The requirement covers people who can get or have Medicaid through the adult group (42 CFR 435.119), unless they fall in an excluded group. 42 CFR 435.551(a)
A person meets the requirement for a month with at least 80 hours of work, 80 hours of community service or 80 hours in a work program. 42 CFR 435.552(a)
States must apply the requirement to Medicaid provided on or after Jan. 1, 2027, unless CMS grants an exemption. 42 CFR 435.559(a)
This checker asks up to six questions and links each rule it uses to the regulation or government page it comes from.
Medicaid Work Requirement Checker
Answer up to six questions to see whether Medicaid’s new work requirement (the regulation calls it community engagement) is likely to apply, what counts toward the monthly hours, and when states must start. It covers the common rules, and each result names the exceptions that could change it.
How to answer this
The adult group covers people 19 through 64 who aren’t pregnant, aren’t entitled to or enrolled in Medicare Part A or B, and have household income at or below 133% of the federal poverty level. 42 CFR 435.119(b)
People who are pregnant, or entitled to Medicaid’s postpartum coverage, are excluded. 42 CFR 435.554(c)(10)
A woman who had Medicaid while pregnant keeps pregnancy-related and postpartum coverage through the end of the month in which the 60-day period after the pregnancy ends. U.S. Code
A state may choose to extend that coverage through the end of the month in which the 12-month period after the pregnancy ends. U.S. Code
The requirement applies in the 50 states and Washington, D.C. It doesn’t apply in the U.S. territories. 42 CFR 435.550
How this checker works:
- The requirement covers people who can get or have Medicaid through the adult group (42 CFR 435.119), unless they fall in an excluded group. 42 CFR 435.551(a)
- The adult group covers people 19 through 64 who aren’t pregnant, aren’t entitled to or enrolled in Medicare Part A or B, and have household income at or below 133% of the federal poverty level. The adult group doesn’t include people who are eligible for and enrolled in one of Medicaid’s mandatory coverage groups. States must cover parents and other caretaker relatives, with household income at or below a state-set standard, in a separate parents and caretaker relatives group. 42 CFR 435.119(b)42 CFR 435.119(b)(4)42 CFR 435.110(b)
- It also covers adults 19 through 64 in a state’s Section 1115 demonstration project that provides full (minimum essential) coverage, if they aren’t pregnant, aren’t entitled to or enrolled in Medicare Part A, aren’t enrolled in Part B, and can’t otherwise get Medicaid under the state plan. 42 CFR 435.551(b)
- Starting on the implementation date, eligibility in the adult group is subject to the requirement in every state and Washington, D.C., that covers the adult group. Some states have expanded Medicaid to cover everyone with household income below a certain level, and others haven’t. 42 CFR 435.119(d)HealthCare.gov
- People in an excluded group aren’t subject to the requirement at all: it isn’t a condition of their eligibility. 42 CFR 435.554(b)
- A person meets the requirement for a month with at least 80 hours of work, 80 hours of community service or 80 hours in a work program. 42 CFR 435.552(a)
- States must apply the requirement to Medicaid provided on or after Jan. 1, 2027, unless CMS grants an exemption. 42 CFR 435.559(a)
How This Checker Decides
- The requirement covers people who can get or have Medicaid through the adult group (42 CFR 435.119), unless they fall in an excluded group. 42 CFR 435.551(a)
- The adult group covers people 19 through 64 who aren’t pregnant, aren’t entitled to or enrolled in Medicare Part A or B, and have household income at or below 133% of the federal poverty level. The adult group doesn’t include people who are eligible for and enrolled in one of Medicaid’s mandatory coverage groups. States must cover parents and other caretaker relatives, with household income at or below a state-set standard, in a separate parents and caretaker relatives group. 42 CFR 435.119(b)42 CFR 435.119(b)(4)42 CFR 435.110(b)
- It also covers adults 19 through 64 in a state’s Section 1115 demonstration project that provides full (minimum essential) coverage, if they aren’t pregnant, aren’t entitled to or enrolled in Medicare Part A, aren’t enrolled in Part B, and can’t otherwise get Medicaid under the state plan. 42 CFR 435.551(b)
- Starting on the implementation date, eligibility in the adult group is subject to the requirement in every state and Washington, D.C., that covers the adult group. Some states have expanded Medicaid to cover everyone with household income below a certain level, and others haven’t. 42 CFR 435.119(d)HealthCare.gov
- People in an excluded group aren’t subject to the requirement at all: it isn’t a condition of their eligibility. 42 CFR 435.554(b)
- A person meets the requirement for a month with at least 80 hours of work, 80 hours of community service or 80 hours in a work program. 42 CFR 435.552(a)
- States must apply the requirement to Medicaid provided on or after Jan. 1, 2027, unless CMS grants an exemption. 42 CFR 435.559(a)
What Counts Toward 80 Hours
- A person meets the requirement for a month with at least 80 hours of work, 80 hours of community service or 80 hours in a work program. 42 CFR 435.552(a)
- Being enrolled in an educational program at least half-time also meets it, as the school defines half-time. 42 CFR 435.552(a)(4)
- So does any mix of work, community service, a work program and school that adds up to at least 80 hours. 42 CFR 435.552(a)(5)
- So does monthly income of at least the federal minimum wage times 80 hours. The federal minimum wage is $7.25 an hour, so 80 hours at that wage comes to $580 a month. 42 CFR 435.552(a)(6)U.S. Code
