Amid all the controversy regarding the crafting and eventual passage of President Trump’s signature piece of legislation, dubbed “One Big Beautiful Bill,” perhaps the most contentious issue concerned proposed new work requirements for those receiving medical coverage through Medicaid. Now that the bill is law, we’re getting a clearer picture of just what those requirements entail. 

While Medicaid plans are administered at the state level, they operate with a large amount of federal oversight and direction. That’s why, no matter where a Medicaid beneficiary lives, these stipulations are bound to have an impact. The work requirements cover those between the ages of 19 and 64, so while they don’t affect older retirees or those receiving long-term care through Medicaid, they will definitely change things for a large number of low-income able-bodied adults. 

For our look at this topic, we’re relying on  this analysis provided by NAELA – the National Academy of Elder Law Attorneys. 

New Work Requirements Change the Medicaid Picture 

Until the new law took effect, low-income adults receiving medical benefits through Medicaid weren’t generally subject to work requirements (except for a few state programs). But now all that has changed. 

“The law puts into place work requirements of 80 hours a month as a condition of eligibility for Medicaid beneficiaries ages 19-64 in the ACA expansion group,” says NAELA.  This refers to people who gained coverage in recent years through the Affordable Care Act as the majority of states expanded enrollment in Medicaid programs.  

In many states today, Medicaid-related programs such as Apple Health in Washington State provide medical coverage to otherwise uninsured adults. Apple Health presently covers about 2 million Washington beneficiaries including children and seniors. 

The reason for the new work requirements is simple: money. The Congressional Budget Office projects that work requirements alone will cut Medicaid spending by $326 billion over the coming decade.  Most of that saving, says CBO, will come from working adults losing Medicaid coverage.  

Work Requirements Come with a List of Exemptions 

According to NAELA, the new rules are straightforward – at least, on the surface. 

“To comply with the law, an individual must spend 80 hours a month working,” says the report. If self-employed, they need to show an income representing at least 80 hours per month times the minimum wage. 

But there are exemptions. These include people participating in community service, vocational training, educational programs, or a combination of these. Parents and caretakers of children under 14 years old are also exempt, as are those caring for the disabled. People with medical conditions (including the “medically frail”), disabilities, or substance use disorders don’t have to comply, nor do those who are pregnant. 

Work Requirements May Take Effect Sooner Than Required 

“Under the law,” the NAELA report explains, “states must implement work requirements by January 1, 2027. However, states may choose to implement work requirements earlier.” HHS has been given $200 million to help states get their systems up and running. 

But that money may prove inadequate. NAELA notes that work requirements have been attempted before, and have proven tough to launch. Georgia is presently the only state with work requirements in place, and that state has already spent more than $26 million to implement its program – which is now being suspended to comply with the OBBBA rules. 

How Beneficiaries Should Prepare for Medicaid Work Requirements 

In reviewing other sources to examine this issue more thoroughly, we came across this simple but helpful article on a website called Propel. Among other information, the Propel analysis, written by writer Emma Diehl, includes an important list of things you should do now if you expect your Medicaid benefits will be affected by work requirements. We’re including these points verbatim. 

Make sure your contact information is up to date. Confirm with your state Medicaid office that they have your correct email, phone number, and mailing address. This makes sure renewal notices or information about work requirements will get to you. 

Check your mail. Notices about work requirements or renewal could come with short deadlines. Continue to check your mailbox to make sure you don’t miss updates. 

Apply for exemption if you qualify. If you fall into any of the exemption categories outlined above, reach out to your Medicare office today to learn more. 

Plan for work requirements. If you’ll need to meet the work requirements to qualify for Medicaid, start planning now. Consider finding work, education, or volunteer opportunities near you. 

Start tracking hours or income. Track hours or income that you make through paid opportunities or volunteering. Begin getting in the habit of getting a sign-off from a supervisor or work contact for the hours completed. You’ll likely need this type of documentation when Medicaid work requirements are instituted. 

Contact your state office with any questions. Medicaid work requirements may have different deadlines across different states. If you have questions around qualified work or exemptions, reach out to your state Medicaid office as soon as you can. As deadlines draw nearer, it may be harder to reach someone quickly. 

What the Professionals Say: Tips from NAELA 

Apart from the Propel list above, there are other recommendations in the NAELA article that we offer for your review. 

Collect documents. NAELA says now is the time to gather the documents you’ll need to show you’re either in compliance with or exempt from requirements. “This may include asking for paperwork from employers or educational institutions, or from doctors verifying that they meet the exceptions for individuals who are ‘medically frail’ or have serious complex medical needs,” the report adds. 

Watch for latest information. According to the NAELA article, the OBBBA requires the HHS Secretary to issue final rules about work requirements by June 1, 2026.  NAELA predicts the first time most people will have to demonstrate compliance will be on January 1, 2027. Remember, too, that each state will be issuing its own rules and timelines. 

Expect some confusion. NAELA warns that the implementation of the new regulations is bound to come with some annoyances and hiccups. When Georgia (and also Arkansas) tried to implement Medicaid work requirements, thousands of people ended up being kicked off Medicaid rolls, says NAELA. The reasons: “onerous reporting requirements, lack of communication about the need to participate, technology challenges for enrollees, questions about who needs to enroll, and failure to provide documentation of an exemption.” 

We’ll keep our Blog readers posted on this important developing story. 

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(originally reported at www.naela.org)