The Centers for Medicare & Medicaid Services has named nine groups of people who are excluded from the new Medicaid work requirement. They include veterans with a total disability rating, people who are pregnant or eligible for postpartum coverage, and members of households receiving SNAP, the food stamp program, who are not exempt from SNAP’s own work requirements.
The list appears in a CMS fact sheet dated June 1, 2026 on the interim final rule for the community engagement requirement. The rule applies to a narrower group than all Medicaid enrollees, so the exclusions decide who actually has to prove work or other activity to keep coverage.
Who has to meet the Medicaid work rule?
CMS says the requirement covers non-pregnant adults ages 19 to 64 who are not entitled to or enrolled in Medicare and who are eligible for or enrolled in the Medicaid adult group, or in certain section 1115 demonstrations. Anyone 65 or older, or on Medicare, falls outside it.
People covered must show 80 hours a month of qualifying activities. CMS also allows them to meet the rule by earning at least 80 times the federal hourly minimum wage, which the fact sheet puts at $580 a month in 2026. States must generally put the requirement in place no later than January 1, 2027, and the fact sheet notes that states may begin earlier.
What are the nine excluded groups?
CMS’s key-provisions table lists these nine groups as excluded:
- Former foster care youth
- American Indians and Alaska Natives
- Parents, guardians, caretaker relatives or family caregivers of a dependent child 13 years of age and under, or of a disabled individual
- Veterans with a total disability rating
- People who are medically frail or otherwise have special medical needs that significantly impair their ability to comply with the requirement
- People who meet the TANF work requirements, or who are a member of a household receiving SNAP benefits and are not exempt from the SNAP work requirements
- Participants in a drug or alcohol rehabilitation or treatment program
- Inmates of a public institution
- People who are pregnant or eligible for postpartum coverage in their state
The fact sheet’s narrative section adds that “certain others” are exempt as well, so the nine in the table are the ones CMS spells out by name.
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Is the caregiver exemption for children under 14 or 13 and under?
The two phrases mean the same age cutoff. The narrative says parents and caretakers of children “under 14 years of age,” while the table says “13 years of age and under.” The table also extends the caregiver exclusion to people who care for a disabled individual of any age, which matters for adults looking after a spouse, parent or adult child.
Who counts as a caretaker relative or family caregiver is something each state’s Medicaid agency will apply. A caregiver who is unsure should ask the state agency in writing before the state’s start date.
How does the food stamp exclusion work?
This is the row that touches the most households. CMS’s wording is that the exclusion applies to people who “meet the TANF work requirements or are a member of a household receiving SNAP benefits and are not exempt from the SNAP work requirements.” CMS lists that group among the nine, so a household already held to SNAP’s work rules is on the excluded list.
The fact sheet does not explain how a state will confirm SNAP status, so the practical question is whether the Medicaid agency sees the SNAP record automatically. The state’s own notice should say.
What happens if a person is on the list but the state does not know it?
An excluded person still has to be identified as excluded in the state’s records. CMS describes the groups, and each state agency decides how it collects proof of, say, a total disability rating from the Department of Veterans Affairs or a pregnancy. Anyone who falls in one of the nine groups and gets a notice about work hours should answer it and name the exclusion rather than ignore it.
The federal rule sets the floor, with January 1, 2027 as the general latest start. Because states may begin earlier, the date a given enrollee faces the requirement depends on the state, and CMS’s fact sheet does not list state dates. The agency points readers to Medicaid.gov for program information.
Does one of the nine groups describe the person on the Medicaid card?
A person aged 19 to 64 on Medicaid who belongs to one of the nine groups can lose coverage by missing the paperwork, not by failing the rule. The groups are broad, from caregivers of a child 13 and under to veterans with a total disability rating, and a state notice does not always say which one applies.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt in Part 6, alongside 51 state packs, a renewal document checklist and a renewal and reporting calendar. It also lays out the 90-day window after coverage is dropped.
Get the exempt-groups walkthrough and state pack for the Medicaid work rule →
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This article was produced with AI assistance and edited for accuracy against the sources linked above.




