New Medicaid work reporting requirements are scheduled to begin in January 2027. These changes could affect millions of people who rely on Medicaid, including many people with disabilities.
This explainer breaks down what the new rules require, who is exempt, and what disabled people and their families should know right now to prepare for these changes.
What is happening?
In July 2025, Congress passed legislation (H.R. 1, or the “One Big Beautiful Bill Act”) that added work reporting requirements to Medicaid in states that expanded their Medicaid program under the Affordable Care Act of 2010.
Work reporting requirements, also known as “work requirements,” are when Medicaid recipients are required to work, receive professional training, study, or volunteer. These recipients must then report their working hours to Medicaid to continue receiving Medicaid health coverage.
Work requirements can also be called “community engagement requirements,” and it is important to remember that “work requirements” and “community engagement requirements” may be used interchangeably.
These new work requirements do NOT apply if you live in Alabama, Florida, Kansas, Mississippi, South Carolina, Tennessee, Texas, or Wyoming, because these states do not participate in Medicaid expansion programs. The federal government is still determining if and how these requirements will apply in Wisconsin and Georgia.
These requirements are scheduled to take effect on January 1, 2027. Some states, like Nebraska, may begin to comply with these requirements earlier. States must contact Medicaid recipients no later than September 30, 2026, about any changes or new requirements that they must meet.
AAPD, other disability advocacy organizations, and allies of the disability community strongly opposed this policy change. Work requirements have a long history of causing eligible people, including people with disabilities, to lose coverage because of paperwork problems, confusing notices of requirements, and administrative errors.
What are the new Medicaid work reporting requirements?
Under the new rules, many Medicaid recipients between the ages of 18 and 64 will be required to report work, training, education, or volunteer hours each month. These individuals must report at least 80 hours per month of qualifying activities in order to maintain their Medicaid coverage.
Qualifying activities may include:
- Paid employment
- Enrollment in an educational program, such as a certificate, technical, or degree program, at least half-time
- Participation in job training or workforce development programs
- Community volunteering
If someone who is required to report does not meet these requirements or does not complete the reporting process correctly, they could lose Medicaid coverage.
Who will be affected?
The requirements apply to many adults between the ages of 18 to 64 who receive Medicaid. Medicaid recipients will need to regularly report their work, education, or volunteer hours in order to keep their health coverage, unless they meet the requirements to qualify for an exemption. However, many groups of people, including people with disabilities and people who care for disabled family members, will be exempt from these new requirements.
These new requirements do NOT apply if you live in Alabama, Florida, Kansas, Mississippi, South Carolina, Tennessee, Texas, or Wyoming, because these states do not participate in Medicaid expansion programs. We do not yet know if these requirements will apply if you live in Georgia or Wisconsin.
It is important to remember that many disabled people will not need to report work hours at all.
Who is exempt from the new requirements?
Many categories of people should be protected from work requirements.
You should NOT be required to report work hours if you fit into any of the following categories:
- People with disabilities
- People with serious health needs
- Caregivers
- People who are pregnant or receiving postpartum Medicaid coverage
- People who are on Medicaid and Medicare
- American Indians and Alaska Natives
- Veterans with a disability rated “total” by the Department of Veterans Affairs
People with disabilities
The law explicitly says that you are exempt if you receive Supplemental Security Income (SSI).
The law also includes other exemptions based on a broad definition of disability. Using the law’s broad definition, you should also be exempt if you:
- Receive Social Security Disability Insurance (SSDI), or
- Receive services through a Medicaid Home- and Community-Based Services (HCBS) waiver
States may define disability differently, so some people with disabilities may be exempt in one state, while people with the very same disabilities in a different state may not be exempt. AAPD is watching this issue closely.
People with serious health needs
The law says you are exempt if you have serious or complex medical conditions, a mental health disability, or a substance use disorder. However, there is no standard definition for complex medical conditions, so it will be up to each state to determine who qualifies under this exemption.
For substance use disorders, this exemption applies whether or not you are currently receiving treatment for these conditions. You must provide evidence of a diagnosis of a mental health disability or a substance use disorder to qualify for those exemptions.
