Medicaid Work Requirements by State (2026

As of September 20, 2026, four states enforce Medicaid work requirements: Georgia (since 2023, through its Pathways program), Nebraska (since May 1, 2026), Montana (since July 1, 2026), and Arkansas (since July 1, 2026, in a no-penalty “soft launch”). Iowa starts December 1, 2026. Every other state covered by the rule must implement it by January 1, 2027. In all, 43 states plus Washington, D.C. are subject the 40 states (plus D.C.) that expanded Medicaid under the ACA, plus Georgia, Tennessee, and Wisconsin through separate waiver programs.

Last verified: September 20, 2026 ·

Quick Facts: The Medicaid Work Requirement at a Glance

Fact	Detail
The law	One Big Beautiful Bill Act (P.L. 119-21), signed July 4, 2025. CMS refers to it as the “Working Families Tax Cut” legislation. It added Section 1902(xx) to the Social Security Act.
The federal rule	CMS Interim Final Rule CMS-2454-IFC, issued June 1, 2026; published in the Federal Register June 3, 2026; effective July 31, 2026.
The requirement	80 hours per month of work, a work program, or qualifying community service; or enrollment in school at least half-time; or any combination adding up to 80 hours; or monthly income of at least $580 (80 hours × the $7.25 federal minimum wage).
Who it applies to	Non-pregnant adults ages 19–64 who are not enrolled in Medicare and who get (or are applying for) Medicaid through the ACA expansion group or certain Section 1115 waiver programs.
States subject	43 states + Washington, D.C. U.S. territories are excluded.
National deadline	January 1, 2027. States can request good-faith extensions in six-month increments, up to December 31, 2028.
Enforcing now	Georgia (2023), Nebraska (May 1, 2026), Montana (July 1, 2026), Arkansas (soft launch since July 1, 2026 — no coverage loss before January 2027).
Next early start	Iowa — December 1, 2026.
If you miss a month	Your state must first try to verify your hours from data it already has. If it can’t, it must send a notice and give you 30 days to show compliance or claim an exemption before coverage ends.
Litigation status	25 states + D.C. sued over the rule’s narrowed “medically frail” exemption on June 29, 2026. A federal judge declined to pause the rule on July 30, 2026. The case continues.

Why You’ll See Different State Counts (40, 41, 42, 43, or 44)

Search results for this topic disagree about how many states are affected — some say 44, one major news report said 42, others say 41. Here’s the actual arithmetic, sourced to CMS’s June 1, 2026 fact sheet:

40 states + Washington, D.C. have adopted ACA Medicaid expansion. Expansion states must apply the work requirement to their expansion adults.
3 more states — Georgia, Tennessee, and Wisconsin — never expanded, but cover some adults through Section 1115 waivers that CMS has identified as subject to the requirement.
Total: 43 states + D.C. U.S. territories are not subject.

Pages that say “44” are usually counting D.C. as a state; pages that say “41” are counting only expansion jurisdictions; “42” appears to be an error that spread through news coverage. When a source doesn’t show its math, check whether it counts D.C. and the three waiver states.

State-by-State Status: Who’s Enforcing, Who’s Next, Who’s Exempt from the Rule Entirely

Currently enforcing

State	Status	Start date	What to know
Georgia	Enforcing (state waiver program)	July 2023	Georgia never expanded Medicaid. Its Pathways to Coverage waiver (up to 100% FPL) has required 80 hours/month since 2023. The waiver runs through Dec 31, 2026 and must realign with the federal rule on Jan 1, 2027. See our Georgia guide.
Nebraska	Enforcing (federal rule)	May 1, 2026	First state to enforce under the new federal framework, via a state plan amendment. Roughly 90,000 expansion adults are being tracked, and the state began ending coverage for people who missed their hours in August 2026. See our Nebraska guide.
Montana	Enforcing (federal rule)	July 1, 2026	Second state to go live. Montana’s waiver changes also introduce new premiums for some expansion enrollees.
Arkansas	Soft launch	July 1, 2026	Arkansas is tracking hours and sending notices now, but will not end anyone’s coverage for missed hours before January 1, 2027. Arkansas previously ran work requirements in 2018, when about 18,000 people lost coverage — most of them working or exempt.

