Medicaid Work Requirements Begin by Jan. 1: 7 Ways People With Disabilities and Caregivers Can Protect Coverage

States must start requiring many adults on Medicaid to show they work, study or volunteer by Jan. 1, 2027, and some, such as Nebraska, have already begun, according to the Centers for Medicare & Medicaid Services. With about two months to go, states are required to reach out to enrollees who could be affected before the rule kicks in.

People with disabilities and family caregivers are among the groups the law exempts. But an exemption only helps if your state knows about it. Here are practical steps to take now, based on CMS’s fact sheet and its interim final rule published in June.

Who has to meet the Medicaid work requirement?

The rule applies to non-pregnant adults ages 19 to 64 who are not entitled to or enrolled in Medicare and who get Medicaid through the adult expansion group or certain Section 1115 demonstrations. CMS says 43 states and the District of Columbia cover these groups and must carry out the requirement. U.S. territories are not subject to it.

Those adults will need 80 hours a month of work, community service, a work program or half-time school, or a mix of them. They can also qualify with monthly income of at least 80 times the federal minimum wage, which CMS puts at $580 a month in 2026.

1. Are you already outside the rule?

Start by checking how you get Medicaid. CMS says adults enrolled in Medicare, or in a Medicaid eligibility group other than the adult group, are considered to meet the requirement. Many people who qualify for Medicaid through a disability benefit or who also have Medicare fall into those categories. If you are not sure which group you are in, ask your state Medicaid agency.

2. Which exemptions fit you or the person you care for?

Under the rule, adults who are exempt include:

• People who are medically frail or have special medical needs that significantly impair their ability to comply.
• Parents, guardians, caretaker relatives or family caregivers of a child 13 or younger or of a disabled individual.
• Veterans with a total disability rating.
• People in a drug or alcohol treatment program, pregnant or postpartum enrollees, former foster youth, and American Indians and Alaska Natives.
• People who meet TANF work rules, or who live in a household receiving SNAP and are not exempt from SNAP’s work rules.

For the caregiver exemption, the rule uses the Americans with Disabilities Act definition of a disabled individual. CMS says that could include an older adult who needs help with daily activities such as bathing, dressing or eating.

The rule says medically frail includes, among others, people who are blind or disabled, people with a substance use disorder or a disabling mental disorder, people with a physical, intellectual or developmental disability that significantly impairs their ability to perform one or more activities of daily living, and people with serious or complex medical conditions.

3. Is your contact information up to date?

States must send outreach and notices about the requirement. If your state has an old address, phone number or email, you could miss them. Update your information with your state Medicaid agency, and if you help a family member, ask how you can be listed as an authorized representative.

4. What records should you gather now?

States must verify compliance at application and at renewal, and they may check more often. It makes sense to keep copies of what proves your situation in one place: pay stubs, school enrollment, volunteer hours, a disability determination, or a letter from a doctor describing a condition that limits your ability to work. Caregivers may want records showing who they care for.

5. What should you do if you get a noncompliance notice?

Act quickly. If a state cannot verify that you meet the requirement, it must send a notice and give you 30 calendar days to show you comply or that the requirement does not apply to you. If you do not respond, your application can be denied or your coverage ended. Open every letter from your Medicaid agency and call if anything is unclear.

6. Could a hardship exception apply?

States may choose to offer short-term hardship exceptions, CMS says. They can cover people receiving inpatient hospital or nursing facility care, people in counties under a presidential disaster or emergency declaration or with high unemployment, and people who must travel for an extended time for serious medical care for themselves or a dependent. Ask whether your state offers them.

7. What if you lose coverage?

People who are disenrolled for not meeting the requirement can reapply at any time, and the state will check compliance again when they do, according to CMS. If you think you were wrongly cut off, ask your state about your appeal rights in the notice you receive.

The changes come as more working-age adults are already going without insurance, as a recent Commonwealth Fund survey found.

Key Takeaways

• States must begin Medicaid work requirements for many adults ages 19 to 64 by Jan. 1, 2027.
• People with disabilities, the medically frail and caregivers of a disabled person or a child 13 or under are exempt, but states must know it.
• Update your contact information and keep records that show your work hours or exemption.
• If you get a notice, you have 30 days to respond; anyone disenrolled can reapply at any time.

Frequently Asked Questions

Featured image: An older man pushes a woman in a wheelchair along a park path. Illustrative photo. (Photo by Ermell, CC BY-SA 4.0, via Wikimedia Commons)