What the 2025 Medicaid Work Requirements Law Actually Says
The 2025 reconciliation law — formally passed by Congress and signed into law — introduces federal Medicaid work requirements, often called "community engagement requirements," that may affect certain adults enrolled in Medicaid expansion coverage. This is the first time federal law has mandated work-related conditions for Medicaid eligibility, and it's generating significant questions from enrollees who want to know whether their coverage is at risk.
The short answer: most Medicaid enrollees are not immediately affected, and broad exemption categories protect many vulnerable groups. But if you're a working-age adult enrolled through Medicaid expansion, understanding the new rules — and your state's implementation timeline — is essential.
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Data Snapshot: Medicaid Enrollment and Who May Be Affected
As of early 2025, approximately 79 million people were enrolled in Medicaid and CHIP nationally, according to CMS data published at Medicaid.gov. Of that total, the expansion population — adults ages 19–64 who gained eligibility under the ACA's Medicaid expansion — represents roughly 21 million enrollees across the 40+ states that have adopted expansion.
KFF analysis of the 2025 reconciliation law estimates that community engagement requirements could affect between 5 and 10 million expansion enrollees who are not already working, in school, or covered by an exemption — though actual coverage loss will depend heavily on state implementation choices, exemption determinations, and reporting infrastructure. States that fail to build accessible reporting systems have historically seen the highest rates of coverage loss due to paperwork failures rather than actual non-compliance.
For reference, the 2025 Federal Poverty Level (FPL) thresholds used in Medicaid eligibility determinations are updated annually by HHS. Medicaid expansion covers adults up to 138% of the FPL. Non-expansion states have varying income thresholds, often significantly lower, for different eligibility categories.
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Who Is Subject to the New Requirements?
The federal requirements apply specifically to non-disabled adults ages 19–64 who are enrolled in Medicaid through the ACA expansion pathway. This group is sometimes called the "new adult group" in policy language.
Who Is Likely Exempt
The law includes exemption categories that may protect a significant portion of the expansion population. You may not be subject to work requirements if you:
- Are pregnant or recently postpartum (typically up to 12 months after delivery)
- Have a documented disability or serious medical condition that limits your ability to work
- Are a primary caregiver for a child under a certain age or for a dependent with a disability
- Are already working, in school, or in job training for a qualifying number of hours per week (the threshold under the 2025 law is generally 80 hours per month)
- Are between ages 19–24 and enrolled in secondary education
- Live in a rural area designated as having insufficient work opportunities (state-defined)
- Are experiencing homelessness
Exemption categories and how they're applied will vary by state. Not every state will implement requirements on the same timeline, and some states may add additional exemptions beyond the federal floor.
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How Implementation Actually Works — State by State
This is where things get complicated, and where many enrollees may be caught off guard.
Federal law sets the framework, but states must submit implementation plans to the Centers for Medicare & Medicaid Services (CMS) and receive approval before requirements take effect. As of mid-2025, states are at very different stages:
- Some states that previously pursued work requirement waivers under prior administrations may move quickly to implement.
- States that opposed work requirements may delay, challenge the law legally, or implement with maximum exemptions.
- A small number of states had existing approved waiver programs with work requirements already in place.
KFF is actively tracking implementation state by state, including which states have submitted plans, which have received approval, and what their specific policies look like. Checking KFF's tracker — along with your own state Medicaid agency's website — is the most reliable way to know where your state stands.
What the Reporting Process May Look Like
Once a state implements requirements, enrollees subject to them will typically need to:
- Report qualifying hours monthly — through an online portal, phone system, or paper form
- Document their activity — pay stubs, employer letters, school enrollment verification, volunteer organization letters
- Report exemption status — and provide supporting documentation if claiming an exemption
Missing a monthly reporting deadline — even if you are actually working or exempt — has historically been the leading cause of coverage loss under state-level work requirement pilots. Building a habit around monthly reporting, and keeping documentation organized, is the most practical protective step you can take.
