Medicaid work requirements start January 1, 2027: what to do now

Key dates

Your checklist

Now (November 2026)

1. Make sure your state can reach you. Update your mailing address, phone and email with your Medicaid agency, and set up your online account if your state has one. Notices go by mail plus at least one other way, such as text, email or your online account. A missed letter is one of the most common ways people lose coverage.
2. Find your renewal month. It is on your last approval or renewal notice and usually in your online account. That is when you will most likely be checked.
3. Check whether you are exempt. Use the checker, read the full exemptions list, or find your situation on who is affected. Parents and caregivers of a child 13 or younger, pregnant and postpartum people, American Indians and Alaska Natives, many veterans, and people with serious health conditions are among those exempt.
4. If you have a health condition, get it on record. Your state looks at your Medicaid claims from the past 12 months to find medically frail members. If you have a condition you have not seen a provider about this year, make an appointment and ask that the diagnosis be written down.
5. If you are not exempt, add up a normal month. Use the hours calculator. You need 80 hours of work, volunteering, job training or school, a mix of those, half-time school, or at least $580 in monthly income. See what counts as work.
6. Start keeping records every month, even if you think the state already has your information. Keep them in one folder or photo album on your phone.

December 2026

• December is the month checked if you apply in January 2027 in most states. Indiana checks October, November and December 2026 for January applicants, and Idaho looks at 3 months.
• Holiday and seasonal work counts. If your income is at least $580 in the month, that month qualifies no matter how many hours you worked.
• If you need hours, ask a nonprofit or public agency about volunteering. It must track your dates and hours. Job training through an American Job Center (WIOA) or SNAP Employment and Training also counts.
• In Iowa, the rule already applies to applications from December 1, 2026, so November counts for December applicants.

January to March 2027

• Open every letter from your Medicaid agency or health plan. Your renewal packet will say which months are being checked.
• Return your renewal form by its deadline, even if you think you are exempt. Answer the questions about work, school and exemptions.
• Send documents only if your state asks for them. Many states will try to confirm you from their own records first.
• If you get a notice saying the state could not confirm you, follow the steps in the next section right away.

Documents to gather

You may never need these, but having them ready makes a notice easy to answer.

How and when your state will check

• Data checks come first. Before asking you for anything, your state must look at the reliable information it can get: payroll and wage data, SNAP and TANF records, other federal data, and your medical claims from the past 12 months. This is often called an ex parte check. Many people will be confirmed or exempted without doing anything.
• At application: your state checks 1 to 3 months in a row right before the month you apply. Each state picks the number, and most chose 1.
• At renewal: you must show at least 1 month (more if your state chooses) between your last eligibility decision and your renewal. The months do not have to be in a row. Idaho, Indiana, Kentucky, Montana and North Carolina ask for 3 months, and Iowa asks for 2. See look-back periods by state.
• How often: states may check more often than at renewal. Indiana reviews every quarter, and New Hampshire law calls for quarterly checks with documents.
• Proof in 2027: when records do not settle it, many states will accept your own statement for some things until January 1, 2028. New Hampshire does not.

When current members are first checked, by state

"Start" is when the rule begins in the state. Current members are checked at their first renewal on or after it. Your state's guide has contacts and how to report.

What to do if you get a notice

1. Find the deadline and the months. You have at least 30 days from when you receive the notice (counted as 5 days after the date printed on it). Some states give 35 days. You only need to cover the months the notice names.
2. Answer the fastest way the notice allows, usually online. Send proof of hours, income, school or an exemption. Keep a copy and write down the date you sent it.
3. If you don't have papers, explain why and give what you can. A state cannot deny you only because papers that don't exist are missing.
4. Your coverage continues during the 30 days. Before ending it, the state must check whether you qualify for Medicaid another way, and send advance written notice.
5. If coverage is ending, you can appeal. Ask for a fair hearing before the end date to keep your benefits during the appeal. You can also reapply at any time; there is no waiting period.

Full details: what happens if you don't meet the requirement.

The October 29, 2026 court ruling and the medically frail exemption

In Massachusetts v. Oz, a federal court in Massachusetts struck down the CMS rule's extra requirement that a health condition must "significantly impair" your ability to meet the work rule. If you are in any one of the five medically frail groups in the law (blind or disabled; a substance use disorder; a disabling mental disorder; a physical, intellectual or developmental disability that significantly limits daily activities; or a serious or complex medical condition), you count as medically frail.

• What did not change: the January 1, 2027 start date, the 12-month claims check, and the rule that signed statements become limited from 2028.
• States that sued got six months of relief from federal enforcement of their medically frail decisions while they update their systems.
• What to do: if you were told before October 29 that your condition did not "significantly impair" you, ask your state to look again. CMS can appeal, and as of October 31, 2026 we had not seen an appeal or new CMS guidance.

More on the exemptions page and for people with disabilities.

States that start differently

• Nebraska: started May 1, 2026, the first state. Current members are checked at renewal.
• Montana: started July 1, 2026. Since October 2026, people who do not meet the rule can be denied or disenrolled.
• Arkansas: soft start on July 1, 2026 with status notices but no penalties. Enforcement begins January 1, 2027.
• Iowa: new applicants from December 1, 2026; current members at renewals from February 2027.
• Georgia: Georgia did not expand Medicaid, but Pathways to Coverage already had its own work rule. On January 1, 2027, Pathways switches to the federal rules, and current members are affected at their 2027 renewal. CMS extended the Pathways waiver through December 31, 2026.
• Wisconsin: applies to BadgerCare Plus adults without dependent children, with renewals checked from March 2027.
• Stricter states: Idaho and Indiana use 3-month look-backs, and New Hampshire requires documents and quarterly checks under state law.

Can a state delay?

Yes, but only with CMS approval. A state showing a "good faith effort" can get an exemption of up to 6 months at first, with possible extensions, and none can last past December 31, 2028. Alaska has said it asked for more time, and North Carolina told CMS it was unlikely to fully meet the new rule's requirements by January 1, 2027. As of October 31, 2026 we had not found any approved delay for any state. Until your state says otherwise, plan for January 1, 2027.