Next up: December 2026

State	Status	Start date	What to know
Iowa	Scheduled	December 1, 2026	Implements about four weeks before the federal deadline. Iowa has announced it will not offer optional hardship exemptions.

All other expansion states: January 1, 2027 (federal deadline)

Most states — including the largest expansion populations (California, New York, Illinois, Washington, Pennsylvania, Michigan, Ohio) — are building systems to meet the national deadline. Notable state-specific details:

State	What to know
Idaho	Governor signed implementing legislation in April 2026; using longer look-back periods at application than the federal minimum.
Indiana	Plans quarterly compliance checks (more frequent than required) and longer look-backs; will not offer optional hardship exemptions.
New Hampshire	Plans quarterly compliance checks.
Arizona	(Verify before publishing) Its pending waiver design applies the requirement to ages 19–55 only and includes a 5-year lifetime coverage limit for people subject to it.
Ohio	Plans to screen broader qualifying categories (age 55+, active addiction treatment, serious mental illness, intensive physical health needs) at application and renewal instead of separate hours tracking.
Pennsylvania	State officials estimate around 310,000 residents could lose coverage.
California, New York, Illinois, Washington, and 20+ others	Implementing on the January 1, 2027 deadline; no early start announced. Most are plaintiffs in the lawsuit challenging the medically frail definition.
All remaining expansion states	January 1, 2027, unless a good-faith extension is granted.

Extensions: A state that shows a good-faith effort can delay full implementation in six-month increments, no later than December 31, 2028. Several states suing over the rule have already requested delays — so some states may not enforce on January 1 even without winning in court. We track announced extensions in the changelog below.

Non-expansion states (largely unaffected by this rule)

State	Status
Alabama, Florida, Kansas, Mississippi, Texas, Wyoming	Never expanded Medicaid, no affected waiver population — the federal work requirement doesn’t apply. (These states still run their own regular Medicaid programs for children, pregnant women, seniors, and people with disabilities — those are not affected by this rule.)
Georgia, Tennessee, Wisconsin	Non-expansion, but adults covered through their 1115 waiver programs are subject.
South Carolina	Non-expansion, but runs a separate small waiver — Palmetto Pathways to Independence — covering about 11,400 parents and caregivers (incomes 67–100% FPL) with work rules, with roughly 65,000 more people on a waiting list.

Who Has to Meet the Requirement — and Who Doesn’t

The rule applies to “applicable individuals“: non-pregnant adults ages 19–64 who are not entitled to or enrolled in Medicare, and who are eligible for or enrolled in the ACA Medicaid expansion group (or a similar 1115 waiver population). You are not subject if:

You are under 19 or 65 or older
You are pregnant or in your state’s postpartum coverage period (12 months in nearly all states)
You are enrolled in Medicare
You qualify for Medicaid through a disability, SSI, foster care, or another traditional category rather than the expansion group
You meet any exemption below

Three edge cases people get wrong:

Your youngest child turns 14. The caregiver exemption covers parents and caregivers of a child age 13 or under. The day your child turns 14, you become subject to the requirement (unless another exemption applies). No one will call to warn you.
You’re on SNAP. If you’re in a household receiving SNAP and you’re not exempt from SNAP’s work requirements, you’re generally treated as compliant for Medicaid — the two programs cross-match. But SNAP’s rules changed too (see our SNAP × Medicaid guide).
You’re a part-time student. School counts toward the 80 hours if you’re enrolled at least half-time — there is no “full-time student exemption.” Half-time enrollment satisfies the requirement on its own, and part-time students can combine school hours with work or volunteering.

