Medicaid Work Requirements Delayed Will You Lose Coverage?

On Friday, November 13, 2026, the Centers for Medicare & Medicaid Services (CMS) told states they may use an optional “hold harmless” period through June 30, 2027 before they deny or end Medicaid coverage because someone fails the new federal work requirement. The requirement still starts January 1, 2027, and it has not been repealed.

Can you still lose Medicaid before July 2027? Yes. The delay is optional, so it depends on your state. It covers only denials and terminations solely for failing the work requirement. Coverage can still end for other reasons, such as income, residency or missed renewal paperwork. It also does not touch the separate six-month renewal rule explained below.

Medicaid Work Requirement Delay: What Changed on November 13, 2026

Question	Latest information
Who announced it?	CMS, in a Friday letter to state Medicaid officials and a press release
Original start date	January 1, 2027
What is the new option?	A “hold harmless” period through June 30, 2027
Is it automatic?	No. States must opt in; reporting says flexibility requests are due December 11, 2026
What must opting-in states still do?	Assess whether people meet the requirement or qualify for an exclusion
What can opting-in states not do?	Deny or disenroll otherwise eligible people solely for failing the requirement during the period
Will CMS penalize states that use it?	No. CMS said it will not take enforcement action against states that opt in
Has the work requirement been repealed?	No. The 80-hour requirement remains federal law
Can other eligibility rules still end coverage?	Yes

CMS said the extra time lets states improve eligibility systems, train workers and reduce errors. It also urged states to maximize automated data checks, send timely notices, test their systems end to end and work with community organizations.

Why Did CMS Delay Enforcement of the Medicaid Work Requirement?

States had warned that the timeline was too short. The law gave them less than 18 months from enactment to go-live, and they said they lacked the data systems needed to verify employment and exemptions. Colorado’s Medicaid director said her department was missing health and employment records for at least 175,000 residents, according to reporting.

Pressure also came from Congress. A letter dated Wednesday, November 11 from Representative Frank Pallone and Senator Ron Wyden asked the administration to use its discretion to give states more time. The delay followed an October 29 federal court ruling against part of CMS’s rule, described below.

The administration defends the requirement as encouraging work, training and community participation. Critics argue it will remove coverage from people who already work or qualify for an exemption but cannot prove it.

Which States Are Delaying Medicaid Work Requirements and Which Are Enforcing Now?

The announcement does not mean every state has chosen the delay. Each state decides, and enforcement already differs:

Nebraska launched its requirements on May 1, 2026. State figures through August showed more than 1,000 people had lost coverage or been denied benefits because of the new rules.
Other early implementers. Some trackers list Montana, Iowa and Arkansas as early movers. Confirm with your state’s Medicaid agency because those dates and details were not verified for this article.
Most other expansion states were preparing for January 1, 2027 and must now decide whether to use the hold harmless period.

The announcement does not by itself reverse terminations that already happened. Check your state Medicaid agency’s latest instructions.

Can a State Delay Work Requirements Until 2028?

Separately from the new hold harmless period, the 2025 law lets the Secretary of Health and Human Services give a state a good-faith exemption that can run as late as December 31, 2028, but only with federal approval. A state cannot assume a 2028 deadline on its own.

Who Must Meet the 80-Hour Medicaid Work Requirement?

The requirement mainly applies to non-pregnant adults ages 19 through 64 who are covered through the Affordable Care Act’s Medicaid expansion group, and to certain adults in Section 1115 waiver programs that provide comparable coverage. Under Section 71119 of Public Law 119-21, codified at 42 U.S.C. § 1396a(xx), qualifying activities generally include:

At least 80 hours a month of work.
At least 80 hours of community service.
At least 80 hours in a work program.
Enrollment in an educational program at least half time.
Any combination of those totaling at least 80 hours.
Monthly income at least equal to 80 times the federal minimum wage, about $580 a month at $7.25 an hour.

Seasonal workers’ hours are generally averaged over the prior six months. The requirement is a monthly total, not a fixed 20 hours every week.

How Do States Verify Compliance?

At application, a state must check compliance for at least one month, and up to three, before the application. For people already enrolled, it must check at least once per renewal period, and a state may check more often. States are directed to use available data first, so some people may not have to submit anything. Do not assume that will happen for you.

Who Is Exempt From the Medicaid Work Requirement in 2027?

Group	General treatment
Under age 19, or age 65 and older	Not covered by the adult requirement
Pregnant or postpartum individuals	Excluded
Entitled to or enrolled in Medicare	Excluded
Parent or caregiver of a child age 13 or under	Excluded
Caregiver of a person with a disability	Excluded
Medically frail individuals	Excluded when statutory criteria are met
Veterans with a total disability rating	Excluded
American Indians and Alaska Natives	Excluded
People in drug or alcohol treatment	Excluded
People meeting SNAP or TANF work rules	May be excluded
Former foster youth under age 26, and people recently released from incarceration	Excluded under the statute’s listed categories

States may also grant short-term hardship exceptions, for example for hospitalization, a declared disaster or a high-unemployment county. Having an exemption does not mean the state already knows you qualify. You may need to confirm it.

