Starting January 1, 2027, most states will be required to enforce work-related requirements for certain adults enrolled in Medicaid. This is a major shift. Until recently, Medicaid had no federal work requirement, and only a handful of states had experimented with one through special waivers. A law signed on July 4, 2025, changed that by making “community engagement requirements” a mandatory part of the program nationwide.
What the New Federal Law Requires
The Working Families Tax Cut legislation, signed into law in July 2025, added community engagement requirements to Medicaid for certain working-age adults. Under this law, states must begin enforcing these requirements by January 1, 2027, though they can choose to start sooner. States that aren’t ready in time can request a temporary exemption from the federal government to delay implementation, but that extension cannot last beyond December 31, 2028. In other words, every state will need to have a system in place by the end of 2028 at the latest.
The law is structured so that states cannot opt out. Previous work requirement efforts relied on special demonstration waivers that individual states applied for and that could be approved or denied by whichever presidential administration was in office. This new requirement is written directly into federal Medicaid law, and the legislation explicitly states that it cannot be waived.
Who It Applies To
The requirements target non-elderly adults, generally those between 19 and 64. Several groups are expected to be exempt, though the exact exemptions will vary somewhat by state. Adults with disabilities, pregnant women, primary caregivers of young children or family members with serious health needs, and people already engaged in school or treatment programs have historically been carved out of state-level work requirement programs. The federal law follows a similar framework, focusing on adults who don’t fall into these categories.
Children, seniors, and people who qualify for Medicaid through disability-related pathways are not subject to the new rules.
What Counts as “Community Engagement”
Despite the name, the requirement isn’t limited to holding a job. To stay eligible, a non-exempt adult must log at least 80 hours per month in one or a combination of qualifying activities. That breaks down to roughly 20 hours per week. The activities that count include:
- Employment: Working at a job for 80 hours, or earning monthly income equivalent to 80 hours at the federal minimum wage (currently $580 per month)
- Community service: Volunteering for 80 hours per month
- Work programs: Participating in a state-approved job training, vocational rehabilitation, or workforce development program
- Education: Enrolling in school or a job training program
- Substance use treatment: Some state plans, like Ohio’s proposed waiver, count active participation in alcohol or drug addiction treatment
- A combination: Mixing any of the above to reach 80 total hours
Georgia’s Pathways to Coverage program, one of the few state programs already operating with a work requirement, offers a useful preview. It requires 80 hours of qualifying activities per month and allows members to request a “Good Cause Exception” if they fall short in a given month due to circumstances beyond their control.
How You’ll Need to Report Your Hours
This is where the requirement gets complicated in practice. State Medicaid agencies will need to verify that each enrollee meets the 80-hour threshold every month. Some of that verification can happen through existing databases, like wage records and tax filings, but those systems typically show whether someone is employed, not how many hours they worked in a given month. For people piecing together community service, training programs, and part-time work, state agencies will need to collect additional documentation directly from the enrollee each month.
The federal law does include one notable restriction on how states can handle this process: states cannot use their Medicaid managed care plans or contractors affiliated with those plans to determine whether someone is in compliance. That means state agencies themselves will need to build or expand systems to track and verify hours, a significant administrative undertaking.
The specifics of how you’ll report, whether through an online portal, paper forms, or phone, will depend on your state. Those systems are still being developed in most places.
What Happens If You Don’t Meet the Requirement
The consequences of not meeting the 80-hour threshold will vary by state, but the general structure ties eligibility to compliance. If you don’t report enough qualifying hours in a given month, you risk losing your Medicaid coverage. States are expected to build in some procedural protections, like the good cause exceptions Georgia already uses, but the core mechanism is straightforward: fail to document your hours, and your coverage is at risk.
Past experience with state-level work requirements suggests that administrative barriers, not unwillingness to work, drive most coverage losses. When Arkansas implemented a work requirement in 2018, more than 18,000 people lost coverage over several months. Many of them were already working or should have qualified for an exemption but didn’t navigate the reporting system correctly. The reporting burden itself became the primary obstacle.
States That Already Have Work Requirements
Georgia is currently the only state actively enforcing a Medicaid work requirement through its Pathways to Coverage program. Several other states have approved or pending waivers to implement their own versions ahead of the 2027 federal deadline. Ohio, for example, has proposed a program where enrollees can qualify by meeting one of several criteria: being employed, being over 55, attending school or job training, participating in addiction treatment, or having serious physical or mental health needs.
Arkansas ran a work requirement program briefly in 2018 before courts blocked it. That legal battle eventually reached the Supreme Court, which sent the case back without a definitive ruling on whether work requirements were legal under the old framework. The 2025 law makes that legal question largely moot by writing the requirement directly into statute rather than relying on administrative waivers.
Timeline to Watch
If you’re currently enrolled in Medicaid, nothing changes immediately. The federal requirement takes effect January 1, 2027, and states that need more time can delay until the end of 2028. Your state will announce its specific plan, including which activities qualify, how to report, and what exemptions are available, before enforcement begins. States that want to move faster can begin implementing requirements before 2027 through their state Medicaid plan or a demonstration waiver.
The practical impact will depend heavily on how each state designs its reporting system and how aggressively it enforces compliance. States with simpler, more accessible reporting processes will likely see fewer people lose coverage for paperwork reasons. States with cumbersome systems could see significant enrollment drops, particularly among people who are already working but struggle with monthly documentation.