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.

Updated · Based on official sources listed below

Work

The CMS rule defines work broadly. It includes:

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 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

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

ActivityCounts?
DoorDash or Uber drivingYes, as work (self-employed)
Unpaid internship at a private officeYes, as unpaid work
Volunteering at a nonprofit food pantry that logs hoursYes, as community service
Helping a neighbor informallyNot 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 candidateNo (partisan activity)
Applying for jobs on your ownNot by itself; only as part of an approved work program
GED classesYes, as school
Raising your own 10-year-oldYou 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.

Sources

  1. Public Law 119-21 (H.R. 1), sec. 71119: community engagement requirement (GovInfo)
  2. CMS interim final rule, Medicaid community engagement requirement, 91 FR 33348 (June 3, 2026)
  3. CMS-2454-IFC, official PDF (GovInfo)