The 80 Hours: Every Way to Qualify

You can meet the requirement in any given month with any one of these — or a combination:

Activity	What counts	What to keep as proof
Work	Paid employment (full-time, part-time, gig, self-employment), in-kind work, and unpaid work that isn’t community service (for example, unpaid caregiving hours — see below)	Pay stubs, employer letter, invoices, tax records
A work program	Participation in a state-approved job training or workforce program	Program enrollment or participation letter
School	Enrollment in an educational program at least half-time — satisfies the 80 hours by itself	Enrollment verification, class schedule
Community service	Volunteering — but only if it meets all four conditions (below)	Signed log from the organization
The income shortcut	Monthly income of at least $580 (80 × the $7.25 federal minimum wage, 2026) satisfies the requirement outright — no hour-tracking needed	Pay stubs, wage records
Seasonal work	If you’re a seasonal worker, an average monthly income of at least $580 over the preceding 6 months qualifies	6 months of income records

The four conditions for volunteering to count. Community service must be (1) unpaid work that benefits the community, (2) completed through a structured program, (3) under the auspices of a public or nonprofit organization, and (4) tracked by the organization, which must be able to confirm your hours through a named point of contact. Informal volunteering — helping a neighbor, informal church help — does not count.

The caregiver credit. If you provide fewer than 80 hours per month of care to a person with a disability, you’re not automatically exempt — but those caregiving hours count as unpaid work toward your own 80 hours, and you can combine them with other activities.

Who Is Exempt — and How Each Exemption Is Verified

Federal law requires these exemptions everywhere the rule applies. States may add optional hardship exceptions (Iowa and Indiana have announced they will not).

Exemption	Who qualifies	How it’s verified / what you may need
Pregnant or postpartum	Through pregnancy and your state’s postpartum coverage period (12 months in nearly all states)	Pregnancy is usually already in your Medicaid record
Caregiver of a young child	Parent, guardian, caretaker relative, or family caregiver of a child age 13 or under	Household record; may require confirming the child’s age and relationship
Caregiver of a person with a disability	Providing substantial care to a disabled individual	Caregiving hours may need documentation if not in state data
Medically frail / special medical needs	People who are blind or disabled under SSI rules, have a substance use disorder, a disabling mental disorder, a physical/intellectual/developmental disability that significantly limits daily activities, or a serious or complex medical condition	States lean on the prior 12 months of your Medicaid claims and encounter data to identify frailty automatically; provider attestation is acceptable documentation; states must offer a request process if your condition isn’t on their list. This exemption’s definition is being contested in court — see below.
American Indian / Alaska Native	Eligible for services through the Indian Health Service	Tribal/IHS data match
Former foster youth	Under age 26	State foster care records
Veteran with a total disability rating	VA-rated 100% disabled	VA data match
Already meeting TANF or SNAP work rules	Meeting TANF work requirements, or a member of a household receiving SNAP who is not exempt from SNAP’s work requirements	Data match between programs
Substance use disorder treatment	Active participation in a qualifying drug or alcohol treatment or rehabilitation program	Program records
Incarcerated	Inmates of a public institution	State records

Optional hardship exceptions (state choice): states may excuse adults receiving inpatient hospital or nursing facility care, living in a county with a presidentially declared disaster, living in a high-unemployment county, or traveling for extended medical care. Nebraska adopted the high-unemployment exception — and so far no county in Nebraska qualifies under the data thresholds. Check whether your state adopted these before counting on one.

How Verification Actually Works (You May Not Have to Do Anything)

States cannot simply demand paperwork. The rule requires data-first verification: before asking you for anything, your state must try to confirm your hours or exemption from information it already has, in this order:

Electronic data sources the state has approved (payroll data, state wage records)
Information from other state or local agencies
The Federal Data Services Hub
The state’s eligibility system
Your own case record
Payroll data

If the data confirms you’re compliant or exempt, you don’t need to act. If the state has reason to believe you’re exempt but can’t yet confirm it, it can keep you enrolled while it verifies. Only when the data is insufficient does the state contact you.

How many months do you have to prove? At renewal, states choose how many months you must demonstrate during the review period — the law requires one or more months, and they don’t have to be consecutive. New applicants generally must show compliance for at least one month before the month they apply. States vary: Indiana and New Hampshire plan quarterly checks; Arkansas, Idaho, and Indiana use longer look-back periods than the federal minimum.

Two more dates that matter:

December 31, 2026 — expansion adults move to renewals every 6 months (instead of 12), with work verification at each renewal.
January 1, 2028 — documentation gets stricter. Through the end of 2027, states have flexibility in how you prove compliance; starting in 2028, they must require documentation wherever it’s reasonably available.

