Nine groups of people are excluded from the new Medicaid work requirement, which asks certain adults to show 80 hours a month of work, volunteering or school. The Centers for Medicare & Medicaid Services lists them in its rule. Anyone in one of those groups does not have to log hours to keep coverage.

States must start enforcing the requirement by January 1, 2027, so the question for many households is not whether the rule exists but whether it reaches them.

Who has to meet the 80-hour test

The CMS fact sheet on the interim final rule says the requirement covers non-pregnant adults aged 19 to 64 who are not on Medicare and who are in the Medicaid adult group or certain state demonstration programs. CMS says 43 states and the District of Columbia are affected. U.S. territories are not.

A person meets the test in a month by working, doing community service or taking part in a work program for at least 80 hours, by being enrolled in school at least half-time, or by combining those. Monthly income of at least 80 times the federal minimum wage also counts, which CMS puts at $580 a month in 2026.

The test sits in federal law, which the Medicaid.gov summary of the Working Families Tax Cut legislation describes as 80 hours of work, community service, a work program or half-time school. Applicants are looked at for one to three months before they apply, and the summary says coverage is to be rechecked every six months starting January 1, 2027.

For anyone on Medicaid who is between 19 and 64, the practical question is whether they fit one of the nine exclusions below, and whether they can document it when the state asks. That is the part that decides whether the state will count hours at all.

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The nine groups the rule leaves out

The Federal Register notice published June 3, 2026, lists nine specified excluded categories, and the CMS fact sheet repeats them. The rule took effect July 31, 2026. In the rule’s own wording, the people left out are:

• Former foster care youth.
• American Indians and Alaska Natives.
• Parents, guardians, caretaker relatives or family caregivers of a dependent child aged 13 or under, or of a disabled person.
• Veterans with a total disability rating.
• Medically frail people, or people with special medical needs that significantly impair their ability to comply.
• People who meet TANF work requirements, or who live in a SNAP household and are not exempt from SNAP work rules.
• People in a drug or alcohol treatment program.
• Inmates of a public institution.
• Pregnant people, and those eligible for postpartum coverage.

CMS itself calls them excluded rather than exempt, and the two words mean the same thing here. The titles are short, but the definitions in the regulation are where a case is won or lost.

The text of 42 CFR 435.554 defines a dependent child as one aged 13 or under who relies on another person for care. It describes the medically frail group as people whose physical, mental or behavioral health condition significantly impairs their ability to comply, including blindness or disability, substance use disorder and disabling mental disorders.

The same regulation describes the veteran exclusion as a disability from the Department of Veterans Affairs rated 100 percent (total). It sends the American Indian definition to a separate federal regulation, so tribal enrollment questions are answered there.

How a state checks, and what happens to someone who falls short

Under the CMS fact sheet, states must verify compliance at application and at renewal, and may check more often. New applicants must meet the requirement for at least one month before the month they apply. For existing enrollees, it is one or more months between renewals.

The Federal Register notice makes the state check data it already holds before asking the enrollee for anything, a step it calls ex parte verification. That is why an exclusion that shows up in existing records, such as a veteran’s disability rating, may never need a separate form.

The medically frail group is the one most likely to need paperwork. The health research group KFF reports in its analysis of the rule that a diagnosis alone cannot verify frailty, so states cannot simply exempt people from a list of conditions. States may accept a provider’s confirmation, and self-attestation is allowed through 2027 when reliable data is missing.

If a state cannot confirm compliance, it must send a notice of noncompliance and give the person 30 calendar days to show either the hours or an exemption. An applicant who fails may be denied, and an enrollee may be disenrolled. Someone who is disenrolled may reapply at any time and will be assessed again.

Four hardship exceptions are not on the list of nine

The fact sheet separates the nine required exclusions from four short-term hardship exceptions that states may choose to offer. They cover people receiving certain medical services such as inpatient hospital or nursing facility care, people in a county with a presidentially declared disaster or emergency, and people in a county with high unemployment. A fourth covers travel outside the community for serious or complex medical care.

The difference matters. The nine groups are required in every state that carries out the rule. The four hardship exceptions are up to each state, and the Federal Register notice adds that states may also ask CMS for a temporary good-faith exemption from the January 1, 2027 deadline.

No named CMS official is quoted in the fact sheet, which lists only a media contact. The practical details, such as which forms prove caregiving or a medical condition, are left to each state’s Medicaid agency, so the notice a household gets from its own state is the one that counts.

On Medicaid and not sure which of the nine groups applies?

The risk is not being left out of the list. It is being in a group on paper and having no proof ready when the 30-day notice arrives. A caregiver or a medically frail enrollee who cannot document the exclusion in time can lose coverage, even though the rule leaves them out.

The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, and it includes a renewal document checklist and 51 state packs. Part 6 of the organizer is built around the new work rule and the 90-day rescue if coverage is dropped.

Get the Medicaid work-rule guide and renewal document checklist for the nine exclusions →

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This article was produced with AI assistance and edited for accuracy against the sources linked above.