 8% or 1.5 times the national average), those affected by federally declared disasters, people admitted to hospitals or nursing facilities, and those who must travel outside their community for medical care not available locally. Indiana and Iowa are the only states that have announced they will not offer any optional hardship exemptions.
State-by-State Status Tracker
The federal deadline is January 1, 2027, but states may implement earlier through a state plan amendment. Here is the current status as of late June 2026.
States Live or Launching in 2026
| State | Implementation Date | Notes |
|---|
| Nebraska | May 1, 2026 | First state to go live; using state plan amendment |
| Montana | July 1, 2026 | Full enforcement beginning July 2026 |
| Arkansas | July 1, 2026 | Soft launch; notifications start July 2026, disenrollments begin January 2027 |
| Iowa | December 1, 2026 | No optional hardship exemptions; quarterly verification |
| Indiana | Targeting 2026 | Quarterly verification; no optional hardship exemptions |
States Implementing January 1, 2027 (All Expansion States)
The law covers all 41 states plus DC that have adopted ACA Medicaid expansion. The remaining states in this group are targeting the federal January 1, 2027 deadline. States with larger Medicaid populations and more complex systems (California, New York, Illinois, Washington) have signaled they will implement on the deadline rather than early.
| State | Status | Notes |
|---|
| California | Implementing Jan 2027 | Largest expansion population in the country |
| New York | Implementing Jan 2027 | Also subject to requirements via 1115 waiver population |
| Illinois | Implementing Jan 2027 | Working with existing Deloitte vendor |
| Texas | Not affected by expansion rule | Non-expansion state; no expansion population to require |
| Florida | Not affected by expansion rule | Non-expansion state |
| Georgia | Existing 1115 waiver | Georgia Pathways work requirement active since 2023; waiver expires Dec 31, 2026; must realign with federal requirements Jan 2027 |
| Tennessee | Affected via 1115 waiver | Non-expansion state but has waiver enrollees subject to the rule |
| Wisconsin | Affected via 1115 waiver | Non-expansion state but has waiver enrollees subject to the rule |
| Idaho | Implementing Jan 2027 | Governor signed state legislation April 2026 |
| Massachusetts | Affected via 1115 waiver | Expansion state; waiver population also subject to rule |
| Hawaii | Affected via 1115 waiver | Expansion state; waiver population subject to rule |
| Oregon | Affected via 1115 waiver | Expansion state; waiver population subject to rule |
| Utah | Affected via 1115 waiver | Expansion state; waiver population subject to rule |
| New Hampshire | Implementing Jan 2027 | Quarterly verification requirement |
| Colorado | Implementing Jan 2027 | Publishing FAQ and outreach materials |
| Michigan | Implementing Jan 2027 | Working with state vendor |
| Ohio | Implementing Jan 2027 | Working with state vendor |
| Pennsylvania | Implementing Jan 2027 | Working with state vendor |
| Virginia | Implementing Jan 2027 | Working with state vendor |
| Washington | Implementing Jan 2027 | Apple Health expansion population affected |
| All other expansion states | Implementing Jan 2027 | Following federal deadline |
States Not Affected by the Federal Expansion Rule
These states never adopted ACA Medicaid expansion. They have no expansion population, so the mandatory rule does not apply unless they have 1115 waiver enrollees that CMS identifies as covered.
| State | Expansion Status | 1115 Waiver Work Requirement |
|---|
| Texas | Non-expansion | Not currently required |
| Florida | Non-expansion | Not currently required |
| Alabama | Non-expansion | Not currently required |
| Mississippi | Non-expansion | Not currently required |
| South Carolina | Non-expansion | Not currently required |
| Kansas | Non-expansion | Not currently required |
| Wyoming | Non-expansion | Not currently required |
| Georgia | Non-expansion | Existing Pathways waiver; must realign Jan 2027 |
| Tennessee | Non-expansion | Identified by CMS in June 2026 as having waiver enrollees subject to rule |
| Wisconsin | Non-expansion | Identified by CMS in June 2026 as having waiver enrollees subject to rule |
Required State Outreach Before Enforcement
The law and CMS guidance require state Medicaid agencies to conduct member outreach between June 30 and August 31, 2026. States must contact all enrollees who will be subject to work requirements by:
- First-class mail (required)
- At least one additional method: phone, text message, website, email, or other electronic means
The outreach must explain what the work requirement is, how to document compliance, and how to claim an exemption. This window matters because millions of people who are already working or already qualify for an exemption may still lose coverage through administrative churn if they do not respond to verification requests.
How Many People Could Be Affected
The Congressional Budget Office projects that work requirements alone will cause approximately 5.2 million people to lose Medicaid coverage by 2034, reducing federal Medicaid spending by roughly $326 billion over 10 years. That estimate is the single largest source of savings in the reconciliation law's Medicaid provisions.
Critically, CBO and independent health policy researchers expect most of those coverage losses will not result from people who are genuinely out of compliance. The bigger driver is administrative burden: people who are working, are caregivers, or qualify for exemptions but cannot navigate the documentation process in time. This pattern was well documented during the 2023 Medicaid unwinding, when millions of people lost coverage at renewal primarily due to paperwork issues rather than actual ineligibility.
