Starting January 1, 2027, most states running Medicaid will have to verify that certain adult enrollees are working, training, volunteering, or otherwise staying active for a set number of hours each month before they can keep their coverage. The requirement comes from an interim final rule the Centers for Medicare & Medicaid Services issued on June 1, 2026, carrying out a provision Congress wrote into this year’s tax law. It will not touch every Medicaid enrollee, and it does not cut anyone off the moment a report is missed — the rule builds in a specific written-notice period first. Here is how the hours test and the notice process are actually supposed to work between now and the deadline.
The 80-Hour Test, and the Income Shortcut Around It
The number at the center of the rule is 80. Adults subject to the requirement have to document 80 hours a month of qualifying activity — paid work, a state-approved work program, community service, or at least half-time enrollment in an educational program — and they can combine those categories to add up to the total rather than clearing it through one alone.
There is also a way to satisfy the rule without logging a single hour: earning at least 80 times the federal hourly minimum wage in a month. CMS’s fact sheet puts that at $580 in 2026, and the rule’s own text in the Federal Register shows the math behind it: the $7.25 federal minimum wage multiplied by 80 hours. Seasonal workers get a six-month income average instead. New Medicaid applicants generally have to show they already met the requirement for at least one month before the month they apply, while people already enrolled have to meet it for one or more months between renewals.
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Non-Pregnant Adults 19 to 64, Not on Medicare
The rule is narrower than “Medicaid work requirement” headlines can make it sound. It applies only to non-pregnant adults between the ages of 19 and 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 that provide minimum essential coverage to adults. Anyone on Medicare, anyone outside that age band, and anyone who fits one of CMS’s separate exemption categories — including veterans with a total disability rating, former foster youth, and family caregivers of young children — sits outside the requirement entirely.
States’ Own Checklist Before the Deadline
States carry their own list of jobs ahead of January 1, 2027. CMS’s fact sheet spells out five of them: identifying who is and isn’t subject to the requirement, including who qualifies for an exemption; verifying compliance at application and at renewal; conducting outreach to affected enrollees before the requirement takes hold; following defined steps when someone is found noncompliant; and reporting implementation data back to CMS. That last piece has teeth — the statute behind the rule, Section 71119 of the Working Families Tax Cut law, Public Law 119-21, is what CMS is enforcing here, and the agency says states that fail to submit required data or show compliance problems of their own can face corrective action.
CMS is also underwriting technical help for the system builds this requires. Medicaid technology vendors have separately pledged $600 million in savings toward state system upgrades, and CMS runs a support program for states called Eligibility Made Easy, both tracked on the same medicaid.gov page that houses the rule.
Forty-Three States, Plus the District of Columbia
CMS is specific about scope: “43 states and the District of Columbia provide coverage to these populations and will be required to implement the new requirement; U.S. territories are not subject to this law,” the agency’s fact sheet states. That is CMS’s own count and its own phrasing — 43 states as one figure, the District of Columbia named separately alongside them, for 44 jurisdictions in total that will actually administer the requirement. States that never extended Medicaid coverage to the relevant adult population are not on the list at all, which is why the count is smaller than the 50-state total.
The 30 Days Before Anyone Loses Coverage
CMS lays out a specific sequence for what happens when a state can’t confirm someone met the hours test. States must check compliance at application and at renewal, and may check more often if they choose. If a state cannot verify the requirement was met, it has to send a notice of noncompliance and give the person 30 calendar days to demonstrate either that they met the requirement or that it doesn’t apply to them. Only after that 30-day window closes without an answer can the state deny the application or disenroll the person. Anyone disenrolled for missing the requirement can reapply at any time and will be assessed again from scratch.
An Interim Rule, Still Open for Comment
The regulation carries an unusual label: an interim final rule with comment period. That means it is already in force as a rule — it took effect July 31, 2026 — while CMS keeps taking public comment under docket CMS-2026-2047 before the operational deadline arrives. States, advocacy groups and Medicaid enrollees can still weigh in, and provisions could shift based on that record before the January 1, 2027 start date.
For households currently covered by Medicaid in one of the affected states, the practical read is straightforward: nothing about eligibility changes today, but the fine print — including which counties will qualify for a high-unemployment hardship exception — could still move before enforcement begins. CMS’s own fact sheet is explicit that the requirement it describes does not start until 2027, and the 30-day notice window is the last step before anyone actually loses coverage once it does.
This article was produced with AI assistance and reviewed by a human editor. Figures are linked to their primary sources; where a claim could not be verified from the public record, we say so.
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