Starting in January 2027, the federal government will begin enforcing new requirements for people who get their health insurance through Medicaid. These changes could affect millions of people who are on Medicaid. This includes many people with disabilities.
This resource explains what the Medicaid work requirements mean and how this new policy will be rolled out.
What this explainer does:
- Breaks down what these rules are
- Who is not affected by these new rules
- What disabled people and their families need to know to prepare for these changes
What is happening?
In July of 2025, Congress passed a law called H.R. 1. This law is more commonly known as the “One Big Beautiful Bill Act”. H.R. 1 decreased funding for Medicaid and required changes to how Medicaid functions. It also added work reporting requirements to specific states. The states who need to meet new work requirements are the states that expanded their Medicaid program under the Affordable Care Act. The Affordable Care Act is also known as “Obamacare.”
“Work requirements” are also called “work reporting requirements” or “community engagement requirements.” All of these terms mean the same thing: a policy that requires people who are on Medicaid to work. This doesn’t always have to be a job. It can also be studying, volunteering, or other professional training. People who are on Medicaid are required to report the hours they worked to the government. They must do this to keep receiving Medicaid health insurance.
There are some states that do NOT have these new work requirements. If you live in one of these states, this does not apply to you, because these states did not participate in Medicaid expansion.
The states that don’t have work requirements are::
- Alabama (AL)
- Florida (FL)
- Kansas (KS)
- Mississippi (MS)
- South Carolina (SC)
- Tennessee (TN)
- Texas (TX)
- Wyoming (WY)
The government is still deciding how these work requirements will apply in:
- Wisconsin (WI)
- Georgia (GA)
These requirements are supposed to take effect on January 1, 2027. Some states may need to begin these requirements earlier. For example, Nebraska’s requirements take effect on May 1, 2026.
States that are adopting work requirements must tell people who rely on Medicaid about the changes and what will be required of them as individuals. States have to provide this information no later than September 30, 2026.
AAPD strongly opposes work requirements and these changes to Medicaid. Work requirements have a long history of causing people to lose coverage. This will affect many people with disabilities.
What are the new Medicaid work reporting requirements?
Under these new rules, many people who rely on Medicaid need to report work hours. These can also be volunteer hours, education, or training. People who must work to stay on Medicaid will be required to report 80 hours a month to keep their Medicaid coverage.
Here is a list of things that you can report. These are called “qualifying activities.”
- Paid employment
- Enrollment in an educational program. This can include:
- such as a certificate program,
- technical program,
- or degree program, at least half-time (6 credits)
- Participation in job training or workforce development programs
- Community volunteering
You need these requirements to keep Medicaid coverage. If you do not meet them or do not report correctly, you may lose coverage.
Who will be affected?
People on Medicaid will need to report their work hours regularly to keep their coverage. These work requirements can include activities other than a job. These activities can include education or volunteer work, for example.
Work requirements apply to many adults between the ages of 18 to 64 years old who receive Medicaid. However, many groups of people will be “exempt” from these requirements. If you are exempt, that means you do not need to report hours at all.
Many people with disabilities, and people who care for people with disabilities, are supposed to be exempt from work requirements. A full list of who is exempt is in the next section.
As a reminder, these new work requirements do NOT apply to anyone who lives in one of the following states:
- Alabama (AL)
- Florida (FL)
- Kansas (KS)
- Mississippi (MS)
- South Carolina (SC)
- Tennessee (TN)
- Texas (TX)
- Wyoming (WY)
The government is still deciding how these work requirements will apply in:
- Wisconsin (WI)
- Georgia (GA)
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 both Medicaid and Medicare at the same time
- 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 from work requirements 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
Different states have different definitions of disability. Because of that, some people with disabilities may be exempt in one state, but people who have the same disability may not be exempt in another state. AAPD is watching this issue closely.
People with serious health conditions
The law says you are exempt if you have a serious or complex medical condition. These include mental health disabilities and substance use disorders. But, there is no definition for “complex medical condition”. So, each state has to determine who qualifies under this exemption.
For substance use disorders, the exemption applies whether you are receiving treatment or not. But to qualify for this exemption, you do need to show proof of diagnosis.
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. But, AAPD is concerned that this process will still create confusion and barriers. People could receive incorrect information from their state. Especially as states work to figure out how to put these requirements in place.
What does this mean for disabled people?
AAPD strongly opposes Medicaid work requirements. They do not increase employment in a meaningful way. They create unnecessary barriers to health care. Work requirements can still be harmful. Even if most disabled people are exempt.
We are especially concerned about several possible problems:
- States use confusing definitions for exemptions. This means many people who are exempt may not even realize it.
- 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
Work requirements have been tried in some states before. WMany individuals in those states lost health insurance coverage due to many problems, like:
- 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 can be devastating. Even if it’s only temporary. Medicaid pays for medicines. It also pays for personal care services and other supports that disabled people rely on.
AAPD believes health care should never be at risk due to administrative problems. We are urging federal and state agencies to make excemptions broad and automatic. This means that they will include as many people as possible. This would also mean that exemptions do not need to be applied for.
When do these changes start?
The changes will not start right away. Federal officials are expected to release detailed rules in June 2026. These rules — also called “regulations” — are to explain how these new requirements will work.
States will begin telling people on Medicaid about the new rules in fall 2026. This will include how to report hours and how to claim an exemption. The requirements are scheduled to take place on January 1, 2027.
What should I do right now?
Right now, 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. This includes:
- Documentation of medical diagnoses,
- Paystubs,
- SSI and SSDI benefit letters, and/or
- Proof of enrollment in an educational or job training program
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.
AAPD is working hard to make sure that people with disabilities are exempted automatically. This also includes individuals with disabilities who currently receive some kinds of benefits. Examples of these benefits include:
- SSI,
- SSDI,
- or Home- and Community-Based services
States can use existing benefit information to automatically exempt disabled people.
AAPD urges 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
- Use as little paperwork as possibkle
- 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.
- You should prepare now by getting your paperwork in order.
- AAPD is fighting to make sure exemptions are automatic, accessible, and easy to qualify for. We will continue to advocate for the disability community to protect access to health care.