Medicaid Work Requirements: Learn More and Take Action!

Published July 13, 2026

The CMS Medicaid work requirements rule takes effect 1 January 2027 and will require most people on Medicaid expansion to prove 80 hours a month of work, study or volunteering. The public comment period closed on 31 July 2026. A plain-language explanation from the Autistic Self Advocacy Network of what the rule says and who it affects.

<blockquote><p><strong>About this resource — Autism Resource Hub editorial note, 5 August 2026.</strong> This is a plain-language explainer republished from the <a target="blank" rel="noopener noreferrer" href="https://autisticadvocacy.org/2026/07/medicaid-work-requirements-learn-more-and-take-action/">Autistic Self Advocacy Network</a>, an autistic-led advocacy organisation. It reflects ASAN's advocacy position as well as its explanation of the rule.</p><p><strong>The call to action in the original has expired.</strong> ASAN published this to encourage public comments to CMS. That comment period <strong>closed on 31 July 2026</strong> and comments can no longer be submitted. We have kept ASAN's explanation of the rule, which remains accurate and useful, and replaced the comment-submission instructions with what you can do now.</p><p><strong>Where the rule stands:</strong> CMS published this as an <strong>interim final rule with comment period</strong> (CMS-2454-IFC) on 1 June 2026. States must implement it by <strong>1 January 2027</strong>. It applies to Medicaid expansion populations aged 19–64 across the 41 expansion states and the District of Columbia. CMS projects it will reduce Medicaid enrolment by roughly 2.3 million people in FY2027.</p><p><strong>This applies to the United States only.</strong></p></blockquote> <h1>What is this resource?</h1> <p>This is a plain language resource to explain a government rule. The rule will affect millions of disabled people in the United States. The resource explains:</p> <ul> <li>What the rule says;</li> <li>How the rule affects disabled people, and</li> <li>What you can do now.</li> </ul> <h1>What is the rule about? </h1> <p>The rule is about Medicaid. Many disabled people get health care and services through Medicaid. <strong>Medicaid</strong> is a health care program run by state governments. Medicaid helps many people get health care. Many people with disabilities and many people who don’t have a lot of money use Medicaid. <strong>Medicaid expansion </strong>is a kind of Medicaid adults can get if they do not make a lot of money. </p> <p>The rule is about work requirements. The rule says most people who get health care through Medicaid expansion will have to follow work requirements. <strong>Work requirements </strong>are when people have to prove they are working to get health care. The<strong> </strong>Centers for Medicare and Medicaid Services (CMS) made this rule about work requirements. <strong>CMS</strong> is the part of the government that makes rules about Medicaid.</p> <h1>What does the CMS rule say about Medicaid work requirements?</h1> <p>The CMS rule says that most people who get Medicaid expansion have to follow work requirements. A few ways people can follow work requirements are:</p> <ul> <li>Prove they work 80 hours a month</li> <li>Prove they are doing a work program for 80 hours a month. <strong>Work programs </strong>teach people how to do a job. It can also teach someone how to find a job.</li> <li>Prove they volunteer 80 hours a month </li> <li>Prove they go to school at least half-time.<strong> Half-time</strong> can mean taking half as many classes as full-time students. The school decides what half-time means.</li> <li>Doing a little bit of each thing above. The total time you spend doing the things together has to be at least 80 hours per month.</li> </ul> <p>There are two other ways to follow work requirements. They have to do with how much money a person makes each month. </p> <p>If a person makes more than $580 a month every month, they followed work requirements. </p> <p>The other way is about people who do seasonal work. <strong>Seasonal work </strong>is when someone works for part of the year. This is very common in farm jobs. </p> <p>People who do seasonal work have to make a certain amount of money to follow work requirements. The government looks at how much money they made in 6 months. People who do seasonal work need to earn $3480 or more in 6 months to follow work requirements. </p> <p>People getting healthcare with programs like Medicaid expansion need to do this to keep getting healthcare. </p> <h2>Who has to follow work requirements?</h2> <h3>People who get health care through programs like Medicaid expansion</h3> <p>Some states have Medicaid expansion programs. Medicaid expansion programs have different names in different states. You can ask your state Medicaid office what Medicaid expansion is called in your state. You can learn how to contact your state Medicaid office <a href="https://www.kidney.org/kidney-topics/find-your-state-medicaid-office" target="blank" rel="noopener noreferrer nofollow">here.