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Preparing for 2026: A Guide to the New Medicaid Work Requirements

Changes are on the horizon for many with Medicaid, and we want to ensure you have everything you need to navigate them with confidence. New Medicaid eligibility requirements are set to be implemented in 2026 — or January 1, 2027 at the latest — and, while the policy is still developing, understanding the framework now can help you prepare. 

Note: If you are over the age of 65, you are exempt from these requirements. If you meet the definition of disabled or “medically frail,” you are exempt from these requirements. We explain more exemptions below. 

This guide will walk you through what to expect, who might be exempt, and the proactive steps you can take to ensure a smooth process.

What are the new Medicaid requirements?

Beginning December 31, 2026, beneficiaries aged 19-64 who were eligible for Medicaid through their state’s Medicaid expansion will be required to verify at least 80 hours a month of participation in work, volunteer activities, “work programs”, or educational programs (or a combination of any of those for 80 hours) to maintain their eligibility. 

This policy is aiming to ensure all able-bodied adults have connections to employment, education, and community service for their overall health and wellbeing, and to save federal budget dollars on insuring beneficiaries who may not be eligible. 

Learn More About the Work Requirements at KFF

The good news is that, according to the Kaiser Family Foundation (KFF), a 62% majority of current Medicaid beneficiaries already meet these standards, and another 11% meet the criteria for exemption. The primary challenge for most won’t be meeting the requirements themselves, but rather navigating the new process of verifying them on a regular basis.

Note: If you are dual eligible for Medicare and Medicaid (and have a dual-eligible special needs plan), it’s critical to verify your eligibility for Medicaid so as to not lose coverage

Who is exempt from the new requirements?

The new rules include several key exemptions to ensure everyone’s circumstances are considered. You may be exempt from work verification requirements if you are:

  • A parent of a young child.
  • Considered “medically frail.”
  • Currently participating in a substance use recovery program.
  • Able to verify your status through disability or other specific exemption criteria.

A shared responsibility: Beneficiaries and states

Both individuals and state governments will have new responsibilities under this system. Think of it as a team effort.

What Beneficiaries Are Responsible For: As a beneficiary, you will need to provide documentation for your specific situation at least every six months. This may include:

  • Submitting income verification if you are eligible for Medicaid based on your income.
  • Providing verification of your work or volunteer hours.
  • Submitting proof of your enrollment in an educational or trade school program.
  • Filing for and verifying exemption status due to a disability or other criteria.

What States Are Responsible For: State governments are tasked with building and managing the verification systems. Their duties include:

  • Developing IT systems to track and report the number of verified beneficiaries to the federal government.
  • Informing all beneficiaries about the new verification processes. The federal government has budgeted funds to help states effectively communicate these new systems.
  • Working with a wide range of organizations—from volunteer groups to universities and trade schools—to create a cohesive reporting system.
  • Filing for waivers to implement their systems ahead of schedule or filing extensions if they need more time for implementation. For example, Utah has already filed such a waiver to implement work requirements for Medicaid eligibility this year.

How you can prepare now

While 2026 may seem far away, there are simple, proactive steps you can take now to get ready.

  1. Empower yourself with digital tools: Many states may model their new Medicaid systems on existing platforms, like those used for SNAP benefits. If you use SNAP, take some time to explore your state’s digital verification system. It is also a good idea to become more familiar with federal identity tools, such as registering for an ID.me account through SSA.gov.
  2. Partner with your Healthcare Provider: If you have a chronic illness or disability and plan to file for an exemption, start the conversation with your doctor now. Ensure they are aware of these future requirements and are prepared to help you complete the necessary forms to verify your health status with the state.
  3. Communicate with your network: Let your employer, school administrator, or volunteer coordinator know that you may need their help providing verification in the future. A simple heads-up can make the process smoother when the time comes.

By understanding these upcoming changes and taking small preparatory steps today, you can empower yourself to navigate the new verification process with confidence.

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Or speak to a licensed insurance agent
1-888-411-7647 | TTY: 711
M-F, 7:30 AM - 5 PM CT

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