Texas is not required to implement Medicaid work requirements on January 1, 2027. The federal community engagement mandate created by the One Big Beautiful Bill Act applies to adults enrolled through the ACA Medicaid expansion group, and Texas never adopted expansion. Of the 44 states and DC that must add an 80 hour per month work rule, Texas is not one of them. Almost everyone on Texas Medicaid today is a child, a pregnant woman, a senior, or a person with a disability, and none of those groups fall under the new federal rule.
That is the short answer. The longer answer matters, because Texans still face work rules in other programs, because the state could change course, and because the rule already reshapes coverage for Texans who move to another state.
Quick Answer Table
| Question | Answer for Texas |
|---|
| Does the federal Medicaid work requirement apply in Texas? | No |
| Why not? | Texas has no ACA Medicaid expansion group and no 1115 waiver covering adults above 133% FPL |
| Federal deadline for states that are covered | January 1, 2027 |
| Number of states required to implement | 44 states plus the District of Columbia |
| Non-expansion states that ARE covered | Georgia, Tennessee, Wisconsin (through 1115 waivers) |
| Do Texas Medicaid enrollees need to report work hours? | No |
| Do work rules apply to Texas SNAP? | Yes, and they expanded in 2026 |
| Do work rules apply to Texas TANF? | Yes, through the Choices program |
| Could Texas add Medicaid work rules later? | Only through expansion or a new 1115 waiver, neither of which is pending |
What the Federal Law Actually Requires
The One Big Beautiful Bill Act, signed July 4, 2025, added a "community engagement requirement" to federal Medicaid law. CMS published the implementing interim final rule on June 3, 2026, with a comment period that closed July 31, 2026.
Under the rule, an "applicable individual" is an adult age 19 through 64 enrolled in the ACA Medicaid expansion group under Section 1902(a)(10)(A)(i)(VIII), or enrolled through certain Section 1115 demonstration waivers that cover adults who would otherwise fall in that group. Those enrollees must document at least 80 hours per month of qualifying activity, or earn monthly income of at least $580, which is 80 hours at the federal minimum wage.
Qualifying activities include:
- Paid employment or self employment
- Unpaid work through a structured program
- Job training or a state or federally recognized employment and training program
- Enrollment at least half time in an educational program
- Community service through a qualifying program
- Any combination of the above adding up to 80 hours
States must check compliance using a look back period of one to three months before application, then verify at least one month of activity within every six month eligibility period. Self attestation gets tighter starting January 1, 2028. States that miss the January 1, 2027 deadline can ask the HHS Secretary for a good faith extension through December 31, 2028.
None of this creates an obligation for Texas Medicaid enrollees.
Why Texas Is Not Covered
The requirement is written to attach to a specific eligibility category, not to Medicaid generally. Texas does not have that category.
Texas is one of ten states that never adopted the ACA Medicaid expansion. Adults in Texas qualify for Medicaid only through pre-ACA pathways: pregnancy, SSI, a disability determination, long term care eligibility, or being a parent or caretaker relative with income under roughly 15% of the federal poverty level. There is no coverage group for low income adults between 0% and 138% FPL, which is exactly the group the federal work requirement targets.
Three non-expansion states are still covered, because their Section 1115 waivers enroll adults who would otherwise be expansion adults. Georgia's Pathways to Coverage program, Tennessee's TennCare demonstration, and Wisconsin's BadgerCare Plus childless adults waiver all fall into that bucket. Texas has an 1115 waiver, the Healthcare Transformation and Quality Improvement Program, but it funds uncompensated care and delivery system work rather than covering an adult expansion population, so it does not trigger the requirement.
The result is a strange piece of policy math. Texas has the largest uninsured population in the country and the strictest adult Medicaid rules, and because of that strictness, no Texan on Medicaid has to log 80 hours a month.