Who Counts as Medically Frail for Medicaid Work Requirements?

The statute includes people who are blind or disabled, have a substance use disorder, a disabling mental disorder, a physical, intellectual or developmental disability that significantly impairs activities of daily living, or a serious or complex medical condition.

What Did the Federal Court Rule About the Medically Frail Exemption in Massachusetts v. Oz?

On October 29, 2026, U.S. District Judge Richard Stearns in Boston ruled in Commonwealth of Massachusetts v. Oz for 25 states and the District of Columbia. CMS’s June 3, 2026 interim final rule said a person with a listed condition qualified as medically frail only if the condition “significantly impairs” the ability to meet the work requirement. Judge Stearns held that extra test goes beyond what Congress wrote, vacated the language and permanently enjoined CMS from enforcing it. One report described the injunction as protecting the plaintiff states, so check how it applies in your state.

The ruling did not strike down the work requirement. The judge also upheld other parts of the rule, including a limit of one self-attestation per enrollment period. CMS had not said whether it would appeal, and a related case, Taylor v. Kennedy, was pending in federal court in Maryland. The ruling and the November 13 hold harmless announcement are separate developments.

The ruling does not exempt everyone with a diagnosis. It means a person who fits a statutory medically frail category does not also have to prove the condition prevents them from working.

Can You Lose Medicaid if You Are Unemployed?

Yes, in some cases, but unemployment alone does not end your coverage automatically. An unemployed person can still qualify by:

Doing 80 hours of volunteering, community service or an approved work program.
Attending school at least half time.
Qualifying for an exclusion, such as medical frailty or caregiving.
Living in a state using the hold harmless period, during that window.

Searching for a job is not by itself an exemption.

Could You Lose Medicaid for Missing Paperwork Even if You Qualify?

Yes. This is the biggest practical risk. Common problems include:

Wage or employment data that does not appear in state databases.
Outdated addresses and notices that never arrive.
Missing records of volunteering or school enrollment.
Medical or caregiving exemptions that are not recorded.
Processing delays after you submit documents.

Under the CMS rule, if a state cannot confirm that you comply or are exempt, it generally must send a notice and give you 30 calendar days to show compliance or an exemption before denying or ending coverage. Update your contact information now and answer every Medicaid notice quickly.

What Happened When Arkansas Tried Medicaid Work Requirements in 2018?

Arkansas applied a work requirement in 2018 under a Section 1115 waiver, and roughly 18,000 people lost coverage in a matter of months. A federal appeals court later held that approving the program was unlawful (Gresham v. Azar, 950 F.3d 93 (D.C. Cir. 2020)). The 2026 requirement differs because Congress now requires it by statute, but the Arkansas experience is why paperwork-related coverage loss is the central concern.

Do the Six-Month Medicaid Renewals Also Start Later?

Not necessarily. Section 71107 of Public Law 119-21 separately requires eligibility checks every six months for most expansion adults, starting with renewals scheduled on or after the end of 2026 (confirm your state’s exact start date). CMS’s hold harmless announcement addresses enforcement of the work requirement, and nothing reviewed shows it suspends the six-month renewal rule. Do not ignore a renewal notice because you heard the work rule was delayed.

Can You Lose ACA Marketplace Subsidies if Medicaid Ends Because of the Work Requirement?

Possibly. Under the 2025 law, people who are denied Medicaid or disenrolled for failing the community engagement requirement can be barred from federal premium tax credits for Marketplace coverage. Someone who loses Medicaid for a different reason, such as income, is not subject to that bar on that basis. Compare options at HealthCare.gov or your state’s Marketplace, and ask what reason the notice gives.

What Should You Do if Medicaid Sends a Termination Notice?

Read the notice and find the exact reason, since a work-requirement denial differs from an income, residency or renewal problem.
Note the effective date and the deadline to appeal.
Contact your state Medicaid agency and ask it to review your records.
Send any missing proof of work hours, school enrollment or an exemption.
Request a Medicaid fair hearing if you think the decision is wrong.
Ask whether benefits can continue during the appeal.
Keep copies of every notice, upload and message.

Can Medicaid Continue During a Fair Hearing Appeal?

Often, yes. Under 42 CFR § 431.230, if you request a hearing in time, usually before the effective date of the action, benefits generally continue until the hearing decision, subject to exceptions. Filing after coverage has ended does not automatically restore benefits, and a state may seek recovery of continued benefits if it later wins. Your right to a hearing comes from 42 U.S.C. § 1396a(a)(3), 42 CFR § 431.220 and the constitutional due process principles of Goldberg v. Kelly, 397 U.S. 254 (1970).

