Medicaid work requirement scenarios

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Scenario 1: Medicaid recipient working

Meets requirements

Elena is a 42-year-old female from Lexington, Kentucky. She receives Medicaid and works as a part-time receptionist at a local dental clinic. She earns about $19,000 per year, which places her well within her state’s eligibility for Medicaid expansion. As part of the new Medicaid work requirements, Elena must document 80 hours of community engagement per month.

Elena has a set schedule of 22 hours per week at the dental clinic, making her monthly total approximately 88 to 92 hours, depending on the month. Because her employment exceeds the 80-hour threshold, she satisfies the requirement through paid work alone.

Each month, Elena logs into the state’s online reporting portal to submit her work hours. She reports her employer information and hours worked and retains pay stubs in case of an audit. Because she consistently meets the requirement, she remains in good standing and maintains her coverage.

Note: Elena also meets the requirement because she earns more than $580 per month (for 2026)

Scenario 2: Medicaid recipient working

Does not meet requirements

Marcus is 34 years old and lives in Portland, Maine. He is enrolled in Medicaid through expansion and works part-time as a delivery driver and helps his uncle with his flooring business when he can. As an adult without a dependent child age 13 or younger (or a disabled family member in his care), Marcus is subject to the new 80-hour monthly community engagement rule.

To maintain his health coverage, Marcus must prove he spends at least 80 hours per month in one or a combination of paid employment, community service, job training, or education.

Marcus experienced some car trouble during the month, so he was only able to log 4 days of delivery work. There was also a seasonal slowdown at the flooring company, so his uncle was not able to offer him any additional hours.

Between his two jobs, Marcus logs 32 hours of work. He is 48 hours short of the 80-hour threshold.

Marcus submits his 32 hours of work and asks whether the hours he spent searching and applying for a full-time job can count toward the rest. The Medicaid agency explains that job search is not one of the qualifying categories; only paid employment hours, community service, an approved work program, or education count towards the 80 hours. His submission still falls 48 hours short. Marcus receives a “Notice of Non- Compliance,” which outlines steps available under the state policy to regain compliance or appeal the determination.

Why Marcus didn’t meet the requirements:

Job search on its own isn’t listed as a qualifying activity. Check your state’s requirements for more information.

Scenario 3: Meets through an avenue besides employment

28-year-old Jordan lives in Wise, Virginia. He is a Medicaid Expansion Recipient who previously worked in retail but lost his job when a local department store closed in late 2025. Wanting to try something new, Jordan enrolled in a Certified Nursing Assistant (CNA) program at a local community college to transition into healthcare. The program is less than half-time enrollment, so Jordan can’t meet the requirement through education alone.

Jordan must ensure his combined hours meet the 80-hour monthly threshold. He is in the classroom and in clinicals for 15 hours per week (approximately 60 hours/month). To bridge the 20-hour gap, Jordan volunteers at a local Senior Center 5 hours every Saturday (approx. 20 hours/month). Jordan keeps records of class schedules and a signed log of volunteer hours in case of an audit. Because Jordan consistently reports qualifying activities totaling at least 80 hours, he remains compliant and retains Medicaid coverage.

Scenario 4: Not participating in the work requirements

Sarah, age 51, lives in Cincinnati, Ohio, and is a Medicaid Expansion Recipient. Sarah is a former community health worker who has recently been diagnosed with Multiple Sclerosis and depression. While she has periods where she feels capable of light work, her “flares” are unpredictable and can leave her bedridden for weeks. She does not currently receive federal Social Security Disability Insurance (SSDI) because her application process is pending appeal.

Under H.R. 1, expansion adults must meet a community engagement requirement unless they qualify for an exemption. One mandatory exemption covers people who are medically frail or have special medical needs, including:

  • People who are blind or disabled
  • People with a substance use disorder
  • People with a disabling mental disorder
  • People with a physical, intellectual, or developmental disability that significantly impairs their ability to perform one or more activities of daily living
  • People with a serious or complex medical condition

Sarah and her medical provider submit medical documentation to the state confirming her condition. Once approved, she is exempt from the community engagement requirement and is not required to report monthly hours.

The state will recheck her eligibility at renewal, which will happen at least every six months for expansion adults.

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