Medicaid Work Requirements by State
Federal law sets January 1, 2027 as the backstop — but states can start earlier, and Georgia already operates a work requirement today. Select a state for its full profile — or get the full dataset (CSV, free to cite).
Can the courts block this?
The first attempt to block the 2027 work requirement failed. The case is still alive.
In late June 2026, 25 states plus the District of Columbia sued the federal government over the rule that tells states how to run the new Medicaid work requirement. Their central argument is that the June 2026 federal rule narrowed the "medically frail" exemption far beyond what Congress enacted — requiring people to prove their condition substantially impairs their ability to work, rather than exempting them based on a serious condition alone. On August 5, 2026, the judge denied the states' request to pause the rule while the case proceeds. The denial does not decide the case; briefing on the merits continues. On September 18, 2026, a second, independent lawsuit — Taylor et al. v. Kennedy Jr. et al. — was filed in federal district court in Maryland by five Medicaid enrollees and medical organizations, challenging the same medical-frailty provisions.
25 states plus the District of Columbia, co-led by California, Massachusetts and New Jersey, with the governors of Kentucky and Pennsylvania also joining. Illinois is one of the plaintiff states.
Judge Richard Stearns concluded the states had not shown they would suffer irreparable harm. Two reasons carried the most weight: the January 1, 2027 deadline was set by Congress rather than by CMS, so the agency is not clearly to blame for the tight timeline; and CMS has said it will reimburse 90% of the cost of building the eligibility systems, so the remaining 10% did not rise to the level of harm that justifies an injunction.
- • Do not plan on the courts stopping this. The injunction was denied and the January 1, 2027 implementation deadline stands.
- • The case is not over. The denial was without prejudice, so the states can ask again, and the court is continuing to hear the merits of the case.
- • If briefing runs past the end of 2026, the states could renew a request to pause the requirement. That is a real possibility, but it is not something to build your coverage on.
- • The practical consequence: prepare for 2027 while treating an 11th-hour court ruling as upside, not as the plan.
Coverage varies on the plaintiff count — most outlets report 25 states plus the District of Columbia, while some report 26 states or jurisdictions. This page uses the more conservative figure. Next milestone: Briefing on the merits continues. Plaintiffs may renew a motion to stay if briefing extends past the end of 2026.
Docket and key dates
- 2025-07-04In effectOBBBA signed into law
The One Big Beautiful Bill Act (P.L. 119-21) creates the national community-engagement requirement: 80 hours per month for Medicaid expansion adults, six-month redeterminations, and a federal implementation backstop of January 1, 2027.
- 2026-06-03In effectFederal implementation rule published
CMS publishes the Interim Final Rule (CMS-2454-IFC; 91 Fed. Reg. 33348; RIN 0938-AV98; corrected at 91 Fed. Reg. 39028 on June 29, 2026) telling states how to run the requirement. It adds a "significantly impairs" test to the medically frail exemption and bars states from relying on diagnosis codes alone. It permits self-attestation for medical frailty during calendar year 2027 only; from January 1, 2028 self-attestation is limited to once per enrollment period, after which documentation is required.
- 2026-06-29In effect25 states plus DC file suit
Massachusetts, et al. v. Oz is filed in the District of Massachusetts. The plaintiffs allege the rule violates the Administrative Procedure Act and unlawfully narrows the statutory medical-frailty protection, and that it coerces states by changing the terms after they had begun building their systems.
- 2026-07-31In effectRule effective; comment period closed
The interim final rule takes effect before public comment is reviewed. The comment window closes July 31, 2026 — late, but comments can still inform future changes.
- 2026-08-05Injunction deniedInjunction denied
Judge Richard Stearns denies the states' request for a preliminary injunction and stay, without prejudice. The case continues on the merits and the states may ask again later.
- 2026-08-31PassedEnrollee notice deadline
Deadline for states to mail notices to affected Medicaid enrollees ahead of the January 2027 start. If you are an expansion adult and you have not received anything, the most likely reason is that your address on file is out of date — not that you are unaffected.
- 2026-09-08In effectCMS releases medical frailty implementation guidance
CMS issues implementation guidance on the medical frailty exclusion (previewed to states on a September 3, 2026 call), building on the June interim final rule. It offers a three-tier verification model — a model, not a mandate: (1) some diagnoses alone may establish frailty; (2) others require supplemental evidence such as utilization or pharmacy records; (3) unresolved cases go to individualized review. CMS highlighted Louisiana's tiered code approach as an example and said it will collect state methodologies in fall 2026.
- 2026-09-18In effect70-organization amicus brief filed in support of states
A coalition amicus brief led by the National Health Law Program and joined by roughly 70 organizations is filed in support of the plaintiff states, arguing the interim final rule unlawfully narrows the statutory medical-frailty exemption. No court order has issued since the August 5 denial of the preliminary injunction.
- 2026-09-18In effectSecond lawsuit filed — Taylor et al. v. Kennedy Jr. et al. (D. Md.)
A separate case from the states' suit: five Medicaid enrollees from multiple states, joined by medical organizations, file in the U.S. District Court for the District of Maryland (Case 1:26-cv-03705-GLR, Judge George Levi Russell III), represented by the National Health Law Program, Democracy Forward and Legal Aid of Western Missouri. The complaint challenges the interim final rule's medical-frailty provisions — the extra "significantly impairs" step and the exclusion of people with substance use disorder in stable recovery for five or more years — as exceeding what Congress enacted. It asks the court to vacate those provisions before the January 2027 implementation.
- 2027-01-01UpcomingFederal implementation deadline
All expansion states must operate the work requirement. States may start earlier — Nebraska began May 1, 2026 and Montana July 1, 2026. In most states, current enrollees enter the requirement at their first redetermination on or after this date.
