Look-Back Periods and Reporting
You don't have to meet the 80-hour rule every month. Your state looks back over a set period and checks whether you met it in enough months. Here is how that works.
When you apply
New applicants must show they met the requirement in the 1 to 3 months in a row just before the month they apply. Each state picks the number. Most states chose 1 month, so if you apply in March, they look at February. Indiana uses 3 months.
When you renew
If you are already enrolled, you must show you met the rule in at least one month (more if your state chooses) between your last eligibility decision and your next renewal. The months do not need to be in a row. Current members are first checked at their first renewal on or after their state's start date.
States may also check more often than at renewal. Indiana reviews compliance every quarter, and New Hampshire's state law calls for checks at least every quarter.
Renewals every 6 months
A separate part of the same law (section 71107) makes expansion adults renew every 6 months instead of every 12, starting with renewals scheduled on or after January 1, 2027. That means the work requirement is checked about twice a year in most states.
Your state checks its records first
Before asking you for anything, your state must check all the reliable information it can get, including payroll data, other state programs like SNAP and TANF, federal data, and your medical claims from the past 12 months. Only if that doesn't confirm you meet the rule, or are exempt, can it ask you for more. Many states tell members not to send documents unless asked.
Proof: 2027 versus 2028
- Before January 1, 2028: states may accept your own statement or other information when records don't settle it. Several states, including Kentucky, Louisiana, New Jersey, Oregon, Vermont, and Virginia, have said they will accept self-attestation for some things in 2027.
- From January 1, 2028: states must require documents whenever they are reasonably available. If no documents exist, the state must accept other information and cannot deny you only because you lack paperwork that doesn't exist.
New Hampshire is stricter: its state law requires documents and does not allow self-attestation.
Records to keep every month
- Work: pay stubs, timesheets, a letter from your employer, or gig app earnings and trip logs
- Self-employment: invoices, receipts, a simple log of hours and income
- Community service: a signed note from the organization with dates and hours (the organization must track them)
- Work programs: attendance records from the program
- School: enrollment verification showing half-time or the number of credits
- Exemptions: a doctor's letter, VA rating letter, tribal document, or SNAP or TANF notice
Notices you should expect
States must tell affected members about the rule before it starts, by regular mail plus at least one other way (text, phone, email, or your online account), and again at application and renewal. Most states sent first notices between July and September 2026.
Look-back by state
| State | Months checked |
|---|---|
| Alaska | Alaska has not published how many months it will check. |
| Arizona | At your first renewal in 2027, AHCCCS will check the information it already has for your income, activities, or an exemption. |
| Arkansas | DHS has not published a set number of months; it checks status using its own data and follows up by phone. |
| California | You must show you met the rule at your next renewal after January 1, 2027. DHCS will try first to confirm this with medical claims, work, school, or volunteer data it already has. |
| Colorado | New applicants must show they met the rule in the calendar month before they apply. At renewal, you need at least one month since your last renewal. |
| Connecticut | DSS has not published a set number of months. It checks when you apply, renew, or report a change, and it may ask for proof. |
| Delaware | Not yet announced. |
| District of Columbia | Not yet announced. DHCF says more online information is coming. |
| Georgia | Applicants must meet the rule in the month just before they apply. The Pathways page says members keep meeting it during enrollment and are checked at the yearly renewal. |
| Hawaii | AlohaCare, a Med-QUEST health plan, says renewing members must meet the rule in at least 1 of the 6 months before renewal, and new applicants in the month before they apply. |
| Idaho | Applicants: 3 months of qualifying activity before approval. Members: at least 3 months of compliance in each 6-month certification period. |
| Illinois | At renewal, HFS may ask you to prove you met the rule in any month since your last renewal. |
| Indiana | Applicants in January 2027 must show they met the rule in October, November, and December 2026. Current members: any 3 months since their last redetermination. FSSA also reviews compliance quarterly. |
| Iowa | Applicants: the month before the month you apply. Current members: at least two months since your last Medicaid review. |
| Kentucky | The state's web page says current members must show they met the rule for at least 3 of the 6 months before renewal. A state letter describes it as any 3 months between renewals. Ask the state which applies to you. |
| Louisiana | LDH has not published a set number of months on its main page. Read your renewal packet for the months being checked. |
| Maine | At least one calendar month since your last renewal (DHHS partner materials). |
| Maryland | When you renew in 2027, you must show you met the rule for at least one month. |
| Massachusetts | New applicants must meet the requirement in the month before they apply. Current members are checked at their first 2027 renewal. |
| Michigan | At least one month between renewals. |
| Minnesota | One qualifying month since your last Medical Assistance renewal (for example 80 hours, $580 in income, or half-time school in one month). |
| Missouri | One qualifying month. For applicants, the month before applying. For members, any one month since the last renewal. Hours do not carry over from month to month. |
| Montana | Applicants: the month before applying. At redetermination: 3 months (not necessarily in a row) of the review period. |
| Nebraska | Applicants must meet the rule in the month before they apply. Current members are checked at renewal. |
| Nevada | At least one month of the review period before your 2027 renewal. Applicants must meet it to enroll. |
| New Hampshire | Applicants: the month before applying. Members: at redetermination, and at least quarterly in between, under state law. |
| New Jersey | At least one month since your last renewal. |
| New Mexico | Applicants: the month before applying. Members: at renewal. |
| New York | Any one month since your last renewal. |
| North Carolina | At renewal: 3 of the 6 months before recertification. If you reapply after losing coverage: 3 months in a row. |
| North Dakota | HHS has not published a set number of months on its main page; your notice will list the months checked. |
| Ohio | At least one month since your last application or renewal. |
| Oklahoma | OHCA checks at renewal using information it already has. |
| Oregon | Applicants: the month before the application month. At renewal: at least one month during the six months before your renewal date. |
| Pennsylvania | You report at application and renewal. Your renewal notice tells you the months being checked. |
| Rhode Island | One month out of every six. |
| South Dakota | At application on or after January 1, 2027, and at your first 2027 renewal. |
| Utah | Checked at each review, every 6 months. |
| Vermont | First 2027 renewal: DVHA looks back 12 months using information it already has. After that, a 6-month look-back at each 6-month renewal. |
| Virginia | Checked at renewal. DMAS says the information you put on your application or renewal will usually be all you need. |
| Washington | Applicants: the month before the application month. At renewal: any one month during the certification period. |
| West Virginia | Applicants: the month before applying. Members: at renewal. |
| Wisconsin | Applicants: the calendar month before applying (or expected monthly income of at least $580). Members: any one month of the previous certification period. DHS checks at application and renewal, not every month. |
Frequently asked questions
What is the look-back period for the Medicaid work requirement?
At application, 1 to 3 months in a row right before you apply (the state chooses). At renewal, at least one month since your last renewal, and possibly more depending on your state.
How often will I have to prove I'm working?
At application and at each renewal, which will be every 6 months for most expansion adults starting in 2027. Some states, such as Indiana, check more often.
Do I need to send proof every month?
Usually not. Most states check their own data and ask only if they cannot confirm. Keep records every month anyway so you can answer quickly if asked.
Can I just tell the state I worked?
In 2027, many states will accept your statement for some things when their data does not settle it. From January 1, 2028, states must ask for documents when they are reasonably available.
When will current members first be checked?
At the first renewal on or after the state's start date. In many states that means renewals due in March 2027 or later. Your renewal notice will say which months are being checked.
Can a managed care plan decide if I complied?
No. Health plans may send reminders and help you, but federal law bars them from deciding compliance. Only the state agency (or a contractor with no financial ties to plans) can.