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Documents You May Need to Gather Now
Whether or not your state has activated requirements yet, gathering these documents proactively can prevent a coverage gap later:
- Proof of employment: Recent pay stubs (last 30–60 days), employer contact information, or a letter from your employer confirming hours
- Proof of job training or education: Enrollment verification from a school, community college, or workforce training program
- Proof of caregiving: Birth certificate for a child in your care, documentation of a dependent's disability if applicable
- Medical documentation: A letter from your treating physician if you have a condition that limits your ability to work — this is critical for disability exemptions
- Proof of address: Utility bill, lease, or official mail — relevant if you're claiming a rural or housing-instability exemption
- Your Medicaid ID and case number: Keep this accessible for any reporting portal or phone system
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Step-by-Step: What to Do Right Now
Step 1: Find Out If Your State Has Activated Requirements
Visit your state Medicaid agency's website directly. Search "[your state] Medicaid community engagement requirements" or "[your state] Medicaid work requirements 2025." Look for official notices or a dedicated FAQ page. If you can't find clear information, call your state's Medicaid helpline.
Step 2: Determine Whether You May Be Exempt
Review the exemption categories listed above. If you believe you qualify for an exemption, contact your state Medicaid office to understand how to formally document and report that exemption. Do not assume your exemption is automatically on file.
Step 3: Set Up a Monthly Reporting Routine
If your state has activated requirements, find out exactly how to report — online portal, phone, or mail — and set a recurring monthly reminder. Treat it like a bill payment. Late or missed reports are the most common reason people lose coverage they're entitled to keep.
Step 4: Connect With a Certified Enrollment Assister
If you're unsure about your status, a certified application counselor or navigator can help you understand your situation at no cost. Find one through your state Medicaid office or through Benefits.gov. Legal aid organizations in your area may also offer free help if you receive a termination notice.
Step 5: Appeal If Your Coverage Is Terminated
If you receive a notice that your Medicaid coverage is being terminated due to work requirements, you have the right to appeal. Request a fair hearing immediately — in most states, if you appeal before your termination date, your coverage continues while the appeal is pending. The termination notice itself will include appeal instructions and deadlines.
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What Hasn't Changed: Core Medicaid Eligibility
Work requirements apply only to the expansion adult group. The following populations remain covered under traditional Medicaid eligibility rules and are not subject to work requirements under the 2025 law:
- Children and adolescents (covered through Medicaid and CHIP)
- Pregnant individuals
- Adults who qualify based on disability (SSI recipients and those meeting disability criteria)
- Seniors (65+) enrolled in Medicaid
- Parents and caretaker relatives in many states (eligibility thresholds vary)
If you fall into one of these categories, your Medicaid eligibility pathway is not directly affected by the 2025 work requirement provisions.
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People Also Ask
Q: When do Medicaid work requirements start in my state? A: Implementation timelines vary by state. States must submit plans to CMS and receive approval before requirements take effect. Some states may implement in late 2025 or 2026; others may delay or challenge the law. Check your state Medicaid agency's website or call their helpline for the most current timeline specific to where you live.
Q: What counts as qualifying work activity under the 2025 Medicaid rules? A: The 2025 law generally requires 80 hours per month of qualifying activity. This may include paid employment, job training, vocational education, community service, or participation in a workforce development program. Exact definitions of qualifying activities may vary by state implementation plan.
Q: Will I lose Medicaid automatically if I don't report my hours? A: Failure to report qualifying hours by your state's deadline may result in a coverage termination notice. However, you have the right to appeal. If you appeal before your termination date, coverage often continues during the appeal. Contact your state Medicaid office or a legal aid organization immediately if you receive a termination notice.
Q: Are people with disabilities exempt from Medicaid work requirements? A: People who qualify for Medicaid based on a documented disability — including SSI recipients — are generally not subject to work requirements. Adults in the expansion group who have a medical condition limiting their ability to work may qualify for a medical exemption, but typically must document this through their state's process with supporting documentation from a treating provider.
Q: Where can I get free help understanding how these changes affect me? A: Free assistance may be available through your state Medicaid office, certified application counselors, navigators, and local legal aid organizations. Benefits.gov can help you locate assistance programs and local resources. No legitimate enrollment assistance service charges a fee to help you understand or apply for Medicaid.
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Last reviewed: August 2026