Table of Contents
In 2025, Congress passed HR 1, which made many changes to Medicaid, including new community engagement (CE) requirements, also known as “work requirements.” In June 2026, the Centers for Medicare & Medicaid Services (CMS) issued an Interim Final Rule on how states must carry them out, leaving some decisions to individual states. States must implement CE requirements by January 2027.
80
hours a month of qualifying activity
$580
a month in household income
6
months, at most, between checks
43
states affected in 2027
—
days until January 1, 2027
Does this apply to me?
The 80-hour or $580 rule
To enroll in or keep Medicaid, a person the requirements apply to must do at least 80 hours a month of qualifying activity, or have monthly income of at least $580 (80 times the federal minimum wage), unless they qualify for an exclusion. Income can be earned or unearned and can come from anyone in the Medicaid household. Looking for work does not count. 42 C.F.R. § 435.552
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An estimate to help explain the rule. Your state checks its own records first and decides what proof it accepts. How states check (Q5)
What happens when
The rules get stricter after the first year. What a state accepts in 2027 won’t be enough in 2028.
- 12025
Congress passes HR 1, creating Medicaid community engagement requirements.
- 2June 2026
CMS issues an Interim Final Rule. Many choices are left to states.
- NowToday
States are setting their own policies. Check your state Medicaid agency.
- 4January 2027
Requirements begin. States may accept your own statement when their data can’t confirm compliance.
- 52028
States must verify with data or documents. Medical frailty self-attestation is limited to one time.
Will the state take my word for it?
Who is excused from the requirements
People who would otherwise have to meet the requirements may be excluded if they meet certain criteria. States can’t review eligibility for an exclusion more often than every 6 months. 42 C.F.R. § 435.554
To qualify as medically frail, a person must meet both parts of a two-part test. States must re-verify this status at least every 12 months.
At least one of these
- Blindness or disability under the Social Security definition
- A substance use disorder, without 5 or more years in stable recovery
- A disabling mental disorder
- A physical, intellectual, or developmental disability that limits at least one daily activity: eating, bathing, dressing, toileting, or mobility
- A serious or complex medical condition
It significantly impairs the ability to meet the requirement
This is the harder part. Even someone Social Security has found disabled must meet it, because the state looks at activities beyond paid work, like volunteering or school. See Q14
States can further define the conditions in Part 1. § 435.554(c)(5)
How states may sort conditions
CMS guidance suggests, but doesn’t require, a three-tier list of diagnoses. Select a tier to see what it means.
States decide which conditions go in which tier. Check your state Medicaid agency for its list, or read the CMS guidance.
Parents, guardians, caretaker relatives, and family caregivers are excluded if they care for a child 13 or younger, or for a person with a disability of any age. The person cared for counts as disabled if they meet the ADA definition: a physical or mental impairment, or being seen as having one, that limits one or more major life activities. § 435.554(a)
Relatives who count
States can add others related by blood, marriage, or adoption. § 435.554(c)(3)
Do I count as a caregiver?
Who do you care for?
Are you related to them, or do you live with them?
Answer both questions to see how the caregiver exclusion applies.
Following TANF work rules
People who comply with Temporary Assistance for Needy Families work requirements are excluded from Medicaid’s.
In a SNAP household with work rules
Members of a SNAP household subject to SNAP work requirements are excluded from Medicaid’s.
Otherwise, Medicaid’s requirements are separate from SNAP and TANF rules. See Q7
How it plays out for real households
Two examples from this FAQ show how much depends on the details.
- Ruth isn’t working.
- John is retired and enrolled in Medicare.
- John gets $1,600 a month from Social Security.
- Ruth is 19–64 and on expansion, so the requirements apply to her.
- At renewal, the state counts John’s income because they’re in the same Medicaid household.
- $1,600 is more than $580. Unearned income counts.
Ruth keeps her Medicaid. Q4
- A serious back injury ended his work.
- He’s in the 24-month wait for Medicare.
- His SSDI is over the limit for disability-based Medicaid, so expansion is his only option.
- Being found disabled by Social Security meets Part 1 of the medically frail test.
- The state still decides Part 2: does his disability significantly impair part-time school, job training, or volunteering?
- His coverage depends on that decision, not on his SSDI approval alone.
Carl isn’t automatically excluded. Q14
Frequently asked questions
This FAQ answers common policy questions that apply across all states. Many details will come from your state Medicaid agency.
Additional resources
- Justice in Aging Webinar: Understanding New Medicaid Work Requirements Rules
- Justice in Aging: Mitigating the Harms of Medicaid Work Requirements for Older Adults: Tools for State Advocates
- KFF: The Medical Frailty Exemption from Medicaid Work Requirements: Key Takeaways from the CMS Interim Final Rule
- State Health & Value Strategies: Medicaid Work Reporting Requirements Member Scenarios