- A seasonal worker meets it with average monthly income over the previous 6 months of at least that amount. 42 CFR 435.552(a)(7)
- Work includes paid work, work in exchange for goods or services, and unpaid work other than community service. 42 CFR 435.552(b)
- Community service is unpaid work, voluntary or court-ordered, done through a structured program of a public or nonprofit organization for the direct benefit of the community. The organization must oversee it, keep it nonpartisan and track the hours. 42 CFR 435.552(b)
- Work programs include Workforce Innovation and Opportunity Act (WIOA) programs, state employment and training programs such as SNAP employment and training, and Labor Department or VA employment and training programs for veterans. A program that is only supervised job search or job search training doesn’t count. 42 CFR 435.552(b)
Who Is Excluded or Not Covered
- A state must count the requirement as met for any month in which the person was under 19 for part or all of the month. 42 CFR 435.553(a)(1)
- A state must count the requirement as met for any month in which the person was entitled to or enrolled in Medicare Part A, or enrolled in Part B, for part or all of the month. 42 CFR 435.553(a)(2)
- The requirement applies in the 50 states and Washington, D.C. It doesn’t apply in the U.S. territories. 42 CFR 435.550
- Parents, guardians, caretaker relatives and family caregivers are excluded if they care for a child 13 or younger who relies on others for care, or for a person with a disability. 42 CFR 435.554(c)(3)
- People who are medically frail or have special medical needs are excluded: those with a health condition that significantly impairs their ability to meet the requirement, together with a listed condition such as blindness or a disability, a substance use disorder (unless in stable recovery), a disabling mental disorder or a serious or complex medical condition. The state must first try to confirm medical frailty from information it has, including medical claims from the past 12 months. 42 CFR 435.554(c)(5)(i)42 CFR 435.557(f)(1)
- People who meet Medicaid’s definition of “Indian” (42 CFR 447.51) are excluded. 42 CFR 435.554(c)(2)
- Veterans with a temporary or permanent VA disability rating of 100% (total) are excluded. 42 CFR 435.554(c)(4)
- Former foster youth who fit Medicaid’s former foster care group are excluded. 42 CFR 435.554(c)(1)
- Members of a household that gets SNAP (food stamp) benefits are excluded when a SNAP work requirement applies to them, meaning they aren’t exempt from it. 42 CFR 435.554(c)(7)
- People complying with the work requirements their state sets for TANF cash assistance (Section 407 of the Social Security Act) are excluded. 42 CFR 435.554(c)(6)
- People in a drug addiction or alcoholic treatment and rehabilitation program are excluded. A state may set a minimum time commitment for the program. 42 CFR 435.554(c)(8)
- People who are pregnant, or entitled to Medicaid’s postpartum coverage, are excluded. 42 CFR 435.554(c)(10)
- An inmate of a public institution is excluded. 42 CFR 435.554(c)(9)
When States Must Start
- States must apply the requirement to Medicaid provided on or after Jan. 1, 2027, unless CMS grants an exemption. 42 CFR 435.559(a)
- A state may choose to start before Jan. 1, 2027. 42 CFR 435.559(b)
- For people already enrolled on the state’s start date, the state checks compliance at their first renewal that begins on or after that date. 42 CFR 435.559(c)
- CMS may give a state that shows a good faith effort a temporary exemption, which must end no later than Dec. 31, 2028. 42 CFR 435.560(c)
- Before the start, a state must notify people who may be covered: three months ahead, plus the number of months it checks at application. 42 CFR 435.561(b)(1)
How States Check Compliance
- At application, the state checks 1 to 3 consecutive months, as its state plan sets, just before the month of application. 42 CFR 435.556(a)(1)
- For people already enrolled, the state checks 1 or more months, not necessarily in a row, as its state plan sets, between the last eligibility decision and the renewal. 42 CFR 435.556(a)(2)
- A state may check more often than at each renewal. 42 CFR 435.557(d)
- The state must try to confirm compliance or an exclusion from information it already has, such as payroll data, before asking the person for documents. 42 CFR 435.557(c)(1)
- A state can’t deny or end coverage just because a person can’t produce documents that don’t exist or aren’t reasonably available. 42 CFR 435.557(b)(2)(iii)
If the State Can’t Confirm Compliance
- If the state can’t verify compliance, it must send a notice of noncompliance and give the person 30 days from receiving it to show they met the requirement or that it doesn’t apply to them. 42 CFR 435.558(a)
- The notice counts as received 5 days after the date on it, unless the person shows it arrived later. 42 CFR 435.558(c)(4)
- An enrolled person keeps Medicaid until the state finds them ineligible. 42 CFR 435.558(a)(3)
- Before denying or ending coverage, the state must consider every other way the person might qualify for Medicaid. 42 CFR 435.558(d)(1)
- If no satisfactory showing is made, an enrolled person is disenrolled no later than the end of the month after the month the 30 days end, with advance written notice and fair hearing rights first. 42 CFR 435.558(d)(2)(ii)
- The notice must explain what noncompliance means for Medicaid and for premium tax credits used to pay for Marketplace coverage. 42 CFR 435.558(c)(1)(v)
- A state can’t restrict reapplying, or coverage after reapplying, because of an earlier denial or disenrollment for noncompliance. 42 CFR 435.558(e)