Caregivers
You are exempt if you:
- Provide care for a child under age 14
- Provide care for a relative of any age who has a disability
Other exempt groups
The following groups are also exempt from reporting requirements:
- People who are pregnant or receiving postpartum Medicaid coverage
- People enrolled in both Medicare and Medicaid
- American Indians and Alaska Natives
- Veterans with a disability rated “total” by the Department of Veterans Affairs
These exemptions are meant to protect many disabled people and caregivers. However, AAPD is concerned that the exemption process could still create confusion and barriers. People could also receive incorrect information from states, as state Medicaid agencies work to figure out how to administer these new requirements.
What does this mean for disabled people?
AAPD strongly opposes Medicaid work requirements because they do not meaningfully increase employment and instead create unnecessary barriers to health care. Even though many disabled people are supposed to be exempt, work reporting requirements can still be harmful.
We are especially concerned about several possible problems:
- Many qualified individuals may not realize they meet the requirements for an exemption because states may use confusing definitions
- People who qualify for exemptions may still be required to complete complicated paperwork
- Disabled people could lose coverage due to confusion or processing errors
- State reporting systems may not be fully accessible
In other states and programs where similar requirements have been tried, people have lost coverage because of problems such as:
- Confusing forms and notices
- Difficulty proving an exemption
- Online reporting systems that are not accessible
- Missed mail or address changes
- Processing delays and state agency errors
Losing Medicaid, even temporarily, can be devastating. Medicaid pays for medications, personal care services, mental health treatment, and other supports that many disabled people rely on every day.
AAPD believes that health care should never be put at risk because of paperwork problems or administrative hurdles. AAPD is urging federal and state agencies to make exemptions as broad and automatic as possible so that no one loses coverage unfairly.
When do these changes start?
The changes will not begin immediately.
Federal officials are expected to release detailed regulations in June 2026 explaining how the requirements will work. In fall 2026, states will begin notifying Medicaid recipients about the new rules and how to report hours or claim an exemption. The requirements are scheduled to officially take effect on January 1, 2027.
What should I do right now?
At this time, you do not need to report hours or submit new paperwork.
For now, there are some simple ways to prepare for these changes:
- Keep your contact information up to date with your state Medicaid agency
- Pay attention to any future mail or notices from Medicaid
- Learn whether you are likely to qualify for an exemption
- Follow trusted information from AAPD and other disability organizations
- Know how to access important information, including: documentation of medical diagnoses, paystubs, SSI and SSDI benefit letters, or proof of enrollment in an educational or job training program, so that you can provide that information if needed. AAPD and allied organizations are working to ensure that individuals with disabilities who currently receive SSI, SSDI, or home- and community-based services are exempted automatically using existing benefits data.
If you receive a notice in the future and are unsure what it means, consider contacting your state Medicaid office, a local legal aid organization, or a disability rights organization in your state for help.
What is AAPD doing about this?
AAPD is actively advocating to protect disabled people from the harmful effects of these new requirements.
We urge federal officials to require states to take several important steps:
- Automatically grant exemptions to anyone already identified as disabled in existing Medicaid or SSI records
- Use simple and accessible reporting systems
- Use data-matching to automatically qualify people for exemptions
- Minimize paperwork burdens
- Ensure that no one loses coverage because of confusing or inaccessible processes
- Make disability exemptions as broad as possible
- Meet with Medicaid recipients, people with disabilities, and caregivers to better understand their concerns and learn what is needed to make reporting as easy and accessible as possible
AAPD is working with allied organizations to monitor how states implement these rules and to support disabled people who may be affected.
Learn more and stay informed
AAPD will continue to share updates as more details become available.
As the January 2027 start date approaches, AAPD will provide additional information, resources, and guidance to help people maintain Medicaid coverage and further understand the impact of this change.
In Summary
Many disabled people will be exempt from Medicaid work reporting requirements, but confusing paperwork, different state definitions, and state systems could still put coverage at risk.
These changes do not take effect until 2027.
AAPD is fighting to make sure exemptions are automatic, accessible, and easy to qualify for. We will continue to stand with the disability community to protect access to health care.