Medicaid Work Requirements Start No Later Than January 1, 2027: Who Must Meet Them, What Counts, and Who Is Exempt

A 2025 federal law adds a work or community engagement requirement for some adults on Medicaid, and states must start it no later than January 1, 2027. A few started earlier. Here is who it applies to, what counts, who is exempt, and which states have published their plans.

Title graphic on a navy and green background reading Medicaid Work Requirements Start No Later Than January 1, 2027, with the note Federal law and CMS rule, checked October 25, 2026, and the Benefit Bull logo.
Most states must start checking hours no later than January 1, 2027. Many adults are exempt.

Short answer

Do you need a job to keep Medicaid in 2027?

Not a full-time job, and not everyone. Starting no later than January 1, 2027 in most cases, some adults ages 19 to 64 who get Medicaid through the adult group must show 80 hours a month of work, community service, a work program, or half-time school, or monthly income of at least 80 times the federal minimum wage, which CMS puts at $580 a month in 2026 (official threshold). (CMS, Community Engagement Interim Final Rule fact sheet) Many adults are exempt, including people who are pregnant or postpartum, parents and caretakers of a child 13 or younger or of a person with a disability, and people who are medically frail. (CMS, Community Engagement Interim Final Rule fact sheet) If your state cannot verify that you meet the rule, it must give you 30 calendar days to show you do or that you are exempt. (CMS, Community Engagement Interim Final Rule fact sheet)

Federal Medicaid work requirement rules (official). Verified October 25, 2026. Sources: CMS and the Federal Register.
RuleWhat it saysSource
Start dateNo later than January 1, 2027, or an earlier date the state chooses; CMS can grant a temporary good faith exemption that ends no later than December 31, 2028CMS fact sheet; Federal Register
Who it applies toNon-pregnant adults ages 19 to 64, not entitled to or enrolled in Medicare, in the Medicaid adult group or certain section 1115 demonstrationsCMS fact sheet
Where43 states and the District of Columbia cover these adults and must implement it; U.S. territories are not subject to the lawCMS fact sheet
What counts80 hours a month of work, community service, or a work program, or any combination; or half-time schoolCMS fact sheet
Income routeMonthly income of at least 80 times the federal minimum wage: $580 a month in 2026 (official threshold)CMS fact sheet
When it is checkedAt application (1 to 3 months before you apply, the state picks) and at renewal, plus more often if the state choosesFederal Register; CMS fact sheet
If it cannot be verifiedA notice and 30 calendar days to respond; then denial or disenrollment; you may reapply at any timeCMS fact sheet

Source: CMS, Community Engagement Interim Final Rule fact sheet and Federal Register, CMS-2454-IFC. Verified .

Your state Medicaid agency decides who must meet the rule and who is exempt. Benefit Bull is free and never applies for you.

CMS issued the rule on June 1, 2026, as required by law, and calls it an "80 hours per month work requirement (sometimes referred to as Medicaid community engagement)." (CMS, Community Engagement Interim Final Rule fact sheet) The interim final rule took effect July 31, 2026. (Federal Register, CMS-2454-IFC) Your state runs it: it decides who is subject, checks your hours, and sends the notices. (CMS, Community Engagement Interim Final Rule fact sheet)

This page covers the federal law and rule, the states whose official pages show an earlier start, and Indiana and Kentucky, which have published their plans. It does not predict anyone's coverage. Your notice from your state is what counts.

Who has to meet Medicaid work requirements?

Benefit Bull graphic for step 1: Who has to meet Medicaid work requirements?
Adults 19 to 64 in the adult (expansion) group.

CMS says the requirement "applies to non-pregnant adults between the ages of 19 and 64 who are not entitled to or enrolled in Medicare and are eligible for or enrolled in the Medicaid adult group or in certain section 1115 demonstrations that provide minimum essential coverage to adult beneficiaries." (CMS, Community Engagement Interim Final Rule fact sheet)

The adult group is the coverage some states call Medicaid expansion. Kentucky, for example, says its requirement "applies to those enrolled in Medicaid based only on their income, also known as Medicaid Expansion." (Kentucky KHBE, Medicaid Work or Community Engagement) CMS counts 43 states and the District of Columbia that cover these adults. (CMS, Community Engagement Interim Final Rule fact sheet)

If you get Medicaid another way, such as through a disability or pregnancy group, or you have Medicare, the rule is written around the adult group, and CMS says some adults are considered to meet it because they "were enrolled in another Medicaid eligibility group or Medicare." (CMS, Community Engagement Interim Final Rule fact sheet)

The move

Look at your last Medicaid notice or your state portal to see which coverage group you are in. That tells you whether the rule may apply.

