Medicaid Work Requirements 2027: Start Date, Who Is Exempt, and What Happens If You Lose Coverage

Direct answer: Medicaid work requirements start by January 1, 2027

Yes. By January 1, 2027, expansion states must require adults ages 19 to 64 to show 80 hours a month of work, school, training or volunteering, or income of at least $580 a month (2026 figure). Exempt groups are excluded. Nebraska, Montana and Iowa started sooner, and a state can win a delay only through a CMS good faith exemption ending by December 31, 2028.

Who must meet the Medicaid work requirement in 2027

Expansion-group adults ages 19 to 64 are the people the 2027 rule covers. That is the group eligible at or below 138% of the federal poverty level (FPL), which is $22,025 a year for one person in 2026 under the 2026 guidelines from aspe.hhs.gov. The rule also reaches adults covered through certain Section 1115 waivers that provide minimum essential coverage, including Georgia's and Wisconsin's waiver programs. Adults are not pulled in if they are pregnant, or if they are enrolled in Original Medicare (Medicare Part A or Part B), including through a Medicare Advantage plan.

The 10 states that have not expanded Medicaid (AL, FL, GA, KS, MS, SC, TN, TX, WI, WY) do not have an expansion group, so the rule reaches their adults only through waiver programs. Children, adults 65 and older, and people who qualify through disability or other non-expansion categories are outside the rule. Medicaid has no enrollment window, so applying year-round is still possible; what changes in 2027 is the proof a state asks for.

What counts toward the 80 hours a month in 2027

The federal rule accepts several ways to show community engagement each month, and a person needs to meet only one. States must use payroll and other government data first (ex parte verification) so many working adults will not need to upload anything. The options in the statute and the CMS interim final rule are:

• Work at least 80 hours in the month, at one job or several combined.
• Complete at least 80 hours of community service.
• Take part in a work program for at least 80 hours.
• Be enrolled in school or a career and technical education program at least half-time.
• Combine any of those activities for a total of at least 80 hours.
• Earn at least the federal minimum wage times 80 hours in the month, which is $580 a month in 2026. Seasonal workers can use a 6-month income average.

Who is exempt from the Medicaid work requirement in 2027

Federal law exempts specific groups, and a state must treat an exempt person as meeting the rule for the month. Exemptions are the main route by which adults under 65 keep Medicaid without logging hours, so confirm with your state that yours is recorded. The statute and CMS fact sheet list these groups:

• Parents, guardians, caretaker relatives or family caregivers of a dependent child 13 or younger, or of a person with a disability.
• People who are medically frail or have special medical needs, including people who are blind or disabled, have a substance use disorder, a disabling mental disorder, a disability that limits daily activities, or a serious or complex medical condition.
• American Indians, Alaska Natives and other people eligible for Indian Health Service care.
• Former foster care youth, and veterans with a total service-connected disability rating.
• People who meet TANF work rules, or who are in a SNAP household and not exempt from the SNAP work rule.
• People in a drug or alcohol treatment program, people who are pregnant or in the postpartum coverage period, and people in a public institution such as a jail (and for 3 months after release).
• Optional short-term hardships a state may choose to honor: a hospital or nursing facility stay, a presidentially declared disaster county, a county with unemployment at or above 8% (or 1.5 times the national rate) under the 2027 rule, or travel for extended specialty care.

Start dates by state and the October 2026 court ruling

Nebraska began enforcing the rule on May 1, 2026. Montana went live on July 1, 2026, with denials and disenrollments from October 2026. Iowa applies the rule to people who apply on or after December 1, 2026. Every other expansion state must start by January 1, 2027 unless CMS approves a good faith exemption, which the statute caps at December 31, 2028 and which CMS says it will first approve for no more than 6 months. CMS projected that about 10 states would apply.

On the question of whether every state is ready, the answer on November 7, 2026 is that readiness varies. The KFF tracker, updated November 3, 2026, does not mention any approved good faith exemptions. Check your state Medicaid agency for its notice. On October 29, 2026 a federal judge in Boston ruled in Massachusetts v. Oz that CMS could not require people to prove a condition also limits their ability to work; a listed medical frailty category is enough. The work requirement itself was left in place.

What happens if you lose Medicaid for not meeting the work rule

A state cannot cancel coverage the first month it cannot verify your hours. Under the statute, the state must send a notice of noncompliance and give you 30 calendar days to show you met the rule or that you are exempt, and Medicaid continues during those 30 days. If you show nothing, the state checks whether you qualify for Medicaid on any other basis, then sends written notice with fair hearing rights. Denial or disenrollment comes no later than the end of the month after the 30 days end. You may reapply at any time, and the state reassesses your hours.

Losing Medicaid for missing the work rule also affects marketplace help. Section 1902(xx)(7)(B), added by Public Law 119-21 section 71119, treats a person who would be Medicaid-eligible but for failing the work requirement as eligible for Medicaid for premium tax credit purposes. The result: you cannot get the ACA premium tax credit while the state counts you that way, though you can still buy a full-price Marketplace plan. People who are exempt, and people whose income rises above 138% FPL (above $22,025 for one person in 2026), are not caught by this bar.

