New Medicaid Work Requirements: Who is Exempt and Who Could Lose Coverage

The U.S. government has published a provisional rule establishing new work requirements for certain Medicaid beneficiaries, effective no later than January 1, 2027. Adults aged 19 to 64 who receive coverage through the Affordable Care Act (ACA) Medicaid expansion will be primarily affected. To maintain their eligibility, these individuals must demonstrate at least 80 hours per month of engagement in work, education, job training programs, or community service.

The Centers for Medicare and Medicaid Services (CMS) outlined that states will be responsible for verifying compliance with these new mandates. This verification process will occur at the time of application and then every six months during coverage renewals. The rule also specifies a range of exemptions for individuals who will not be obligated to meet these work requirements, including certain groups facing significant barriers.

Some beneficiary groups may encounter greater difficulties in meeting the new demands. The rule identifies populations at higher risk, such as those with disabilities, caregivers, and individuals with serious health conditions. According to KFF, only about one in five adults currently covered by Medicaid reported not meeting these conditions, suggesting a significant portion might struggle to qualify for exemptions or meet the new criteria.

States are required to initiate information and orientation campaigns at least three months before the verification process begins. Additionally, state leaders can request a good-faith effort exemption to delay the implementation until December 2028. Some territories have already begun early implementations, while others are considering starting sooner through special authorizations.