What counts toward the 80 hours?

Benefit Bull graphic for step 2: What counts toward the 80 hours?
Work, volunteering, training, or school, in any mix.

CMS lists four ways to meet the requirement for a month: (CMS, Community Engagement Interim Final Rule fact sheet)

  • Work, complete community service, or take part in a work program for at least 80 hours.
  • Enroll in an educational program at least half-time.
  • Do a combination of those activities that adds up to at least 80 hours.
  • Have monthly income of at least the federal minimum wage times 80 hours, which CMS puts at $580 a month in 2026 (official threshold). Seasonal workers use a different calculation.

States fill in the details. Kentucky, for example, counts school at least half-time "including high school, college, or career and technical education," and for seasonal work, an average of $580 over the last 6 months (official threshold). (Kentucky KHBE, Medicaid Work or Community Engagement)

So 80 hours a month is roughly 20 hours a week, not full time. That arithmetic is ours, not the state's.

The move

Start a simple log today: date, activity, hours, and who can confirm it. Keep pay stubs with it.

Who is exempt from Medicaid work requirements?

Benefit Bull graphic for step 3: Who is exempt from Medicaid work requirements?
Parents of young kids, pregnancy, frailty, and more.

CMS lists adults who are exempt and do not need to meet the requirement, including: (CMS, Community Engagement Interim Final Rule fact sheet)

Federal exemptions from the Medicaid work requirement (official). Checked October 25, 2026. Sources: CMS fact sheet, CMS-2454-IFC; Federal Register for the under-26 note.
Exempt groupCMS wording
Former foster youthFormer foster care youth (the federal group for former foster youth generally covers people under age 26)
Tribal membersAmerican Indians and Alaska Natives
Parents and caregiversParents, guardians, caretaker relatives, or family caregivers of a dependent child 13 years of age and under, or a disabled individual
VeteransVeterans with a total disability rating
Medically frailMedically frail or otherwise have special medical needs that significantly impair their ability to comply with the requirement
TANF or SNAP work rulesMeet the TANF work requirements or are a member of a household receiving SNAP benefits and are not exempt from the SNAP work requirements
TreatmentParticipants in a drug or alcohol rehabilitation or treatment program
IncarcerationInmates of a public institution
PregnancyPregnant or eligible for postpartum coverage in their state

If you aged out of foster care, you may be exempt while you are under 26. The Federal Register explains that the former foster care group "generally serves individuals who were enrolled in Medicaid while in foster care, then exited foster care (or 'aged out') without an adoption or other permanency, and are under age 26." (Federal Register, CMS-2454-IFC)

If you were released from jail or prison in the past 3 months, you may count as meeting the requirement. The law tells states to treat you as meeting it for a month if "at any point during the 3-month period ending on the first day of such month, the individual was an inmate of a public institution." (Public Law 119-21, sec. 71119)

States may also offer short-term hardship exceptions, for example for a hospital or nursing facility stay, travel for serious medical care, a county with high unemployment, or a county with a declared emergency or disaster. (CMS, Community Engagement Interim Final Rule fact sheet) Kentucky's list also names people getting SSI, or SSDI or Social Security retirement due to disability, and people entitled to or enrolled in Medicare. (Kentucky KHBE, Medicaid Work or Community Engagement)

The move

If one of these fits you, gather proof now, such as a child's birth certificate, a VA rating letter, or a note about your treatment, so you can answer a notice fast.

Which months will your state check?

Benefit Bull graphic for step 4: Which months will your state check?
Months before you apply, and months before you renew.