</a> </p> <p>Some states have programs that are like Medicaid expansion but are not Medicaid expansion. States made these programs to give health care to people who could not get Medicaid some other way. Some people who get Medicaid from these programs will also have to follow work requirements. These programs are: </p> <ul> <li>Georgia–Pathways to Coverage: Pathways population and ESI/HIPP </li> <li>Hawaii–QUEST Integration: Populations 1, 4, and 5 </li> <li>Massachusetts–MassHealth: e-HIV/Family Assistance + TANF and EAEDC </li> <li>New York–Medicaid Redesign Team: TANF </li> <li>Oregon–Oregon Health Plan: Youth with Special Health Care Needs </li> <li>Tennessee–TennCare III: Parent/Caretaker Relatives Expansion </li> <li>Utah–Utah Medicaid Reform: Adult Expansion Population and Targeted Adults </li> <li>Wisconsin–Badgercare Reform: Childless Adult Demonstration Population </li> </ul> <p>Your state has to tell you if you will have to follow work requirements. Most states were expected to start telling people in August of 2026. If you are not sure if you are part of one of these programs, talk to your state Medicaid agency. This resource calls Medicaid expansion and these other programs “programs like Medicaid expansion”.</p> <h2>Who does not have to follow work requirements?</h2> <p>The rule does not do a good job explaining who does not have to follow work requirements. This is bad for people who get health care through Medicaid. This is bad for states trying to follow the rule. </p> <p>There is a lot of information about people who do not have to follow work requirements. ASAN put that information in its own plain language resource. <a href="https://autisticadvocacy.org/2026/07/who-does-not-have-to-follow-medicaid-work-requirements/" target="blank" rel="noopener noreferrer nofollow"><strong>Read that resource here</strong></a>.</p> <h2>Do people who get SSI or SSDI have to follow work requirements? </h2> <p>ASAN made another plain language resource to explain this. <a href="https://autisticadvocacy.org/2026/07/medicaid-work-reqs-ssi-ssdi/" target="blank" rel="noopener noreferrer nofollow"><strong>Read that resource here</strong>.</a></p> <h3>How does CMS decide if someone has to follow work requirements?</h3> <p>The rule says that states have to decide who has to follow work requirements. The rule says states need to use data for this. Another word for data is information. The data they use is about people who get health care through Medicaid. The data is also about people who are trying to get health care through Medicaid. </p> <p>States already have to get some kinds of data. States already have some of the data they need. But states do not have a way to get all the data CMS wants them to have. For example, states do not have a way to get data that says someone’s disability means they can’t work. That data does not exist. </p> <p>This means states might have to ask people questions about their disability. The questions will help states get data that says someone’s disability means they can’t work. The rule does not say what questions states have to ask. The rule does not tell states how to get the data. People might have to do a lot of paperwork to help states get the data. That is not fair to people who get health care through Medicaid. People who get health care through Medicaid already have to fill out a lot of paperwork. </p> <p>A lot of people could lose their health care. This is because many people do not have the support they need to fill out all the paperwork. </p> <h1>What can I do now?</h1> <p>The public comment period closed on 31 July 2026. You can no longer send CMS a comment about this rule. Here are things you can still do:</p> <ul> <li><strong>Contact your state Medicaid agency.</strong> Ask if you are in a program that has work requirements. Ask how your state will decide who does not have to follow them. Ask what paperwork you will need.</li> <li><strong>Keep your paperwork.</strong> Keep copies of anything that shows your disability or health condition. Keep any letter that says you get SSI or SSDI.</li> <li><strong>Contact your state Protection and Advocacy agency.</strong> Every state has one. They give free legal help to disabled people.</li> <li><strong>Contact your members of Congress.</strong> You can tell them how this rule affects you. You can find them at <a href="https://www.congress.gov/members/find-your-member" target="blank" rel="noopener noreferrer nofollow">congress.gov</a>.</li> <li><strong>Follow ASAN.</strong> ASAN posts new plain language resources and action alerts when there is something new to do.</li> </ul> <p>If you need help, you can email Jules Good, State Advocacy Manager at the Autistic Self Advocacy Network, at <a href="mailto:jgood@autisticadvocacy.org">jgood@autisticadvocacy.org</a>.</p> <hr/> <p><em>Source: Autistic Self Advocacy Network — <a href="https://autisticadvocacy.org/2026/07/medicaid-work-requirements-learn-more-and-take-action/" rel="noopener noreferrer nofollow" target="blank">Medicaid Work Requirements: Learn More and Take Action!</a> ASAN's explanation of the rule is republished in its original plain-language wording; the expired comment-submission instructions have been replaced. Rule status checked against the <a href="https://www.cms.gov/newsroom/fact-sheets/medicaid-community-engagement-requirement-certain-individuals-interim-final-rule-comment-period-cms" rel="noopener noreferrer nofollow" target="blank">CMS fact sheet for CMS-2454-IFC</a> on 5 August 2026.</em></p><p><em>This is general information about a United States federal rule, not legal advice. Talk to your state Medicaid agency or a benefits advocate about your own situation.</em></p>

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