Who Has to Meet Medicaid Work Requirements?

Pick your situation for a plain answer, the exact rule, what proof you may need, and what to do next.

Updated · Based on official sources listed below · How we research

The rule covers adults 19 to 64 who get Medicaid through the adult expansion group (plus Georgia Pathways and Wisconsin BadgerCare Plus adults without children at home). It starts January 1, 2027, or earlier in a few states. Many people in that group are exempt.

GroupDoes the rule apply?In short
Parents and caregiversExemptParent, guardian or caretaker of a child 13 or younger, or caregiver of a person with a disability.
StudentsSchool countsHalf-time school meets the rule; less than half-time adds hours.
Pregnant and postpartumExemptPregnant, or in Medicaid postpartum coverage.
Disability and medically frailExemptMedically frail: disability, substance use disorder, disabling mental disorder, or a serious or complex condition.
VeteransOnly 100% / TDIUExempt with a total VA disability rating or TDIU; other veterans must meet the rule unless another exemption fits.
American Indians and Alaska NativesExemptIndian, Urban Indian, California Indian, or eligible for Indian Health Service care.
Former foster youthExempt to 26In foster care at 18 and on Medicaid then; exempt until age 26.
Substance use treatmentExemptIn a drug or alcohol treatment program, or a substance use disorder (unless 5+ years in recovery).
After jail or prisonExempt for 3 monthsIn jail or prison, and about 3 months after release.
Age 50 to 64Covered until 65No age exemption before 65; Medicare, income, and health exemptions often help.
Gig and seasonal workersWork countsGig and self-employed hours count; seasonal workers can average income over 6 months.
High-unemployment areasOnly if approvedExcused only where your state asks and CMS approves the county.
SNAP and TANFOften exemptIn a SNAP household and subject to a SNAP work rule, or meeting TANF work rules.

Not listed here? Being homeless, Native Hawaiian, or caring for a child 14 or older without a disability is not an exemption by itself. Check the full exemptions list or use the checker.

Your state checks first. Before asking you for anything, your state must check its own records, such as claims, SNAP files, and tribal status. Many people will be exempted without doing anything.

Frequently asked questions

Who is exempt from Medicaid work requirements?

People who are pregnant or postpartum, parents and caregivers of a child 13 or younger or a person with a disability, American Indians and Alaska Natives, veterans with a total VA disability rating, former foster youth under 26, people who are medically frail, people in drug or alcohol treatment, people subject to SNAP work rules or meeting TANF work rules, and people in or recently released from jail or prison.

Who is not covered by the rule at all?

People under 19 or 65 and older, people with Medicare, and people who get Medicaid through another group, such as disability, SSI, parent and caretaker, or pregnancy coverage. The rule also does not apply in states that did not expand Medicaid, except Georgia and Wisconsin.

Are homeless people exempt from Medicaid work requirements?

Not because of homelessness alone. People experiencing homelessness may still qualify another way, for example as medically frail or by being in a SNAP household subject to SNAP work rules. The CMS rule has no separate homelessness exemption.

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 fact sheet: community engagement interim final rule (June 1, 2026)
  4. Massachusetts v. Oz, No. 1:26-cv-12962-RGS (D. Mass.), memorandum and order (Oct. 29, 2026)