A Medicaid adult whose state cannot confirm compliance with the new work rule gets a notice and 30 calendar days to respond before coverage can be denied or ended. The Centers for Medicare & Medicaid Services set that in its interim final rule, CMS-2454-IFC, which the Federal Register published on June 3, 2026 at 91 FR 33348.
CMS issued the rule on June 1, 2026, according to the law firm Goodwin, which wrote a June 2026 alert summarizing it. The rule took effect on July 31, 2026, the day its comment period closed, and states must apply the work requirement by Jan. 1, 2027. A state may start earlier. The 30-day window is the step between a state’s flag and a loss of coverage.
For an adult on Medicaid, the question is what the state needs to see within those 30 days and what form the proof takes. The rule names three routes: hours, income or an exemption. Anyone who gets a noncompliance notice can use whichever fits.
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What happens when a state flags a Medicaid adult?
The Federal Register text says states must provide “a notice of noncompliance and 30 calendar days to demonstrate a satisfactory showing” when compliance cannot be verified. The notice must explain how to show compliance or claim an exception, and how to reapply if coverage ends. The rule cites 42 CFR 435.558 for the noncompliance step.
What counts as proof of hours or income?
Goodwin quotes the process this way: after a failed verification, the individual “will then be given 30 calendar days to demonstrate compliance,” or risk denial or disenrollment.
The requirement is 80 hours a month of work, community service, a work program or half-time enrollment in school, or a combination, for adults at least 19 and under 65. The law firm Goodwin, in a June 2026 alert on the rule, adds that earning at least the federal minimum wage times 80 hours, $580 a month for 2026, also satisfies it.
States check compliance at application and renewal, and may check more often. Goodwin says the 30 calendar days also let a person show that the rule does not apply to them at all.
Who is outside the rule?
The rule does not apply to people entitled to or enrolled in Medicare, according to Goodwin. It lists pregnant and postpartum people and people with disabilities among the exempt groups, along with certain others. The federal text covers states that expanded Medicaid, including partial expansions run through section 1115 demonstrations. It excludes U.S. territories.
Can a state excuse a whole county?
States may offer short-term hardship exceptions, Goodwin says, such as for residents of a county with an unemployment rate of 8% or higher. Other optional exceptions cover people who must travel outside their community for certain medical care and people receiving services such as inpatient care. These are optional, so the choice rests with each state.
States can also ask CMS for a temporary exemption from timely implementation. The Federal Register text sets out the process under 42 CFR 435.560.
Is 30 days enough to find the paperwork?
The clock runs in calendar days, not business days, and it starts with the state’s notice. An adult who gets a letter in the mail has to find pay stubs, a volunteer log or a doctor’s note inside that window. The rule leaves the exact documents to each state, so the notice itself is the list to follow, and the state is the place to ask what it will accept.
Got a Medicaid letter about hours, income or an exemption?
The 30-calendar-day window starts when the state sends its notice, and the rule leaves it to each state to say what proof it takes. An adult who sets the letter aside, or cannot find pay records in time, risks denial or disenrollment.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, with a renewal document checklist and a renewal and reporting calendar, so the proof is gathered before the notice arrives. It includes the 90-day window after coverage is dropped, for cases that have already lapsed.
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
