If you have Medicaid, you may have heard that some people will have to prove they work at least 80 hours a month to keep their coverage.
This new work requirement, announced in June of this year, applies to certain adults between the ages of 19 and 64 who receive Medicaid and meet specific eligibility criteria.
States must begin implementing these requirements no later than January 1, 2027, although some may do so earlier.
Who does this affect?
The requirement applies to people between the ages of 19 and 64 who are part of the Medicaid expansion group—that is, adults without dependent children or with low incomes who do not qualify for any of the medical or personal exceptions established by the program.
Among the exceptions are some pregnant or postpartum individuals, people with certain disabilities or medical needs, and parents, guardians, and family members who care for children under 13 or family members with disabilities.
What do you need to demonstrate?
If you are subject to the new rule, you can meet it in different ways. One way is to work at least 80 hours per month. These hours may also come from certain work, education, or community service programs—or a combination of these activities.
How you demonstrate compliance will depend on how your state implements the requirement. If the state cannot verify your compliance using the information it already has, it must give you 30 days to provide evidence that you are compliant or that you are exempt.
An alternative way to meet the new work participation requirement is to demonstrate monthly income equivalent to 80 hours paid at the federal minimum wage. In 2026, this amounts to $580 per month.
The requirement may begin to apply before you apply for Medicaid
If you are subject to the requirement, your state will have to ask you to show that you met the 80-hour work requirement or other required activities during at least the month prior to your application. The state may decide to require up to three months of compliance prior to the application.
For example, if you apply for Medicaid in January 2027, you will have to show that you met the requirement in December 2026. If your state requires two months, you’ll need to demonstrate compliance in November and December; if it requires three, in October, November, and December.
However, before the requirements take effect, states must provide affected individuals with information about the new rules, how to demonstrate compliance, and what they need to do to maintain their coverage.
For caregivers: Could EVV help you document your hours?
This is a possibility that could be especially relevant for caregivers who already use EVV (Electronic Visit Verification).
EVV is a system that Medicaid uses to verify certain in-home health and personal care services. The system records information about who provided the service, who received it, where it took place, and when the visit began and ended.
The Centers for Medicaid and Medicare Services (CMS) stipulate that states must first attempt to use reliable information they already have to verify compliance before requesting additional documentation from the individual. Examples include payroll data, payments to Medicaid providers, and encounter data.
This is relevant for caregivers who use EVV because those systems already collect information about the services provided. The National Alliance of Home Care Workers (ANTH) has suggested that states could leverage these records to help verify the hours worked by caregivers providing Medicaid-funded services, which would enable compliance with Medicaid work requirements in states that have expanded the program.
Note: The National Domestic Workers Alliance is a partner organization of La Alianza.
For example, if a caregiver is subject to the new requirement and works 20 hours per week, her visits are recorded in the EVV system. If her state decides to accept those records to verify the work requirement, the data could help demonstrate that the caregiver worked approximately 80 hours during the month.
But this is not a federal rule. Each state will have to determine how it will verify compliance.
EVV may also have issues
Worker organizations, advocates for people with disabilities, and experts in technology and privacy have questioned some uses of EVV due to its surveillance effects and the burdens it can create.
An investigation by Data & Society documented how these systems can increase surveillance and create additional burdens for both caregivers and the people they care for. Glitches in these systems have also been documented, leading in some cases to theft or delays in the payment of wages.
That’s why it’s recommended that you keep your own records of hours worked.
What You Can Do Now
The CMS recommends that individuals subject to the requirement familiarize themselves with their state’s rules and be prepared to demonstrate compliance. While states finalize their procedures, here are some steps you can take to prepare.
- Find out if the requirement applies to you. Not all people on Medicaid are subject to it.
- Check to see if you may be exempt, for example, if you care for a young child or a family member with a disability.
- Start keeping your own records of the hours you work. CMS allows states to require proof of compliance for one, two, or even three months before you apply for Medicaid. Having your own records can help you verify the hours you worked if the state cannot verify them using the information it already has.
- If you use EVV, check to make sure your visits and work hours are recorded correctly.
- Ask your state’s Medicaid office or the state agency responsible for administering the Medicaid program and the EVV system how you can correct an error in EVV if you find one.
- Stay tuned for instructions from your state’s Medicaid office on how the requirement will be verified.
Editor’s note: This article was originally written in Spanish and translated into English
