On Friday 13 November 2026, the Centers for Medicare and Medicaid Services told states they can delay enforcing Medicaid work requirements for up to six months, through 30 June 2027. During that "hold harmless" period, no one in a participating state should lose coverage just for failing to show they meet the requirements.
It is a significant change, but it is narrower than many headlines suggest. The requirements themselves still begin on 1 January 2027, states must still check eligibility, and the delay is optional.
The short version
- What: an optional six-month hold-harmless period for enforcing Medicaid work requirements.
- Until: 30 June 2027. Some outlets report it as 1 July; coverage losses would begin from July at the earliest.
- State deadline: states must tell CMS by 11 December 2026 if they will use it.
- Still starting 1 January: the requirement itself, and states' duty to verify it.
- The rule: many adults covered through Medicaid expansion must work, volunteer or do job training at least 80 hours a month, or be in school at least half-time.
- Why now: states sued over the rules, and a federal judge struck down the federal definition of "medically frail".
What exactly did CMS announce?
CMS is offering states a choice. A state that opts in must still:
- check whether each person meets the work requirement or qualifies for an exemption
- keep working towards "full compliance with the statute"
But it may suspend denials and disenrolments for otherwise eligible people who do not demonstrate that they meet the requirements. In practice, KFF says, many people who would have been blocked from enrolling or removed from coverage could temporarily get and keep Medicaid.
States that follow their mitigation plans also avoid formal compliance action and penalties for higher eligibility error rates, which the 2025 reconciliation law had made a real financial risk for them.
Key dates
| Date | What happens |
|---|---|
| 13 November 2026 | CMS announces the optional delay |
| 11 December 2026 | States must notify CMS if they will use it |
| 1 January 2027 | Work requirements take effect in 43 states and DC |
| 3 January 2027 | New Democratic Congress sworn in |
| 30 June 2027 | Hold-harmless period ends in opting-in states |
Who has to meet Medicaid work requirements?
Under the 2025 law, the rules apply to most adults covered through the Medicaid expansion, generally those aged 19 to 64 who are not otherwise exempt. The requirement is 80 hours a month of work, community service, a work programme, or at least half-time education, or a combination.
The law includes exemptions, among them for pregnant women, parents and caregivers of young children or disabled people, and people who are medically frail. That last category is where the legal fight has been.
What did the court ruling on "medically frail" change?
A federal judge struck down a key part of CMS's interim rule, which had required people to prove that their health condition limits their ability to work. States now only need to verify that a person's condition falls into one of the five medical frailty categories written into the statute. That is a lower bar, and it should make exemptions easier to get.
Does this affect ACA marketplace coverage?
Yes, indirectly. Adults who are denied or removed from Medicaid solely for failing the work requirements are not eligible for premium tax credits on the marketplace, according to KFF. During the hold-harmless period, fewer people should be in that position. See our guide to ACA open enrollment 2027.
Will Democrats repeal the work requirements?
Democrats, who take control of both chambers on 3 January, have said they want to roll the requirements back. But repeal needs the President's signature or a two-thirds override, and President Trump supports the rules. Realistically, the next six months will be shaped more by court cases and state choices than by Congress. See what the Democratic Congress can and cannot do.
What should I do if I am on Medicaid?
- Find out whether your state is opting in. Your state Medicaid agency's website will say, and states must decide by 11 December.
- Report anyway. The delay protects people who do not show they meet the rules. It does not stop states asking. Responding keeps your record clean when enforcement starts.
- Check whether you are exempt. The new medical frailty standard is easier to meet. If you have a qualifying condition, ask for the exemption now.
- Keep records of hours worked, volunteering or school enrolment.
- Watch your mail. Most coverage losses in past renewals happened because notices went to old addresses.
This is general information. Your state Medicaid agency is the authority on your coverage.
What it means for employers
If you employ hourly workers in a state with work requirements, expect more requests for hours confirmations and pay records from 1 January. A simple, consistent way to provide them, ideally straight from payroll, will save your managers time and protect your staff's coverage.
Frequently asked questions
Are Medicaid work requirements delayed?
States can choose to delay enforcement for up to six months, until 30 June 2027. The requirements still take effect on 1 January 2027.
When do Medicaid work requirements start?
1 January 2027 in 43 states and DC. In states that opt into the hold-harmless period, no one loses coverage for failing to report until after 30 June 2027.
How many hours do you need to work for Medicaid?
At least 80 hours a month of work, volunteering or job training, or at least half-time school enrolment, unless you are exempt.
Who is exempt from Medicaid work requirements?
Exemptions include pregnant women, certain parents and caregivers, and people who are medically frail, among others. Check your state's list.
Sources
KFF on the optional delay; STAT News; NBC News; ABC News; Modern Healthcare; KFF 2027 open enrollment for state count and marketplace interaction. As of 15 November 2026.
