Medicaid Work Requirement State Tracker: Enforcement Dates, Lookback Periods & Disenrollment Data
A continuously verified dataset of state implementation of the OBBBA community-engagement requirement: which states are enforcing, when each starts, how often enrollees must re-prove compliance, and how far back states look. 3 states are actively enforcing as of this update. Built for journalists, researchers, and advocates — cite it freely.
Quick answer: 3 states are enforcing the 80-hour rule right now — Nebraska (started May 1, 2026), Montana (July 1, 2026, with no disenrollments before October 2026), and Georgia's Pathways program (active since 2023). Expansion states must implement by January 1, 2027.
| State | Status | Enforcement start | Hours/mo | Re-review | Lookback | Verified |
|---|---|---|---|---|---|---|
| Illinois | Federal deadline; state plan pending | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| Georgia | Enforcing now | 2023-07-01 (waiver program) | 80 | every 6 mo | TBD | 2026-09-28 |
| Nebraska | Enforcing now | 2026-05-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| Montana | Enforcing now | 2026-07-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| Arkansas | Prior program; early implementation expected | 2026-07-01 (soft launch; penalties 2027-01-01) | 80 | every 6 mo | TBD | 2026-09-28 |
| Missouri | Awaiting federal deadline (Jan 1, 2027) | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Florida | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-28 | |
| Texas | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-20 | |
| Tennessee | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-28 | |
| Iowa | Scheduled (before Jan 2027) | 2026-12-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| North Carolina | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| Ohio | Expected early implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| Indiana | Scheduled (before Jan 2027) | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| Michigan | Scheduled (before Jan 2027) | 2027-01-01 | 80 | every 6 mo | 1 mo | 2026-09-28 |
| Kentucky | Prior program; early implementation expected | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-28 |
| Louisiana | Expected early implementation | 2027-01-01 | 80 | every 6 mo | 1 mo | 2026-09-28 |
| California | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Oklahoma | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Washington | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Oregon | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| New Mexico | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Wisconsin | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-20 | |
| Alabama | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-20 | |
| Alaska | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Arizona | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Colorado | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Connecticut | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Delaware | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Hawaii | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Idaho | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Kansas | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-20 | |
| Maine | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Maryland | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Massachusetts | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Minnesota | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Mississippi | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-20 | |
| Nevada | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| New Hampshire | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| New Jersey | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| New York | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| North Dakota | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Pennsylvania | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Rhode Island | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| South Carolina | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-20 | |
| South Dakota | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Utah | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Vermont | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Virginia | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| West Virginia | Expected implementation | 2027-01-01 | 80 | every 6 mo | TBD | 2026-09-20 |
| Wyoming | Not applicable (non-expansion state) | — | N/A | TBD | 2026-09-20 |
Disenrollment and denial log
As of July 19, 2026, DHHS reported 65 renewal applications and 317 initial applications denied for failing the new work requirements — the first denials under the new federal law in any state. The department also estimated about 200 enrollees would lose coverage from August 1; that figure is a projection, not a completed count. Urban Institute projects 16,000–30,000 Nebraskans could lose coverage by 2028. Source: DHHS figures reported by KOLN/1011now (2026-08-03) and Nebraska Public Media (2026-07-31).
Montana began enforcement July 1, 2026 but committed to no disenrollments before October 2026. First Montana disenrollment data is expected in fall 2026 and will be logged here within 48 hours of verified reporting.
Reading this dataset
Which states are enforcing Medicaid work requirements right now?＋
Three: Nebraska (started May 1, 2026), Montana (July 1, 2026), and Georgia's Pathways program (active since 2023 under its 1115 waiver). All other expansion states must implement by January 1, 2027.
What does "enforcement start date" mean?＋
The date a state begins enforcing the community-engagement requirement — the 80-hour monthly rule for expansion-state adults. States marked "active" are enforcing now; scheduled or expected states show that status and are not enforcing yet.
How often will my eligibility be re-checked?＋
Under OBBBA, states re-review eligibility every 6 months. The tracker's "Re-review" column shows each state's cycle in months.
What is the lookback period?＋
How far back a state looks at your work or income history during a compliance review. Each state's published figure is in the "Lookback" column; entries marked TBD are fields states have not yet published.
How do I read the disenrollment data?＋
Nebraska is the first state with OBBBA work-requirement denials: as of July 19, 2026, DHHS reported 65 renewal and 317 initial applications denied, and projected about 200 enrollees could lose coverage from August 1 — a projection, not a completed count. Urban Institute projects 16,000–30,000 Nebraskans could lose coverage by 2028.
How often is this dataset updated?＋
Every field carries a last-verified date, and verified changes are logged within 48 hours. Montana's first disenrollment figures, expected in fall 2026, will be added within 48 hours of verified reporting.
Cite this dataset
Journalists, researchers, and advocates may use this data with attribution. This dataset is published with a DOI, so it can be cited like any other research output.
DOI 10.5281/zenodo.22706060 (all versions) · 10.5281/zenodo.22706061 (this version)
Verification standard: every field carries a last-verified date; entries marked TBD are fields states have not yet published. Corrections: see our editorial policy. Last verified: 2026-09-28.
Reviewed by Gavin YE, Technical Director, ClearRules Labs.
Page last reviewed 2026-09-28