States can hold off on cutting people from Medicaid for missing the new work requirement until July 2027. The Centers for Medicare & Medicaid Services announced the option on Friday, Nov. 13, calling it a "hold harmless" period that runs through June 30, 2027.
The requirement itself still starts on Jan. 1, 2027. States that sign up will check whether people meet the requirement or qualify for an exemption, but they will not deny an application or end someone's coverage only because that person fell short of it.
The period is optional. Whether it applies to you depends on your state, and CMS did not list which states plan to use it.
Who the requirement covers
The rule applies in the 43 states and the District of Columbia that cover the Medicaid expansion adult group or similar adult coverage through federal waivers, according to the CMS fact sheet on the interim final rule. It reaches adults ages 19 to 64 who are not pregnant and are not on Medicare.
To meet it in a given month, a person needs one of these:
- 80 hours of work, community service or a work program
- Enrollment in school at least half time
- A mix of those activities adding up to 80 hours
- Monthly income of at least 80 times the federal minimum wage, which CMS puts at $580 a month in 2026
Many people are exempt. The list includes people who are pregnant or postpartum, people who are medically frail or have a total disability rating as a veteran, parents and caregivers of children 13 and under or of a person with a disability, American Indians and Alaska Natives, former foster youth, and people in drug or alcohol treatment. Edit USA laid out the full list and how the 80 hours work on Nov. 3.
What happens after June 2027
Once a state stops using the hold harmless period, the normal rules apply. If the state cannot confirm that someone meets the requirement, it must send a notice and give the person 30 days to show they comply or are exempt. People who are cut off can reapply at any time.
CMS also urged states to check data they already hold before asking people for paperwork, and to send notices that say what the state has already verified. "If the state can use data to show that someone is working or qualifies for an exclusion, that person should not have to track down paperwork to prove it," said Dan Brillman, who directs the agency's Center for Medicaid and CHIP Services.
What to do now
If you are on Medicaid and between 19 and 64, read every notice your state sends about the work requirement and answer by the deadline it gives. Ask your state Medicaid office whether it is using the hold harmless period, and keep pay stubs or school enrollment records handy in case the state cannot match your data on its own.
The requirement is also in court. Four states sued on Nov. 5 to keep their Medicaid funding if they refuse to carry it out.
