On July 4, 2025, the federal government passed a new law – the 2025 Budget Reconciliation Bill (H.R. 1) – that adds work requirements for some adults on Medicaid. Below, you will find a summary of how these changes are affecting beneficiaries and provide recommendations to open up opportunities and increase access for families to meet the work requirements to remain eligible for Medicaid.
If you’re between the ages of 19 and 64 and get Medicaid through the Affordable Care Act (ACA) expansion or a waiver program, you may now need to meet certain work or activity requirements to keep your coverage. Under this new law, starting no later than December 31, 2026, people will have to show that they are working, going to school, in job training, or doing community service for at least 80 hours per month to stay eligible for Medicaid. This applies to people in the Medicaid expansion group—those whose income falls between the traditional Medicaid income limit and up to 138% of the Federal Poverty Level (Center for Health Care Strategies, 2025).
However, this law includes a number of exemptions to protect people who may be unable to work or who already meet similar requirements under other programs. Here’s a detailed list of who is exempt:
- Foster youth and former foster youth under age 26
- American Indians and Alaska Natives who are eligible for services through the Indian Health Service (IHS)
- Caregivers, including parents or family members who care for:
- A child aged 13 or younger
- Or a disabled individual
- Disabled veterans rated as totally disabled under federal law
- Medically frail individuals, including people who:
- Are blind or disabled
- Have serious or complex medical conditions
- Have intellectual, developmental, or physical disabilities
- Have a substance use disorder or a disabling mental illness
- People already meeting work requirements through programs like:
- TANF (Temporary Assistance for Needy Families)
- SNAP (Supplemental Nutrition Assistance Program)
- Individuals in an approved substance use disorder (SUD) treatment program, if the program meets federal guidelines and is run by a nonprofit or public mental health center
- People who are currently incarcerated or who were released within the past three months
- Pregnant individuals, or those within the 12-month postpartum Medicaid coverage period
- People facing short-term hardships, including those who:
- Are receiving inpatient care (in hospitals, nursing homes, or psychiatric facilities)
- Live in areas affected by natural disasters
- Reside in counties with high unemployment rates
- Need to travel outside their home area for extended medical care, or care for a dependent who does
If you’re not exempt, you’ll need to complete and report 80 hours of approved activity each month, or you risk losing coverage. States will be required to notify you if you’re out of compliance, and you’ll have 30 days to fix the issue before being disenrolled. These notices will be sent by mail and at least one other method like text or email. States will also check whether you’ve met the requirements using data sources like payroll records and Medicaid usage (Hinton, Diana, & Rudowitz, 2025).
The Center for Health Care Strategies (CHCS) has provided recommendations to expand access for families needing to meet the work requirements. CHCS suggests that Medicaid agencies are encouraged to partner with existing workforce systems, such as labor departments, local governments, and community organizations, to streamline access to employment supports, improve coordination on exemptions, and reduce administrative burdens. Drawing from lessons in TANF and other workforce programs, states are advised to prioritize subsidized employment, job training, and voluntary, individualized services, which have shown modest but consistent gains in employment and earnings.
We must recognize that these work requirements being implemented create more barriers for families, particularly those historically marginalized by systemic inequities, deserve more than just access to services; they deserve free, accessible pathways to education, skill development, and long-term economic security.
Resources to Help Reach Work Requirement of 80 hours a month
1. SNAP Employment & Training (SNAP E&T)
- The program is completely voluntary and participants receive career coaching, job readiness, training, reimbursements for transportation and childcare, and access to loaner tech tools (like laptops) for eligible participants. Participation can count toward your monthly hours (SNAP E&T).
2. Job Search & Training Programs
- Local community service agencies, workforce centers, and nonprofits may offer job-search support, training, or placement assistance.
- Here are some provided by Catholic Charities DC.
3. Community Service & Volunteering
- Participating in structured community service or volunteer opportunities can also satisfy hour requirements.
- Here are some volunteer sites.
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