What Happens If You Miss a Month

In soft-launch states (Arkansas, and Montana through the end of 2026): missing hours right now will not cost you coverage before January 1, 2027.

In enforcing states (Georgia, Nebraska, and Iowa after December 1): the sequence is:

The state checks its data sources and cannot verify your hours or an exemption
You receive a noncompliance notice
You have 30 days to show compliance or claim an exemption
If you don’t respond, coverage ends — but you can reapply as soon as you can demonstrate compliance or an exemption
You have the right to appeal (request a fair hearing) if you believe the decision is wrong — deadlines vary by state, typically 30–90 days from the notice

Two warnings:

Medical bills during a gap are your responsibility, and retroactive coverage is shrinking: starting January 1, 2027, Medicaid will generally cover only about one month of care before an application for expansion adults (previously up to three).
You can lose coverage while actually working. In Arkansas in 2018, roughly 18,000 people lost coverage — the large majority were working or exempt but tripped on reporting. In Nebraska’s first week of disenrollments in August 2026, about 200 people lost coverage; the state says each case was reviewed multiple times first.

If you lose Medicaid, you likely qualify for a special enrollment period on the ACA marketplace, where subsidies can bring premiums to $0 or near it for low incomes — see our lost coverage guide.

The Lawsuit, Briefly

On June 29, 2026, 25 states and D.C. (plus the governors of Kentucky and Pennsylvania) sued CMS in federal court in Massachusetts — Commonwealth of Massachusetts v. Mehmet Oz — arguing the agency illegally narrowed the “medically frail” exemption. Congress listed five categories that qualify someone as medically frail; CMS’s June 2026 rule added that the condition must also “significantly impair your ability to comply” with the work requirement. On July 30, 2026, Judge Richard Stearns declined to pause the rule while the case proceeds, noting Congress — not CMS — set the January 1, 2027 deadline. The underlying case is still active, and the definition could still change. Practical advice: don’t wait for the courts — if you believe you’re medically frail, document it now.

How Many People Could Lose Coverage?

Source	Estimate	Time frame
CMS (the rule’s own projection)	~2.3 million fewer enrolled	Federal fiscal year 2027; 3.1–3.3 million in later years
Commonwealth Fund	~5.3 million	As the rule fully phases in (~18.5 million adults affected annually)
Urban Institute	3–7 million	Varies by state implementation
Robert Wood Johnson Foundation	Up to 7 million	By 2028
Congressional Budget Office	More than 5 million (~$326 billion in federal savings)	By 2034

The numbers differ because they measure different things — a single year vs. a phase-in, and narrow ineligibility vs. everyone at risk of paperwork failure. Researchers across these organizations broadly agree on the driver: most expected coverage loss comes from people who are working, exempt, or eligible but fail the documentation process — not from people who genuinely don’t meet the hours.

What to Do This Month: Three Checklists

If you’re already working (or in school, or volunteering):

Confirm your mailing address, phone, and email with your state Medicaid agency — most notices go by mail first
Find out whether your state is enforcing now or starts January 1, 2027
Gather 3 months of proof: pay stubs, school schedule, or volunteer logs
Check whether your earnings already clear the $580/month shortcut
Don’t assume the state knows you’re working — check your portal before your renewal

If you believe you’re exempt:

Identify which exemption applies (table above)
Confirm whether the state already has it on file call or check your portal
If not, submit documentation now (provider attestation for medical frailty; proof of relationship/age for caregiving; program letters for SUD treatment)
Respond to any state notice by its deadline, even if you think it’s a mistake

If you’re not working, not in school, and not exempt:

Check every exemption — most people who assume they’re subject actually qualify for one
If you’re truly subject: 80 hours can be built from a mix — part-time work, half-time school, approved training, qualifying volunteering
Set up volunteering correctly: a structured program, public or nonprofit organization, with an organization contact who tracks your hours
Know your safety net if coverage ends: marketplace special enrollment, community health centers, and your right to appeal and reapply

FAQ

Which states have Medicaid work requirements right now?

