Medicaid Work Requirements Begin January 2027 for 20 Million Adults

The Centers for Medicare and Medicaid Services published the interim final rule on June 1 that implements the Medicaid work-requirements provision of the 2025 One Big Beautiful Bill Act. Beginning January 1, 2027, roughly 20 million adults in the Affordable Care Act Medicaid expansion population across 43 states and the District of Columbia must show 80 hours a month of qualifying activity to keep coverage.

Qualifying activities include employment, half-time school, job training, approved work programs, community service, or any combination. Earning at least $580 in a month also satisfies the rule. Pregnant and postpartum women, the medically frail, parents and caregivers of children 13 or younger, American Indians and Alaska Natives, former foster youth, disabled veterans, people in addiction treatment, and those already meeting food-stamp or cash-assistance work rules are exempt.

States must verify compliance at application and at least every six months at renewal. If an enrollee misses a check, the state sends notice and allows 30 days to respond before coverage ends. Enrollees may self-attest in the first year; from 2028 documentation is generally required.

A handful of states plan to switch on early.

Energy and Commerce Committee staffers Katie West and Matthew VanHyte said the requirements will re-engage able-bodied adults through jobs, training, or school. They stated that employment and income are expected to rise, some workers will move to employer coverage, and Medicaid will concentrate on the disabled, children, and fragile adults.

An HHS brief projects the requirements could lift 1.6 to 2.9 million people out of poverty. Dr. Adam Brown, an emergency physician and managing partner of ABIG Health, and Dr. Steve Farmer, a cardiologist and former CMS Chief Strategy Officer at ABIG Health, said the Arkansas 2018 program produced no employment gain over 18 months.