Key takeaways:
Medicaid work requirements, for adults ages 19 to 64 among the Medicaid expansion population in 40 states and Washington, D.C., are scheduled to begin January 1, 2027. Georgia has had Medicaid work requirements since 2023 and is the only state with this mandate at the time of publication.
To maintain Medicaid coverage, an “able-bodied” applicant or enrollee in the expansion population, who doesn’t qualify for an exemption, must complete at least 80 hours a month of combined work, community service, “work program” participation, and educational enrollment — or half-time educational enrollment alone.
Health policy researchers and Congressional Budget Office analysts expect Medicaid work requirements to result in more than 5 million people losing insurance by 2034 and little if any increase in employment.
Medicaid is the public health insurance program that covers adults and children from low-income households as well as people of all ages with disabilities. There are 56 Medicaid programs that are funded in part by the federal government. Each state, plus five U.S. territories, and Washington, D.C., has its own Medicaid program.
Through the Affordable Care Act, 40 states and Washington, D.C., have expanded Medicaid coverage. For these states, Medicaid includes people with higher incomes than previously qualified. Typically, expansion adults have incomes up to 138% of the federal poverty level (FPL).
The One Big Beautiful Bill Act of 2025 sets new work requirements for adults ages 19 to 64 living in states that have expanded Medicaid. The mandate is scheduled to begin by January 1, 2027. (States can start the work requirements sooner.) The secretary of the U.S. Department of Health and Human Services can give states until December 31, 2028, to begin.
Arkansas became the first state with Medicaid work requirements in 2018. By the time the short-lived program was shut down by a federal judge in 2019, about 18,000 people lost coverage (which was later restored). Nonexpansion states can also pursue Medicaid work requirements. Georgia has not expanded Medicaid, but it has had Medicaid work requirements since 2023. It is the only state with a waiver for this purpose.
Nearly 77.6 million people are covered by Medicaid and the Children’s Health Insurance Program (CHIP) as of July 2025. More than 40 million (52%) were adults. As of December 2024, at least 20 million adults covered by Medicaid are in the expansion group.
A 2023 KFF analysis of Medicaid-covered adults, ages 19 to 64, found that most were working. And in a survey of health policy scholars, the majority said they don’t think work requirements will boost employment.
What are the new Medicaid work requirements in the One Big Beautiful Bill Act?
An “able-bodied” Medicaid enrollee subject to the Medicaid work requirements must complete one of the following every month:
80 hours of work, community service, and/or “work program” participation
At least half-time educational enrollment
80 hours of combined work, community service, “work program” participation, and educational enrollment
States can also allow hardship exemptions. These include people who have been:
Recently in the hospital
Living in a county with a federally declared disaster or emergency
Living in a county with a high unemployment rate
Can’t pay for medical care? You may qualify for help paying for medications and affording healthcare through patient assistance programs, free prescription programs, and community clinics.
How to pay for medications if you lose Medicaid. Ask your prescriber for additional refills before your coverage ends, switch to generics, and use GoodRx to help you save on prescriptions.
Does Medicaid offer dental benefits? Medicaid programs are required to provide comprehensive dental coverage for children, but adult benefits are optional.
Your work status may be verified upon enrollment. In some states, this mandate will require up to 3 months of work when you apply for Medicaid. Your compliance will be checked during annual reenrollment and may be verified monthly.
Who is exempt from the new work requirements?
There are excluded individuals and mandatory exemptions. People who won’t need to meet the Medicaid work requirements are:
Parents, guardians, and caregivers for children age 13 and younger or disabled individuals
Pregnant women or individuals receiving postpartum Medicaid coverage
Disabled veterans
Current or former foster youth under age 26
Medically frail individuals or those with special medical needs
American Indians, Alaska Natives, California Indians
Participating in substance abuse treatment or rehabilitation programs
Participants in work requirements for other benefits, such as Supplemental Nutrition Assistance Program (SNAP, or food stamps) or Temporary Assistance for Needy Families (TANF)
Individuals who are incarcerated or who have been in the past 3 months
How do work requirements differ by state?
Georgia is the only state with an approved Medicaid work requirement waiver. Seven states have requests pending with the Centers for Medicare & Medicaid Services (CMS).
