Medicaid work requirements from President Trump’s 2025 law start January 1, 2027, and KFF counts 44 states, including the District of Columbia, that must apply them to adults covered through the Affordable Care Act’s Medicaid expansion. A separate KFF survey, taken in the first three months of 2026, found that 34 states plan to verify compliance every six months. Most of the practical details are still being settled state by state.
According to the KFF Medicaid work requirements tracker, the law requires those 44 states to condition Medicaid eligibility on work for expansion-group adults, and some people in waiver programs face the same test. A household with an adult in that group can start by asking the state Medicaid agency how it will collect proof, because states are choosing different timing and methods.
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Which states and programs does the January 1 start cover?
KFF’s tracker, last updated September 29, 2026, says the requirement begins January 1, 2027, in 44 states including D.C. That count covers the states that expanded Medicaid under the Affordable Care Act and a few that did not.
The tracker also lists waiver programs identified in a list the Centers for Medicare & Medicaid Services released in June 2026. Three are in non-expansion states: Georgia, Tennessee and Wisconsin. Five are in expansion states: Hawaii, Massachusetts, New York, Oregon and Utah.
Because Georgia, Tennessee and Wisconsin did not expand Medicaid, the rule there reaches waiver enrollees rather than the expansion group. In the five expansion states with waivers, the waiver enrollees sit alongside the expansion adults the law covers directly. A reader in any of those eight places should check which category their own coverage falls under.
How often will states recheck compliance?
KFF’s April 30, 2026 report, written by Jennifer Tolbert, Amaya Diana, Anna Mudumala, Tricia Brooks, Yuliya Yafimenka and Antony Lin, surveyed 43 states, including D.C., about their plans. Thirty-four reported that they will verify work compliance every six months at renewal.
Indiana and New Hampshire plan to check quarterly instead, and seven states had not decided. Those are plans from the winter survey, so a state can still change course before January.
What is the lookback when someone applies?
At application, 36 states told KFF they will look back one month to see whether the applicant met the work rule. Indiana and Idaho will look back three months, and five states had not decided.
At renewal, Arkansas also reported a three-month lookback. A longer lookback matters because a person who had a gap in work or volunteer hours in that window can be turned away even if hours are back up today.
Which exemptions are still unsettled?
Twenty-nine states plan to adopt at least one optional short-term hardship exception, KFF reported. Indiana and Iowa plan none, Oklahoma, Missouri and New York each skip one, and 12 states had not decided.
Medical frailty is the larger open question. About half of states, 22, have a current definition, but KFF said it is unclear whether those match the law, and 33 states had not chosen one. Thirty-two states plan to use Medicaid claims data to confirm frailty, and 30 want to let people self-attest when data are missing, though they are unsure federal rules will allow it. States also want CMS guidance on what counts as a significant relationship for the parent and caretaker exemption.
What is left to learn before January 1?
The January 1, 2027 start date and the 44-state count come from KFF’s tracker, while the choices on lookbacks, six-month checks and exemptions are still the states’ to announce. The open question for any family is which of those choices their own state makes, and how soon its Medicaid agency tells members what paperwork to keep.
Does the Medicaid work rule reach a household in one of the 44 states?
A household that misses a state notice about proving work hours can lose Medicaid coverage over paperwork, and KFF’s survey shows that notices, lookbacks and exemptions will not look the same in every state.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt in a dedicated part on the new rule, and it comes with 51 state packs for SNAP and Medicaid. It also adds a renewal calendar so dates are not lost.
See the organizer’s Medicaid work-rule and exemption pages for a January 1 start →
More Financial Reading
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- 15 Places to Find Your Share of the $4.25 Billion States Give Back
- 17 Medicare Money Moves Now That Part D Caps at $2,400
This article was produced with AI assistance and edited for accuracy against the sources linked above.
