What Counts as Work or Community Engagement
The 80 hours can come from more than a regular job. Here is what the CMS rule counts, with everyday examples.
Work
The CMS rule defines work broadly. It includes:
- Paid work: full-time, part-time, temporary, or day labor
- Self-employment and gig work: you do not need to be an employee. Running a business, freelancing, and independent contractor work (such as ride-share, delivery, cleaning, or hair braiding) count.
- Work for goods or services ("in-kind"): for example, managing a building in exchange for rent
- Unpaid work: such as an unpaid internship or a trial work period when applying for a job. Unlike community service, this can benefit a private business.
Community service
Unpaid service for the community through a structured program run by a public agency or nonprofit, including 501(c)(3) charities. The organization must oversee the work and keep track of the type of activity, dates, hours, and a contact person who can confirm them. Court-ordered community service counts. Partisan political activity does not.
Examples: food banks, shelters, school or library volunteer programs, faith-based charity programs, and park cleanups organized by a city or nonprofit.
Work programs
- Job training under the Workforce Innovation and Opportunity Act (WIOA), often through American Job Centers
- Trade Adjustment Assistance training (Trade Act)
- State employment and training programs, including SNAP Employment and Training (SNAP E&T)
- Employment and training programs for veterans run by the Department of Labor or the VA
- SNAP workforce partnerships
Job search: supervised job search counts only as a smaller part of a work program (less than half its hours). Unemployment insurance job search counts if it is done in a way that matches a work program's requirements.
School
- Colleges and universities
- Career and technical education programs
- High school
- A state-approved high school equivalency (GED/HiSET) program, if you don't have a diploma
Half-time enrollment or more counts by itself for the month. Less than half-time counts as hours: each weekly credit hour equals 3 hours a week. See the hours calculator.
What about caregiving?
Caregiving is handled as an exemption, not as hours. If you care for a child 13 or younger, or for a person with a disability, you are excluded from the requirement entirely. That includes a relative you help regularly even if you live apart, or a non-relative you give 80 or more hours of care a month.
Examples
| Activity | Counts? |
|---|---|
| DoorDash or Uber driving | Yes, as work (self-employed) |
| Unpaid internship at a private office | Yes, as unpaid work |
| Volunteering at a nonprofit food pantry that logs hours | Yes, as community service |
| Helping a neighbor informally | Not as community service. If the neighbor has a disability and you give 80+ hours of care a month, you may be exempt as a family caregiver. |
| Campaigning for a political candidate | No (partisan activity) |
| Applying for jobs on your own | Not by itself; only as part of an approved work program |
| GED classes | Yes, as school |
| Raising your own 10-year-old | You are exempt, so hours aren't needed |
Frequently asked questions
Does gig work count for Medicaid work requirements?
Yes. The CMS rule says self-employment and independent contractor work count as work. Keep app summaries, payout statements, or logs that show your hours or earnings.
Does volunteering count?
Yes, if it is through a public agency or nonprofit that oversees the work and tracks your hours. Informal help to friends or neighbors does not count as community service.
Does caring for a family member count as work?
It counts as an exemption rather than hours. Parents and caregivers of a child 13 or younger, and family caregivers of a person with a disability, do not have to meet the requirement.
Does looking for a job count?
Only as a smaller part of an approved work program, such as WIOA or SNAP E&T. Job searching on your own does not count by itself.
Does an unpaid internship count?
Yes. The CMS rule counts unpaid work, including internships and trial work periods, even at a private business.
Do online classes count?
Yes, if the program is a college, career and technical program, high school, or high school equivalency program. Your school decides whether you are half-time.