KFF is maintaining a Medicaid work requirement tracker, with a map and a chart. The tracker has information about:
States with approved work requirement waivers
States with pending waiver requests that have been submitted to CMS for review
Legislative action in progress or approved in states where Medicaid waivers must be affirmed by lawmakers before submission to CMS
This chart has details:
Medicaid work requirements approved and pending by state
State | Medicaid work requirements |
Georgia (approved) | Pathways to Coverage, started in July 2023, is the only Medicaid work requirement program in effect. Access to health coverage for low-income adults previously ineligible for Medicaid fell far short of goals because of failed technology and other snags limiting reporting of work, school, or volunteer hours. The program didn’t boost employment in its first 18 months. A waiver extension through December 31, 2026, applies to people ages 19 to 64. It exempts parents of children younger than age 6 from work mandates. |
Arizona (pending) | This waiver applies to expansion adults ages 19 to 55 who don’t qualify for an exemption. It includes a 5-year lifetime limit on Medicaid coverage for people subject to work requirements. |
Arkansas (pending) | The Pathways to Prosperity waiver applies to expansion adults ages 19 to 64 with no exemptions. Individuals who fail to comply or “refuse to cooperate” would have their coverage dropped until the end of the calendar year. |
Iowa (pending) | The Iowa Health and Wellness Plan waiver applies to expansion adults ages 19 to 64 who don’t qualify for an exemption. New applicants wouldn’t have to meet work requirements for initial Medicaid eligibility. |
Montana (pending) | The waiver would apply to expansion adults ages 19 to 64 who don’t qualify for an exemption. It also introduces Medicaid premiums for these enrollees. |
Ohio (pending) | This waiver provides Medicaid expansion coverage at application and renewal to adults who are working (or have household earned income); are older than 55; are enrolled in school or job training; are participating in addiction treatment; have intensive physical healthcare needs; or have a serious mental illness. |
South Carolina (pending) | The Palmetto Pathways to Independence waiver extends Medicaid coverage with work requirements for up to 11,400 parents and caregivers ages 19 to 64 with incomes at 67% to 100% of the FPL; about 50,000 others who would be eligible can join a wait list for coverage. South Carolina has not expanded Medicaid. |
Utah (pending) | A waiver is pending. But the state doesn’t expect to implement work requirements before the federal law takes effect. |
Source: KFF (as of October 7, 2025)
How often will the state verify your work hours?
Your compliance with work requirements may be verified when you sign up for Medicaid coverage. The application process could include a look-back period of 1 to 3 months. Work requirements will also be checked during annual renewal and at least every 6 months. Some states may verify work requirements monthly.
How Medicaid work requirements may affect your health insurance coverage
Congressional Budget Office analysts and health policy researchers have concluded that work requirements will lead to widespread insurance coverage losses for more than 5 million people by 2034. This will reduce access to care, including prescription medications. And in the survey of health policy scholars mentioned earlier, the majority believed most people subject to Medicaid work requirements would lose coverage due to challenges reporting hours — even if they were employed, volunteering, participating in job training, and/or going to school.
During the brief Arkansas program started in 2018, more than 18,000 people lost their Medicaid. Coverage was restored, but the interruption left many with poorer health. Many continued with necessary care they couldn’t afford, which resulted in medical debt.
The bottom line
Medicaid work requirements for people ages 19 to 64 among the Medicaid expansion population in 40 states and Washington, D.C., are scheduled to start by January 1, 2027. Georgia, which has not expanded Medicaid, started a similar mandate in 2023. It is the only state with Medicaid work requirements in effect. Under the One Big Beautiful Bill Act of 2025, Medicaid enrollees in the expansion population who don’t qualify for an exemption must complete at least 80 hours monthly of combined work, community service, “work program” participation, and educational enrollment — or half-time educational enrollment — to keep their coverage. Health policy analysts and scholars predict nationwide Medicaid work requirements will cause insurance coverage losses for more than 5 million people by 2034 and won’t increase employment appreciably.
Why trust our experts?
References
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Bell, C., et al. (2025). A look at the potential impact of the high unemployment hardship exception to Medicaid work requirements. KFF.
Coker, M., et al. (2025). Georgia’s Medicaid work requirement program spent twice as much on administrative costs as on health care, GAO says. ProPublica.
Congress.gov. (2025). H.R.1 - One Big Beautiful Bill Act. 119th Congress.
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Hinton, E., et al. (2025). A closer look at the work requirement provisions in the 2025 federal budget reconciliation law. KFF.
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KFF. (2025). Do I have to renew Medicaid coverage every year?
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