At application, the federal rule says states must require you to show you met the requirement "for at least 1 but not more than 3 consecutive months, as specified by the State, immediately preceding the month of application." (Federal Register, CMS-2454-IFC) At renewal, CMS says existing members will need to meet it "for one or more months between renewals," and states may check more often. (CMS, Community Engagement Interim Final Rule fact sheet)

Which months count under the federal rule (official). Checked October 25, 2026. Sources: Federal Register, CMS fact sheet.
SituationFederal rule
New applicant1 to 3 months before the month you apply, as your state chooses
Current memberOne or more months between renewals
How often checkedApplication and renewal, more often at state option

Your state picks the exact months. For Kentucky's lookback, see Kentucky Medicaid work requirements; for Indiana, see Indiana HIP work requirements. For how and when renewals happen, see How Medicaid Renewal Works.

The move

Find your renewal date in your state portal now, then count back the months your state checks.

What happens if your state cannot verify your hours?

Benefit Bull graphic for step 5: What happens if your state cannot verify your hours?
A notice, then 30 days to respond.

If your state cannot verify that you meet the requirement, CMS says it "must send a notice of noncompliance and provide the individual with 30 calendar days to demonstrate compliance or that the requirement does not apply to them." If you do not, your application might be denied or you might be disenrolled. (CMS, Community Engagement Interim Final Rule fact sheet)

Three things soften that:

There is a second cost to missing it. The federal rule requires your notice to describe the consequences for your Medicaid and for the premium tax credits used to pay for Marketplace coverage. (Federal Register, CMS-2454-IFC)

The move

Open every letter, email, and text from your Medicaid agency the day it arrives, and answer within 30 days.

Which states started early, and what are Indiana and Kentucky doing?

Benefit Bull graphic for step 6: Which states started early, and what are Indiana and Kentucky doing?
A few states started in 2026. Indiana and Kentucky start January 1, 2027.

States that started early

States may start before the federal deadline. These official state pages show an earlier start, or a work rule already in place. (Federal Register, CMS-2454-IFC)

States that started early, as published by each state (official). Checked October 25, 2026. Sources: Nebraska DHHS, Federal Register, Montana DPHHS, Iowa HHS, Georgia Pathways.
StateStartWhat the state saysSource
NebraskaMay 1, 2026Members and applicants eligible under Medicaid expansion must meet work requirements to keep or get coverageNebraska DHHS, Medicaid Work Requirements; Federal Register, CMS-2454-IFC
MontanaJuly 1, 2026Community engagement requirement for the Medicaid Expansion population, including all new expansion applications on and after that dateMontana DPHHS, Medicaid Changes FAQs
IowaDecember 1, 2026Applies to new Iowa Health and Wellness Plan applicants from that date, and to current members with renewal dates on or after February 2027Iowa HHS, IHAWP Community Engagement Requirements
GeorgiaAlready in place; federal rules apply from January 1, 2027Georgia Pathways to Coverage already requires at least 80 hours a month; current members are not affected by the federal changes until renewal in 2027Georgia Pathways, H.R. 1 Changes to Pathways

Indiana and Kentucky

What Indiana and Kentucky have published (official). Checked October 25, 2026. Sources: Indiana FSSA, Kentucky KHBE.
StateProgram and startHow to report or get helpSource
IndianaHealthy Indiana Plan (HIP) work requirements, for new applicants and redeterminations on or after January 1, 2027FSSA Benefits Portal (FSSABenefits.IN.gov) or DFR at 1-800-403-0864; report changes within 10 days; a pre-screening tool shows whether you may be subject or exemptIndiana FSSA, HIP Work Requirements
KentuckyMedicaid Work or Community Engagement (MACE), starting January 1, 2027, for adults 19 to 64 in Medicaid Expansionkynect at 1-855-459-6328, a kynector, or DCBS at 1-855-306-8959; for 2027, self-attestation is allowed on the MACE formsKentucky KHBE, Medicaid Work or Community Engagement

For the full Indiana rules, see Indiana HIP work requirements. For Kentucky's lookback months and the 2027 MACE forms, see Kentucky Medicaid work requirements. For renewal timing, see How Medicaid Renewal Works.

For Massachusetts, Minnesota, and states not listed above, we have not yet confirmed rollout details on an official state page, so this page does not describe them. Watch your mail and your state portal, and see MassHealth or Minnesota Medical Assistance for income limits.

The move

In Indiana, run the HIP pre-screening tool. In Kentucky, download the MACE form that fits you and keep it ready.

What can you do now to keep your coverage?