- 2028-01-01UpcomingMedical-frailty documentation begins
This is the date most people underestimate. Through 2027, states may accept a signed self-attestation for medical frailty where they cannot verify it from existing data. From January 1, 2028, self-attestation is limited to once per enrollment period and documentation is required thereafter. If you rely on this exemption, the paperwork you should be gathering is for 2028.
- Judge rejects states' bid to pause Medicaid work requirements — Healthcare Dive (accessed 2026-09-10)
- Explainer: the Medicaid work reporting requirements interim final rule — Georgetown Center for Children and Families (accessed 2026-09-10)
- A cancer diagnosis may not be enough: the fight over who counts as medically frail — POLITICO (accessed 2026-09-10)
- Judge rejects states' bid to block Medicaid work rules — NC Health News (accessed 2026-09-10)
- State regulatory approaches to Medicaid work requirements — Stateside Associates (accessed 2026-09-10)
- CMS Releases New Information on Operationalizing Medicaid Work Reporting Requirements' Medical Frailty Exclusion — State Health & Value Strategies (describing CMS guidance released 2026-09-08) (accessed 2026-09-21)
- From DC 09/18/2026 (amicus brief coverage) — Justice in Aging (accessed 2026-09-21)
- Taylor et al. v. Kennedy Jr. et al. — Complaint (Case 1:26-cv-03705-GLR, D. Md., filed 2026-09-18) — National Health Law Program (accessed 2026-09-28)
- Medical groups, patients sue Trump administration over Medicaid work requirements — WBIW / The Hill (accessed 2026-09-28)
Which states have active work requirements in 2026?
3 states already enforce a Medicaid work requirement — Nebraska and Montana, the first two to start under the OBBBA rules, and Georgia, whose Pathways program has required 80 hours a month since 2023. Every other expansion state must have the federal 80-hour rule in place no later than January 1, 2027.
| State | Enforcing since | Program | What's different |
|---|---|---|---|
| Georgia | 2023-07-01 | Georgia Pathways to Coverage | Pathways waiver — the longest-running work requirement in the country. 80 hours a month to enroll and stay enrolled. |
| Nebraska | 2026-05-01 | Nebraska Medicaid (Heritage Health Adult expansion) | First state enforcing under the OBBBA rules. New applicants had to comply from May 1; existing enrollees from August 1. |
| Montana | 2026-07-01 | Montana Medicaid expansion (HELP Act) | Second state under the OBBBA rules. Grace period: no disenrollments before October 2026. |
HealthChoice Illinois — ACA Adult (MAGI) expansion
Georgia Pathways to Coverage
Nebraska Medicaid (Heritage Health Adult expansion)
Montana Medicaid expansion (HELP Act)
ARHOME (Arkansas Health and Opportunity for Me)
MO HealthNet (Adult Expansion Group)
Florida Medicaid (no adult expansion)
Texas Medicaid (no adult expansion)
TennCare (no adult expansion)
Iowa Health and Wellness Plan (Medicaid expansion)
NC Medicaid (expansion)
Ohio Medicaid (Group VIII expansion)
Healthy Indiana Plan (HIP 2.0)
Healthy Michigan Plan
Kentucky Medicaid (expansion via kynect)
Louisiana Medicaid (expansion)
Medi-Cal
SoonerCare
Apple Health (Washington Apple Health)
Oregon Health Plan (OHP)
Centennial Care (New Mexico Medicaid)
BadgerCare Plus
Alabama Medicaid
Alaska Medicaid
Arizona Health Care Cost Containment System (AHCCCS)
Health First Colorado
HUSKY Health
Delaware Medicaid (Diamond State Health Plan)
Med-QUEST
Idaho Medicaid
Kansas Medicaid
Maine Medicaid
Maryland Medicaid
MassHealth
Minnesota Medical Assistance
Mississippi Medicaid
Nevada Medicaid
New Hampshire Medicaid
NJ FamilyCare
New York Medicaid
North Dakota Medicaid
Pennsylvania Medicaid
Rhode Island Medicaid
South Carolina Medicaid
South Dakota Medicaid
Utah Medicaid
Vermont Medicaid (Green Mountain Care)
Cardinal Care
West Virginia Medicaid (Mountain Health Trust)
Wyoming Medicaid
The national rule in brief
Do you have to work 80 hours a month for Medicaid?
Yes — if you are a Medicaid expansion adult (generally ages 19–64). Federal law requires 80 hours per month of work or qualifying community engagement — not per week — in every expansion state no later than January 1, 2027. Earning at least $580 in a month counts as an alternative compliance path in several state implementations, and the federal exemption list (caregivers, pregnancy, disability and more) applies in every state.
Who does the Medicaid work requirement apply to?
Adults covered through the ACA Medicaid expansion — generally ages 19–64. It does not apply to children, pregnant people, people enrolled on the basis of disability, anyone 65 or older, or adults in states that did not expand Medicaid. Your state's profile above gives its exact scope.
Is it 80 hours a month or 80 hours a week?
Per month. The confusion usually comes from the "80-hour work week" schedules known in medicine and residency — that is a different rule altogether. The monthly hours can be combined across paid work, volunteering, job training and half-time education.
When does the Medicaid work requirement start?
Federal law sets January 1, 2027 as the deadline for every expansion state, but states can start earlier — Georgia already enforces a requirement, and Nebraska and Montana began in 2026. The state list above shows each state's start date and re-review cycle.
What happens if you don't meet the work requirement?
You receive a notice with a 30-day response window, and coverage continues while you respond. Missing it can end expansion coverage — the coverage-alternatives page ranks your fallback options (marketplace subsidies, CHIP, employer coverage).
Implementation details (countable activities, lookback periods, reporting channels) are finalized state by state. We update each profile within 48 hours of new official guidance.