As of September 2026, four: Georgia (since 2023 through its Pathways waiver), Nebraska (since May 1, 2026), Montana (since July 1, 2026), and Arkansas (since July 1, 2026 — a soft launch with no coverage loss before January 2027). Iowa begins December 1, 2026.

When do Medicaid work requirements start nationwide?

January 1, 2027 is the deadline for every state subject to the rule, though states can request good-faith extensions in six-month increments through December 31, 2028. Several states have requested delays, so enforcement dates may vary by state.

How many hours do you have to work to keep Medicaid?

80 hours per month of work, a work program, or qualifying community service or enrollment in school at least half-time, or any combination totaling 80 hours. Seasonal workers can qualify on a 6-month income average instead.

Is there an income level that replaces the hours requirement?

Yes. Monthly income of at least $580 (80 hours × the $7.25 federal minimum wage) satisfies the requirement by itself, with no hour-tracking. For seasonal workers, an average of $580/month over the preceding six months qualifies.

Who is exempt from Medicaid work requirements?

Pregnant and postpartum people; caregivers of a child age 13 or under or of a person with a disability; people who are medically frail or have special medical needs; American Indians and Alaska Natives; former foster youth under 26; veterans with a total disability rating; people meeting TANF or SNAP work rules; people in substance use disorder treatment; and people who are incarcerated.

Do parents have to meet the Medicaid work requirement?

Only parents whose children are all age 14 or older (unless another exemption applies). Parents and caregivers of a child age 13 or under are exempt. Caregiving for a disabled person counts toward your own 80 hours if it’s less than 80 hours of care per month.

Does going to school count toward the 80 hours?

Yes. Enrollment at least half-time satisfies the requirement on its own you don’t need to also work. Part-time students can combine school hours with work, training, or volunteering to reach 80.

Does volunteering count for Medicaid work requirements?

Only if it’s through a structured program under a public or nonprofit organization that tracks your hours and can confirm them through a named contact. Informal volunteering helping neighbors, casual church help — does not count.

Are SSI recipients subject to Medicaid work requirements?

Generally no. Most SSI recipients qualify for Medicaid through a disability pathway, not the expansion group, so the requirement doesn’t apply to them. People who are blind or disabled under SSI rules are also a mandatory “medically frail” exemption category.

What happens if you don’t meet the Medicaid work requirement?

The state must first try to verify compliance from data it already has. If it can’t, you get a notice and 30 days to show compliance or an exemption. If you still don’t, coverage ends — but you can reapply at any time you can demonstrate compliance or an exemption, and you can appeal the decision.

Can you lose Medicaid while you’re actually working?

Yes — this is the best-documented failure mode. In Arkansas in 2018, most of the roughly 18,000 people who lost coverage were working or exempt but failed the reporting step. Keep your contact information current and check your state portal before your renewal date.

Does the Medicaid work requirement apply in Texas or Florida?

Not to this rule. Texas, Florida, Alabama, Kansas, Mississippi, and Wyoming never expanded Medicaid, so they have no expansion population for the requirement to cover. Their regular Medicaid programs for children, pregnant women, seniors, and people with disabilities continue unchanged.

Is the Medicaid work requirement the same as SNAP’s?

No — the numbers look similar (both 80 hours/month) but the rules differ, and they moved in opposite directions: SNAP removed its veteran, homeless, and former-foster-youth exemptions in November 2025, while Medicaid kept foster and tribal exemptions. See our SNAP × Medicaid comparison.

What is the “medically frail” lawsuit about?

Twenty-five states and D.C. sued on June 29, 2026, arguing CMS narrowed the medically frail exemption beyond what Congress wrote. A judge declined to pause the rule on July 30, 2026, but the case is ongoing and the definition could still change.

Has anyone actually lost coverage in 2026?

Yes. Nebraska began ending coverage in August 2026 for enrollees who didn’t report their hours — about 200 people in the first week, according to the state’s Medicaid director. Georgia’s Pathways program has had work requirements since 2023.

Medicaid Work Requirements by State (2026–2027): Status, Deadlines, Exemptions, and What to Do