A law firm’s analysis of a new federal work-reporting rule says about 2.3 million fewer people will be on Medicaid in fiscal year 2027. The Centers for Medicare & Medicaid Services issued the rule on June 1, 2026, and it applies to adults in the group of states that expanded Medicaid. The estimate appears in a Foley Hoag analysis of the rule, which attributes the projection to CMS.
What does the new rule require?
Under CMS’s fact sheet on the community engagement requirement, affected adults must meet an 80-hours-per-month requirement. Work, community service, education or an equivalent activity can count toward those hours.
The requirement applies to adults between the ages of 19 and 64. According to a Foley Hoag analysis of the rule, it covers the adult expansion group: people who are not pregnant, with incomes up to 133 percent of the federal poverty level, in the 41 expansion states and the District of Columbia. It does not apply to U.S. territories.
Who would a Medicaid recipient need to be to feel it?
A person on expansion Medicaid between 19 and 64 who is not in one of the exempt groups would have to show the 80 hours. Someone 65 or older is outside the age range, as is anyone whose Medicaid comes through a different category, such as pregnancy.
For a 60-year-old on Medicaid who is not working, the first thing to find out is whether an exclusion applies. That is the question that decides whether the 80 hours ever becomes that person’s problem.
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What date must each state be ready by?
CMS says states must generally put the requirement in place no later than January 1, 2027. That date is the outer limit. A state can start earlier, and a state that cannot be ready can ask for a good-faith-effort exemption, which expires no later than December 31, 2028.
The 2.3 million projection is for fiscal year 2027, the federal budget year that began on October 1, 2026. It depends on states switching the rule on during that year, so the full effect depends on how quickly each state moves.
The figure is a projection, not a count of people who have already lost coverage. It describes what the Foley Hoag analysis says CMS expects once states begin asking certain adults to prove they work, volunteer or study.
Who is exempt from the 80 hours?
The rule lists nine groups of “specified excluded individuals.” They are:
- Former foster care youth
- American Indians and Alaska Natives
- Parents, guardians, caretaker relatives or family caregivers of a dependent child 13 or younger or of a disabled person
- Veterans with a total, 100 percent disability rating
- People who are medically frail or have special medical needs
- People who meet TANF work requirements, or who are in a SNAP household and not exempt from SNAP work requirements
- People in drug addiction or alcohol treatment and rehabilitation programs
- Inmates of a public institution
- Pregnant people and those entitled to postpartum coverage
CMS estimates that about 24 percent of the people the rule applies to will qualify for one of these exclusions. The fact sheet’s text and table differ slightly on the age of a child, saying under 14 in one place and 13 and under in another, which describe the same cutoff.
How many people will actually lose coverage?
The 2.3 million figure is the one Foley Hoag reports for fiscal year 2027, and its analysis does not say what enrollment baseline it is measured against. It is an estimate of reduced enrollment attributed to CMS, not a list of named people.
Public comments on the interim final rule were accepted through July 31, 2026, the same date the rule takes effect. Whether the number holds up will depend on how states design their reporting systems and how many exempt people are correctly identified.
Anyone with questions about a specific case can start at Medicaid.gov, which lists federal guidance, and then at their own state Medicaid office, which sets the reporting process.
On expansion Medicaid before January 1, 2027?
The work rule carries a deadline of January 1, 2027, and an adult between 19 and 64 who misses a reporting step can be dropped even when an exemption applies. The 80 hours a month, and the nine exclusions, only help if the right facts reach the state.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, in plain steps. It also includes a renewal document checklist and a renewal and reporting calendar, plus a state pack for each of the 51 states, so a Medicaid recipient can keep every date in one place.
Get the Medicaid work-rule exemption guide and renewal calendar →
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
