A new Medicaid requirement could create a challenge for some adults with jobs: their hours may not consistently add up to the amount needed to meet the rule.
A study published in JAMA Health Forum found that 19.8% of potentially affected Medicaid adults in Medicaid expansion states could be at risk of falling short of the federal government’s new community-engagement requirement because their work hours are too low or inconsistent.
The finding does not mean those people will automatically lose Medicaid. Researchers reviewed current work patterns to estimate who may struggle to meet the new standard once it takes effect. Some individuals may still qualify through other activities, income rules, or federal exclusions.
For people with steady jobs, meeting the requirement may be simple. But workers with changing shifts, part-time schedules, or gig work may face a different calculation every month.
The New Rule Requires 80 Hours of Qualifying Activity
The federal community-engagement requirement applies to certain Medicaid adults ages 19 to 64 and requires 80 hours per month of qualifying activity.
That activity includes more than traditional employment.
People can meet the requirement through:
- Work
- Education
- Job training
- Community service
- Other approved activities
CMS also created an income-based option for people who earn at least the equivalent of 80 hours at the federal minimum wage, which the agency lists as $580 per month in 2026.
The rule is scheduled to take effect no later than January 1, 2027, although states may begin earlier. It applies to certain adults on Medicaid, not the entire Medicaid population.
The People Who Could Struggle Are Not Necessarily Unemployed
The study found that many adults who could face challenges are already connected to the workforce.
Researchers estimated:
- 19.8% could be at risk because of insufficient or inconsistent hours.
- 13.6% were close to the minimum-hours threshold.
- 7.6% had highly inconsistent work schedules.
The difference comes down to predictability.
Someone with a regular 40-hour schedule may easily meet an 80-hour monthly requirement. Someone whose hours depend on seasonal demand, employer scheduling, or gig opportunities may not have the same certainty.
Paul Shafer, the study’s lead author and an associate professor at Boston University, said the requirement could be especially difficult for people with limited control over their schedules.
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“These new work requirements are going to be tougher to fulfill for people with less education, part-time jobs or gig work, who have less control over their hours, and those who have substantial health concerns that may not rise to the level of a documentable disability.”
Some Medicaid Recipients Are Excluded From the Requirement
The federal rule does not apply to everyone.
People who qualify for certain categories are excluded from the community-engagement requirement, including:
- Pregnant and postpartum people
- Former foster-care youth
- Certain parents and caregivers responsible for young children or disabled individuals
- American Indians and Alaska Natives who meet the federal definition
- Medically frail individuals
- Veterans with total disability ratings
- People participating in qualifying drug or alcohol treatment programs
The rule also includes exclusions connected to other public programs.
For TANF, the person must be complying with applicable state TANF requirements under federal work rules. For SNAP, the exclusion applies to someone in a SNAP household who is not exempt from SNAP work requirements.
Simply receiving SNAP or TANF does not automatically remove the Medicaid requirement.
Related: 5 States With the Most People on Food Stamps.
Hardship Exceptions May Be Available in Some States
States may choose to offer temporary hardship exceptions for certain situations.
CMS identifies possible circumstances, including qualifying medical care, living in an area affected by a presidentially declared disaster, living in a high-unemployment county, or needing extended travel for serious medical care.
These exceptions are different from permanent exclusions.
An excluded person is not required to meet the Medicaid community-engagement condition. A person receiving a hardship exception is only treated as meeting the requirement for a limited period. States decide whether to offer these exceptions and how people apply.
States Will Determine How the Rule Works in Practice
The federal government created the requirement, but states will handle much of the rollout.
States will decide how they verify compliance, identify exclusions, process hardship requests, and communicate with Medicaid recipients.
CMS says states should use available information first, including employment records, Medicaid data, education records, and other government sources, before asking individuals for additional documentation.
For people whose information is incomplete or changes frequently, proving eligibility may become a major part of the experience.
The new rule is not only changing what Medicaid recipients may need to do each month. It’s also changing how the government measures work in an economy where many people rely on flexible schedules and changing hours.
