Medicaid Work Requirements for Gig and Seasonal Workers
You don't need a regular job. Gig work, self-employment, and seasonal work all count, and seasonal workers can use a 6-month income average.
Short answer: Gig and self-employed work counts as work for the 80-hour rule, and your earnings count toward the $580 monthly income test. If you are a seasonal worker, such as a farm worker or holiday retail worker, you meet the rule in a month if your average monthly income over the past 6 months is at least $580. The rule starts January 1, 2027, or earlier in a few states.
Gig and self-employed work
The CMS rule defines work as work for money, work for goods or services, or unpaid work (42 CFR 435.552(b)). CMS says you do not have to be an employee: self-employment and independent contractor work, like ride-share, delivery, cleaning, or freelancing, count. You meet the rule with any of these:
- 80 hours of work in the month. Hours from different apps and jobs add up, and you can add volunteering, a work program, or part-time school.
- $580 or more in monthly income (80 × the $7.25 federal minimum wage). Medicaid counts household income using its usual MAGI rules, which for self-employment generally means earnings after business expenses.
Pay counted as hours: if you earn less than $580 and your state has no record of your hours, the CMS rule lets the state divide your income by $7.25 to estimate hours. States don't have to do this, so ask yours.
Seasonal workers
The law adds a special test (sec. 1902(xx)(2)(G)): a seasonal worker meets the rule for a month if their average monthly income over the preceding 6 months is at least $580. It uses the federal tax code definition of a seasonal worker (26 U.S.C. 45R(d)(5)(B)): someone who works on a seasonal basis, such as farm work done only at certain times of year, and retail workers hired only for the holiday season. As with regular income, the CMS rule uses household MAGI income.
Example: a farm worker who earned $4,200 over the last 6 months has a $700 average, so this month counts even if they earned little this month.
What CMS has not defined
CMS did not list which gig jobs are "seasonal," and it did not set one method for counting gig hours. Keep both hours and earnings records, and ask your state how it counts them.
What proof is usually needed
- App earnings summaries or payout statements
- A simple log of dates and hours worked, signed by you
- 1099 forms, invoices, receipts, or bank deposits
- For seasonal work, pay records for each of the last 6 months
What to do next
- Add up your month with the 80-hour calculator.
- Download your app earnings summaries each month and keep them.
- Use the free checker to see if the rule applies to you and which exemptions may fit.
- See which months your state checks and what records to keep.
- Got a notice? You have at least 30 days to answer, and you can ask for a fair hearing. See what to do about a notice.
Frequently asked questions
Does DoorDash or Uber count for Medicaid work requirements?
Yes. App-based delivery and ride-share work count as self-employed work. Either 80 hours or $580 in monthly income meets the rule.
Can I add hours from different apps?
Yes. All work hours add up, and you can also add volunteer, job training, and part-time school hours.
Who counts as a seasonal worker?
The law uses the federal tax code definition: someone who works on a seasonal basis, such as farm workers, and retail workers hired only for the holiday season.
I had a slow month. What can I do?
You usually only need to meet the rule in one month (or a few, depending on your state) of the period your state checks. You can also add volunteering or training hours. If you are a seasonal worker, your 6-month average may already cover it.
Sources
- Public Law 119-21 (H.R. 1), sec. 71119: community engagement requirement (GovInfo)
- CMS interim final rule, Medicaid community engagement requirement, 91 FR 33348 (June 3, 2026)
- CMS-2454-IFC, official PDF (GovInfo)
- 26 U.S.C. 45R(d)(5)(B): definition of seasonal worker (Cornell LII)
- U.S. Department of Labor: federal minimum wage