What Happens If You Do Not Comply
If a state determines you have not met the work requirement and you do not qualify for an exemption, the timeline works as follows:
- State sends a noncompliance notice
- You have 30 calendar days to demonstrate compliance or establish an exemption
- If you do not respond or cannot demonstrate compliance, coverage terminates
- You must reapply and demonstrate compliance to re-enroll
One critical detail: if you lose coverage and later re-establish compliance, you can re-enroll. But any medical expenses during the gap in coverage are your responsibility. Getting ahead of the requirement before enforcement begins is far safer than trying to re-enroll after the fact.
How to Verify Your Status or Find an Exemption
If you are currently on Medicaid and live in an expansion state, you should expect outreach from your state Medicaid agency by August 31, 2026. If you do not receive anything by September 2026, contact your state Medicaid office directly to ask whether you will be subject to the requirement and what documentation you need to provide.
You can also use the Benefits Navigator screener at /screener to check your current program eligibility and get guidance on which exemptions may apply to your situation.
Steps to take now:
- Confirm your mailing address with your state Medicaid agency is current. Most outreach goes by mail first.
- Check whether you qualify for an automatic exemption (disability, pregnancy, caregiver status, student status, tribal membership).
- If you are working, gather documentation: pay stubs, employer letters, or records from a staffing agency.
- If you are doing volunteer or community service work, get written documentation from the organization.
- If you are in job training or an educational program, get enrollment verification from your school or program.
- If you live in a high-unemployment county, ask your state whether the county-level hardship exemption applies.
State Verification Frequencies
Two policy decisions that vary significantly by state are how often states will verify compliance and how far back they will look.
| Verification Policy | States Using This Approach |
|---|
| Every 6 months at renewal | Majority of implementing states |
| Quarterly | Indiana, New Hampshire |
| 1-month lookback at application | Most states |
| 3-month lookback at application | Idaho, Indiana |
| 3-month lookback at renewal | Arkansas |
States using AI-assisted document processing (approximately 6 states as of mid-2026) may be able to process verification faster, but that also means errors in automated systems could cause incorrect terminations.
Frequently Asked Questions
Who is exempt from Medicaid work requirements?
Federal law exempts pregnant and postpartum individuals, people receiving SSI or SSDI, those determined to be medically frail, parents or caretakers of children under 14 or people with disabilities, American Indians and Alaska Natives, people already in TANF or SNAP work programs, those in substance use disorder treatment, and incarcerated individuals. States may add optional hardship exemptions for high unemployment counties, disaster-affected areas, and hospital or nursing facility stays.
When do Medicaid work requirements start?
The federal deadline is January 1, 2027. Nebraska started enforcement on May 1, 2026. Montana begins July 1, 2026. Arkansas starts notifying enrollees July 1, 2026, but will not disenroll anyone until January 2027. Iowa begins December 1, 2026. All other expansion states are implementing January 1, 2027 unless they announce earlier dates.
Do work requirements apply if my state did not expand Medicaid?
If your state has not adopted ACA Medicaid expansion (Texas, Florida, Alabama, Mississippi, South Carolina, Kansas, Wyoming, Georgia, Tennessee, Wisconsin), the mandatory expansion population rule does not apply to you because there is no expansion population. However, Tennessee and Wisconsin have 1115 waiver enrollees that CMS has identified as subject to the requirement. Georgia's existing Pathways waiver must realign with federal requirements by January 2027.
What counts as qualifying work activity?
Qualifying activities include paid employment, unpaid work, job search activities in a work program, vocational training, community service, volunteer work, and enrollment in an educational program. Half-time enrollment in an accredited educational institution on its own satisfies the 80-hour requirement without needing to combine it with other activities.
What happens if I lose Medicaid coverage due to work requirements?
If you lose coverage, you can reapply once you can document compliance or establish an exemption. Expenses during the gap in coverage are your responsibility. Depending on your income and household size, you may qualify for ACA marketplace coverage with subsidies if you lose Medicaid. The Benefits Navigator screener can show you what other programs you may be eligible for.
How does the 80-hour requirement work for caregivers?
If you are a parent or caretaker of a child under 14 years old, or a person with disabilities, you are fully exempt from the work requirement. The age cutoff is 14, not 13 as some earlier guidance suggested. CMS clarified the age threshold in the June 2026 interim final rule.
Will my state notify me before enforcement begins?
Yes. All states are required to conduct outreach between June 30 and August 31, 2026, by first-class mail plus at least one additional method (phone, text, or email). If you have not received anything from your state Medicaid agency by September 2026, contact your state agency directly to confirm your address and ask about your status.
Can I lose Medicaid even if I am already working?
Yes, if you cannot document compliance within the verification window. The 30-day response period after a noncompliance notice is short. Gathering pay stubs or employer letters before enforcement begins is the safest approach. States that use quarterly verification (Indiana, New Hampshire) will check more often than states that verify at 6-month renewals.
For a full eligibility check across Medicaid and other programs based on your income and household size, use the free Benefits Navigator screener at /screener.