Can You Reapply for Medicaid After Losing Coverage for Not Meeting the Work Requirement?

Yes. The state must evaluate you under the rules in effect when you reapply. Reapplying does not guarantee immediate approval or payment for care received while uncovered. Ask the agency to review every Medicaid category you might fit, including disability and pregnancy.

What Federal Laws and Rules Govern the Medicaid Work Requirement?

Law or rule	Why it matters
Public Law 119-21, § 71119	Creates the federal Medicaid community engagement requirement
42 U.S.C. § 1396a(xx)	Defines who is covered, qualifying activities and exclusions
CMS interim final rule (June 3, 2026)	Implements verification, notice and exemption procedures
Public Law 119-21, § 71107	Requires six-month eligibility checks for many expansion adults
42 U.S.C. § 1396a(a)(3), 42 CFR § 431.220	Guarantee a fair hearing
42 CFR § 431.230	Continued benefits during certain appeals
5 U.S.C. § 706 (Administrative Procedure Act)	Lets courts set aside agency action that exceeds the statute
Goldberg v. Kelly, 397 U.S. 254 (1970)	Due process before termination of public benefits

Massachusetts v. Oz shows that an agency cannot add restrictions beyond the authority Congress granted.

Can Congress Repeal or Delay the Medicaid Work Requirement in 2027?

Yes, but only by passing new legislation that survives a presidential signature or veto. Reporting by Nextgov/FCW says Democrats, who are expected to take control of Congress in January, will likely try to repeal the requirement. A change in congressional control does not repeal an existing law by itself, and the current statute and CMS guidance apply until the law changes or a court rules otherwise.

What Should Medicaid Enrollees Do Before January 1, 2027?

Confirm your address, phone and email in your state Medicaid account.
Find out whether you are in a group the requirement covers.
Keep pay stubs, volunteer logs and school records.
Gather proof of any medical condition or caregiving role that supports an exemption.
Keep sending renewal paperwork and answering every notice.
Call your state Medicaid agency, a navigator or legal aid if you are unsure.

Medicaid Work Requirement Delay FAQ

Did Trump cancel the Medicaid work requirements?

No. CMS announced an optional six-month enforcement grace period. The federal requirement remains in place.

When do Medicaid work requirements start now?

The requirement begins January 1, 2027. States that opt in can wait until July 1, 2027 to deny or end coverage solely for failing it. Early-implementing states may differ.

Can I lose Medicaid in January 2027?

Yes, depending on your state and the reason. The hold harmless period covers only terminations solely for noncompliance with the work requirement.

Who has to work 80 hours a month for Medicaid?

Mainly non-pregnant adults ages 19 to 64 in the ACA expansion group and certain 1115 waiver groups, unless exempt.

Are parents exempt?

Parents and caregivers of a child age 13 or under are generally excluded.

Are people with disabilities exempt?

Many are, either because of their eligibility category or the medically frail exclusion. It depends on your category and your state’s verification process.

Are seniors exempt?

Yes. The adult requirement does not apply to people 65 and older.

Do I have to report my hours every month?

Not necessarily. States must verify at application and at renewal and may check more often. Follow your state’s instructions.

Can I appeal a Medicaid termination?

Yes. Request a fair hearing quickly and ask about continued benefits while it is pending.

Does the delay affect SNAP?

No. SNAP work rules are governed separately.

Is the July 2027 date guaranteed?

No. Congress, CMS or the courts could change the rules.

Official Sources and Where to Get Help With Medicaid

Bottom line: CMS’s six-month hold harmless period can protect otherwise eligible adults in states that opt in from losing Medicaid solely for failing the work requirement before July 2027. The 80-hour requirement is not repealed, each state chooses for itself, and other eligibility rules and the separate six-month renewals still apply. Enrollees should check their exemptions, keep their records and contact information current and answer every Medicaid notice.

This is a developing story, and state decisions, CMS guidance and court rulings may change. This article provides general legal information, not legal advice. Medicaid rules vary by state.

Researched and written by Israr Ahmad, legal content researcher and founder of AllAboutLawyer.com. All facts verified against CMS’s November 13, 2026 announcement as reported by NBC News, Nextgov/FCW, Fierce Healthcare and The Hill, the October 29, 2026 opinion in Massachusetts v. Oz as reported by the Associated Press and others, and Public Law 119-21, as of November 14, 2026. Last Updated: November 14, 2026.

About the Author

Israr Ahmad is a legal content researcher with 4+ years of experience covering class action settlements and consumer rights cases. He has researched and published coverage of 2,500+ settlements using verified court records, settlement administrator filings, and government sources. Learn more about Israr.