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Requirements

Who It Applies To

Work requirements Non-pregnant adults aged 19 to 64 in the Medicaid expansion group or certain section 1115 demonstrations, as long as they aren't enrolled in or entitled to Medicare. CMS puts the number of affected states at 43, plus D.C.

Six-month renewals Adults covered through the expansion, whether under the state plan or a waiver for the whole expansion group. Children, parents and pregnant or postpartum people stay on 12-month renewals. American Indian and Alaska Native enrollees do too.

What Members Must Show

Qualifying activities A member needs 80 hours a month of work, community service or a work program, or half-time enrollment in school. Hours from different activities can be added together.

Income instead of hours Earning at least the federal minimum wage times 80 hours also counts. In 2026, that's $580 a month.

When it's checked Applicants have to show one to three months of compliance before the month they apply, and the state picks the number. Enrolled members must meet the requirement in at least one month of every eligibility period, and states are free to verify more frequently.

Who Is Exempt

The interim final rule requires states to exclude these groups:

  • Former Foster Youth - who turned 18 on or after January 1, 2023.
  • American Indians And Alaska Natives - regardless of income or activity.
  • Parents And Caregivers - of a child aged 13 or under, or of a person with a disability.
  • Disabled Veterans - with a total disability rating from the VA.
  • Medically Frail Individuals - including people with serious mental illness, substance use disorder, or physical, intellectual or developmental disabilities.
  • Members Already Meeting Other Program Rules - people meeting TANF work requirements, or SNAP household members not subject to SNAP work rules.
  • People In Treatment - in a drug or alcohol treatment and rehabilitation program.
  • Incarcerated Individuals - in a public institution.
  • Pregnant And Postpartum Individuals - through the end of the postpartum period.

A federal court struck down part of the medically frail definition on October 29, 2026. Part 2 covers what changed.

States may also grant short-term hardship exceptions. They cover inpatient care, federally declared disasters, travel for medical care and counties where unemployment is at least 8% or 1.5 times the national rate, whichever is lower.