Who Is Actually on Texas Medicaid
Texas Medicaid and CHIP together cover roughly 4 million people. The breakdown explains why the federal rule has no target population here.
| Group | 2026 income limit (approximate) | Subject to federal work rule? |
|---|
| Children ages 0 to 1 | Up to 198% FPL | No, under 19 |
| Children ages 1 to 5 | Up to 144% FPL | No, under 19 |
| Children ages 6 to 18 | Up to 133% FPL | No, under 19 |
| Pregnant women | Up to 198% FPL | No, pregnancy is exempt |
| Parents and caretaker relatives | About 15% FPL, roughly $340 a month for a household of three | No, Texas has no expansion group |
| SSI recipients | Federal SSI limits | No, disability is exempt |
| Aged, blind, and disabled | SSI related and long term care limits | No |
| Adults without children | Not eligible at any income | Not enrolled |
Note that even in states where the rule does apply, most of these categories would be exempt anyway. The 2026 federal poverty guidelines used for these calculations are $15,960 for one person and $33,000 for a household of four, effective January 13, 2026.
For a full breakdown of who qualifies, see our Texas Medicaid eligibility guide.
The Exemptions, and Why Texans Should Still Know Them
The federal exemption list matters for two groups of Texans: anyone who moves to one of the 44 covered states, and anyone planning around a future policy change. It also matters because these categories show up in other benefit rules.
| Exempt category | Detail |
|---|
| Under 19 or over 64 | Outside the covered age band |
| Pregnant and postpartum | Runs through the 12 month postpartum period |
| Parents and caretakers | Caring for a dependent child age 13 or under, or a person with a disability |
| Medically frail | CMS requires proof the condition significantly impairs ability to complete 80 hours, not just a diagnosis |
| Disabled veterans | Rated totally disabled |
| Former foster youth | Under age 26 |
| American Indian and Alaska Native | Including those eligible for Indian Health Service care |
| Already meeting TANF or SNAP work rules | Deemed compliant, no separate reporting |
| Substance use disorder treatment | Active participation in a qualifying program |
| Incarcerated or recently released | Includes people incarcerated within the prior three months |
| Medicare enrolled | Outside the requirement |
Our national work requirement exemption guide covers how states verify each of these and what happens when verification fails.
The Work Rules That DO Apply to Texans
Skipping the Medicaid mandate does not mean Texas households are free of work requirements. Two programs enforce them right now, and one expanded significantly in 2026.
SNAP
This is the one that changed. The One Big Beautiful Bill Act raised the ABAWD age ceiling from 54 to 64. Texans ages 18 through 64 who can work and have no household member under age 14 are limited to three months of SNAP in any 36 month period unless they meet the work rule. Meeting it means 80 hours a month of work, a work program, or a combination. Texas HHSC enforces this through recertifications and eligibility reviews rolling through 2026.
Adults ages 55 to 64 who never had to think about SNAP work rules before are the group most likely to get caught off guard. Details are in our Texas SNAP eligibility guide and the SNAP work requirements breakdown.
TANF
Texas TANF cash assistance has always carried a work requirement through the Choices program, run by the Texas Workforce Commission. Adults in a TANF household generally must participate in work, job search, or training activities, with a 60 month lifetime limit on benefits.
Child Care Services
The Texas Workforce Commission's child care subsidy program requires parents to be working, in school, or in training a minimum number of hours per week. That is a program condition, not a Medicaid rule, but it functions the same way for families budgeting around it.
| Program | Work rule in Texas? | Hours standard |
|---|
| Medicaid | No | Not applicable |
| CHIP | No | Not applicable |
| SNAP | Yes, ages 18 to 64 | 80 hours per month |
| TANF | Yes | Set by Choices participation plan |
| Child Care Services | Yes | Minimum weekly hours, varies |
Timeline: What Happens and When
| Date | Event | Texas impact |
|---|
| July 4, 2025 | One Big Beautiful Bill Act signed | Creates the Medicaid work mandate and expands SNAP ABAWD ages |
| Early 2026 | Texas begins enforcing expanded SNAP work rules | Affects SNAP recipients ages 55 to 64 |
| June 3, 2026 | CMS publishes interim final rule | Confirms scope is expansion and certain 1115 populations |
| July 31, 2026 | Federal comment period closes | No Texas Medicaid filing obligation |
| January 1, 2027 | Federal deadline for the 44 covered states | Texas not covered |
| January 2027 | Texas Legislature convenes its next regular session | Any state level change would start here |
| December 31, 2028 | Last date for good faith extensions in covered states | No Texas impact |
Could This Change?