Medicaid and Marketplace income lines by household size (2026 guidelines)

Income lines show which side of the 138% FPL boundary a household sits on, which decides whether the expansion work rule or the Marketplace route applies. The Medicaid column uses the 2026 poverty guidelines (the current year). The Marketplace columns are for 2027 coverage, sold from November 1, 2026, which uses the 2026 guidelines; 2026 coverage used the 2025 guidelines ($15,650 to $62,600 for one person).

Alternatives if you lose Medicaid or do not qualify in 2027

Adults under 65 who lose Medicaid for a reason other than the work rule, or who are exempt and whose income rises, have several routes to coverage. The options below apply to 2027 coverage; open enrollment for 2027 plans runs November 1, 2026 to January 15, 2027, and HealthCare.gov lists the sign-up date for coverage starting January 1, so confirm it there. Losing Medicaid also opens a special enrollment period for most people.

• Marketplace plan with the premium tax credit: available at 100% to 400% FPL ($15,960 to $63,840 for one person, 2027 coverage) if you are not denied for the work rule. Every ACA-compliant plan covers essential health benefits and cannot turn you away for a preexisting condition. Apply at HealthCare.gov or your state exchange.
• Full-price Marketplace plan: open to anyone eligible to enroll, including people barred from the credit by a work-rule denial. Premiums have no subsidy, so compare the plan tiers carefully.
• Employer coverage: losing Medicaid triggers a special enrollment period at a job that offers a plan. Employer coverage counts as affordable at 10.22% of household income for 2027 plan years.
• Another Medicaid category: a state must check for any other basis of eligibility before ending coverage, such as disability, parent or caretaker status, or pregnancy. Ask the caseworker for that review in writing.
• Community health centers: federally funded centers charge on a sliding fee scale by income. Find one at findahealthcenter.hrsa.gov. This is care, not insurance, but it limits costs while you reapply.

How to report your hours and keep Medicaid in 2027

Expansion adults should expect a mailed notice about the rule, because states must send one by regular mail plus another channel such as text or an online account. The same law requires expansion adults whose renewal is scheduled on or after January 1, 2027 to renew every 6 months rather than once a year, with American Indians and Alaska Natives exempt, so verification arrives twice as often. Steps and documents are listed in the application block below, and the starting point for every state is Medicaid.gov's state finder.

When do Medicaid work requirements start?

Federal law requires expansion states to start no later than January 1, 2027. Nebraska started May 1, 2026, Montana July 1, 2026, and Iowa applies the rule to people who apply on or after December 1, 2026. CMS can approve a state good faith exemption, first for up to 6 months, ending no later than December 31, 2028, so check your state agency for its exact date.

Who is exempt from Medicaid work requirements in 2027?

Exempt groups include parents or caregivers of a child 13 or younger or of a person with a disability, medically frail people, American Indians and Alaska Natives, former foster youth, veterans with a total disability rating, people in addiction treatment, pregnant and postpartum people, and people who follow SNAP or TANF work rules. States may add short-term hardship exceptions.

How many hours do I need to work for Medicaid in 2027?

You need 80 hours a month of work, community service, a work program or half-time school, or any combination totaling 80 hours. You can instead earn at least $580 a month (2026 figure), which is the federal minimum wage times 80 hours. A state can check one to three months before you apply and at each renewal.

What happens if I lose Medicaid because of the work requirement?

The state must send a notice and give you 30 calendar days to show compliance or an exemption, and Medicaid continues during that time. If you do not, the state checks for any other eligibility basis, then sends written notice with fair hearing rights. You can reapply at any time. The loss also blocks the ACA premium tax credit under Public Law 119-21 section 71119.

Can I get ACA Marketplace subsidies if I am denied Medicaid for not working?

No, not while the state counts you as Medicaid-eligible but for the work rule. Section 1902(xx)(7)(B) deems you eligible for Medicaid for premium tax credit purposes. You can still buy a Marketplace plan at full price. Exempt people and people whose income rises above 138% FPL ($22,025 for one person in 2026) are not caught by this bar and can seek the credit for 2027 coverage.

Do Medicaid work requirements apply in all states?

They apply to expansion adults in the 40 expansion states plus DC. The 10 states that have not expanded (AL, FL, GA, KS, MS, SC, TN, TX, WI, WY) have no expansion group, though waiver programs such as Georgia's and Wisconsin's are covered. States with an approved good faith exemption can start later, no later than December 31, 2028.

Did a court block the Medicaid work requirement?

No. On October 29, 2026, a federal judge in Boston ruled in Massachusetts v. Oz that CMS could not require people to prove a condition also limits their ability to work in order to qualify as medically frail. The work requirement itself and the January 1, 2027 deadline were left in place. HHS had not announced an appeal in KFF's summary.

Does the work requirement apply to Medicare or children?

No. The rule covers adults ages 19 to 64 in the Medicaid expansion group, and people enrolled in Original Medicare (Part A or Part B) or Medicare Advantage are not subject to it. Children under 19, adults 65 and older, and pregnant people are also outside the rule. Expansion adults will, however, renew every 6 months for renewals scheduled on or after January 1, 2027.