Benefit Bull graphic for step 7: What can you do now to keep your coverage?
Five steps that keep you ready for a notice.
  1. Check your coverage group and renewal date in your state portal. (Indiana FSSA, HIP Work Requirements) (Kentucky KHBE, Medicaid Work or Community Engagement)
  2. Update your address, phone, and email with your Medicaid agency, so notices reach you. (Kentucky KHBE, Medicaid Work or Community Engagement)
  3. Track your hours each month: work, volunteering, training, and school. Kentucky advises: "Keep a record of any work, volunteer, job training, or school hours you complete each month." (Kentucky KHBE, Medicaid Work or Community Engagement)
  4. Check the exemption list above and gather documents if one fits. (CMS, Community Engagement Interim Final Rule fact sheet) (Kentucky KHBE, Medicaid Work or Community Engagement)
  5. Answer any notice within 30 days, and reapply if your coverage ends. (CMS, Community Engagement Interim Final Rule fact sheet)

If you are not on Medicaid and want to apply, you can apply any time of year. (HealthCare.gov, Medicaid and CHIP) There is no fee to apply through official channels; Georgia, for example, says "there's no cost to apply for benefits through the portal." (Georgia.gov, Georgia Gateway) You submit your application yourself on the official site. Benefit Bull is free and never files for you. For income limits, see Medicaid income limits.

The move

Put your renewal month on your calendar and set a reminder two months before it.

What this adds up to

No later than January 1, 2027 in most states, and earlier in a few, some Medicaid adults ages 19 to 64 in the adult group must show 80 hours a month of work, volunteering, training, or half-time school, or income of at least $580 a month in 2026 (official threshold). (CMS, Community Engagement Interim Final Rule fact sheet) Parents of children 13 and younger, pregnant and postpartum people, people who are medically frail, and several other groups are exempt. (CMS, Community Engagement Interim Final Rule fact sheet) Your state checks at application and renewal and must give you 30 days to respond before coverage ends, and you can reapply at any time. (CMS, Community Engagement Interim Final Rule fact sheet) If you are already enrolled, you may keep coverage during those 30 days. (Public Law 119-21, sec. 71119) Indiana and Kentucky have already published their rules. (Indiana FSSA, HIP Work Requirements) (Kentucky KHBE, Medicaid Work or Community Engagement) You submit your application yourself on the official site. Benefit Bull is free and never files for you. Questions about this guide: ben@benefitbull.com.

Sources

Every claim above links to the source it came from. Figures checked October 2026. Last updated October 25, 2026.

  1. Centers for Medicare and Medicaid Services, Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC) fact sheet, June 1, 2026 (accessed October 25, 2026)
  2. Federal Register (govinfo.gov), Medicaid Program; Community Engagement Requirement for Certain Individuals (CMS-2454-IFC), 2026-11094, June 3, 2026 (accessed October 25, 2026)
  3. Indiana Family and Social Services Administration, HIP Work Requirements: Information for HIP Members (accessed October 25, 2026)
  4. Kentucky Health Benefit Exchange, Medicaid Work or Community Engagement (MACE) Requirements (accessed October 25, 2026)
  5. HealthCare.gov, Medicaid and CHIP coverage (accessed October 25, 2026)
  6. Georgia.gov, Use Georgia Gateway (accessed October 25, 2026)
  7. Public Law 119-21 (govinfo.gov), sec. 71119, Requirement for States to Establish Medicaid Community Engagement Requirements for Certain Individuals (accessed October 25, 2026)
  8. Nebraska Department of Health and Human Services, Medicaid Work Requirements (accessed October 25, 2026)
  9. Montana Department of Public Health and Human Services, Medicaid Changes FAQs (accessed October 25, 2026)
  10. Iowa Health and Human Services, IHAWP Community Engagement Requirements (accessed October 25, 2026)
  11. Georgia Pathways to Coverage, H.R. 1 Changes to Pathways (accessed October 25, 2026)
Portrait of Anthony Paluzzi

Anthony Paluzzi Founder and CEO, Benefit Bull

Anthony Paluzzi is the founder of Benefit Bull, a free platform that shows Americans which government assistance programs they may qualify for and walks them through applying themselves. He also founded Palo Media Group, a performance marketing company in Plymouth, Massachusetts, which is Benefit Bull's parent company. Program facts on this page were checked against the official sources listed above on October 25, 2026, and reviewed by Anthony Albert, Manager. Questions or corrections: ben@benefitbull.com. Meet the whole team

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