Three paths could bring Medicaid work requirements to Texas, and none of them is currently in motion.
Texas adopts Medicaid expansion. If Texas ever expanded, the new expansion group would be subject to the federal rule automatically. There is no active expansion legislation, and the Legislature does not meet in regular session again until January 2027.
Texas seeks a new 1115 waiver covering adults. This is the Georgia Pathways model: a limited coverage program for low income adults with work participation built in as a condition of entry. Texas has not submitted such a request.
Congress extends the rule to non-expansion populations. The current statute does not reach parents and caretakers in non-expansion states. Changing that would take new federal legislation.
If any of these happen, the rule would still exempt the great majority of current Texas enrollees, since children, pregnant women, seniors, and people with disabilities make up nearly the entire caseload.
What to Do Right Now
Even without a work requirement, Texas Medicaid renewals are where coverage is most often lost, usually for paperwork reasons rather than eligibility ones.
- Log into YourTexasBenefits.com and confirm your mailing address, phone number, and email are current. Missed renewal notices are the single most common cause of a coverage loss.
- Report changes within 10 days. Income changes, household size changes, address changes, and pregnancy all affect eligibility.
- Answer renewal packets immediately. Texas sends a renewal form before your certification period ends. Returning it late can mean a gap in coverage even when you still qualify.
- If you are on SNAP, track your hours. The expanded ABAWD rule is the one that can actually cut a Texas household off. Keep pay stubs, training records, and volunteer hour logs.
- If Medicaid denies you, check the Marketplace. Texans over 100% FPL may qualify for subsidized coverage through healthcare.gov. See our Texas ACA eligibility guide.
More Texas program details are available on our Texas benefits page.
Frequently Asked Questions
Do I have to report work hours to keep Texas Medicaid in 2026 or 2027?
No. Texas Medicaid has no community engagement or work reporting requirement. The federal mandate that starts January 1, 2027 applies only to the ACA expansion group and certain 1115 waiver populations, and Texas has neither.
Why are other states adding work requirements but not Texas?
The requirement attaches to the Medicaid expansion eligibility category created by the ACA. Forty states plus DC expanded Medicaid, and three additional non-expansion states cover similar adults through waivers. Texas never expanded and has no comparable waiver, so there is no covered population here.
I am a parent on Texas Medicaid. Am I affected?
No. Parents and caretaker relatives in Texas qualify through a pre-ACA pathway with an income limit around 15% of the federal poverty level. That category is not covered by the federal rule. Separately, parents caring for a child age 13 or under are on the federal exemption list even in states where the rule applies.
If I move from Texas to a state with work requirements, what happens?
You would apply under that state's rules. If you enroll in that state's expansion group and are between 19 and 64, you would need to document 80 hours a month of qualifying activity or claim an exemption. Check the receiving state's implementation date, since several started before the federal deadline.
Do Texas SNAP work requirements affect my Medicaid?
No, they are separate programs with separate rules. Losing SNAP for a work rule violation does not end Medicaid coverage. In states that do enforce the Medicaid rule, meeting SNAP work requirements counts as compliance, but that provision has no application in Texas.
What is the 80 hour rule and how is it measured?
In covered states, enrollees must complete at least 80 hours per month of work, job training, education, or community service, or earn at least $580 in a month. States verify a one to three month look back at application and at least one month per six month eligibility period afterward.
Will Texas Medicaid enrollment drop because of this law?
Not from the work requirement itself. Other provisions of the 2025 law affect Texas differently, including changes to Marketplace verification and eligibility redetermination processes. Texas Medicaid coverage losses in 2026 have come mainly from renewal paperwork, not work rules.
Where can I check what I qualify for in Texas?
Texas HHSC handles Medicaid, CHIP, SNAP, and TANF applications at YourTexasBenefits.com or by phone at 1-800-252-8263. The 2-1-1 Texas helpline can also connect you with local application assistance.
