Short answer: No. If you are entitled to or enrolled in Medicare, you are categorically excluded from the new Medicaid work requirements. This exclusion is written directly into the federal statute and confirmed in CMS’s June 2026 interim final rule. Dual-eligible beneficiaries do not need to report work hours, volunteer hours, or school enrollment to keep their Medicaid coverage.
That said, even if you don’t have to report work hours, the changes could still have an inadvertent effect on you. Below is a complete breakdown of what’s changing, who it applies to, why dual-eligible individuals are exempt, and the indirect risks dual-eligible beneficiaries should still watch for.
What Are the New Medicaid Work Requirements?
The Medicaid work requirement, officially called the “Community Engagement Requirement,” comes from the One Big Beautiful Bill Act, or OBBBA. It requires most Medicaid expansion enrollees ages 19 to 64 to document at least 80 hours per month of one or more of the following:
- Paid employment (including self-employment)
- Unpaid or in-kind work
- Participation in a state-run “work program,” such as job training
- Community service
- Enrollment in an educational program at least half-time
- Any combination of the above totaling 80 hours
Instead of hours, a person can also qualify by earning at least 80 times the federal minimum wage in a month ($580/month in 2026).
Key dates:
- CMS issued its interim final rule on June 3, 2026
- States must fully implement the requirement by January 1, 2027
- Some states are moving earlier: Nebraska (May 1, 2026), Montana (July 1, 2026), Arkansas (soft launch July 1, 2026), and Iowa (December 1, 2026)
This is the most significant change to Medicaid eligibility rules since the Affordable Care Act.
Are People With Medicare Subject to the Medicaid Work Requirement?
No. The statute defines who counts as an “applicable individual” subject to the work requirement, and that definition specifically excludes anyone who is “entitled to or enrolled for benefits under Part A” or “enrolled for benefits under Part B” of Medicare.
In plain terms: if you have Medicare Part A, Medicare Part B, or both, you are not an applicable individual under this rule — regardless of whether you also have full Medicaid or the Medicare Savings Program.
This means the work requirement effectively does not apply to:
- Anyone 65 or older (since Medicare eligibility generally starts at 65)
- Anyone under 65 who has Medicare due to a disability
- Anyone with End-Stage Renal Disease or ALS who has Medicare
The work requirement is specifically targeted at the ACA Medicaid expansion population — adults aged 19–64 with income up to 138% of the federal poverty level who qualify for Medicaid through income alone, not through age, disability, or Medicare enrollment.
Quick Reference: Who Is and Isn’t Subject to the Work Requirement
| Population | Subject to Work Requirement? |
| Adults 19–64 in Medicaid expansion group, no exemption | Yes |
| Anyone enrolled in or entitled to Medicare Part A or B | No |
| Adults 65 and older | No |
| People eligible for Medicaid via disability/SSI/ABD pathway | No |
| Pregnant or postpartum individuals | No |
| Parents/caregivers of a child 13 or younger, or a disabled dependent | No |
| Former foster youth under 26 | No |
| American Indian/Alaska Native/California Indian | No |
| Medically frail individuals (narrower CMS definition) | No, if exemption is verified |
What Indirect Risks Should Dual-Eligible Medicare Beneficiaries Still Watch For?
Being exempt from the work requirement itself doesn’t mean Medicare beneficiaries with Medicaid are unaffected by these changes. Here are two potential risks to keep an eye on:
1. More frequent eligibility redeterminations.
The law increases renewal frequency to every six-months for the broader Medicaid expansion population. While Medicare beneficiaries aren’t subject to this renewal timeline, the increased reporting could overburden the state Medicaid offices, delay processing times, and include a general risk of administrative errors.
2. Wrongful disenrollment due to verification system errors.
States are building new eligibility-checking systems on a short timeline — the Center on Budget and Policy Priorities and Urban Institute have both warned that this as a major risk. They worry that automated systems may fail to correctly flag Medicare enrollment. This could be more of an issue for people who are on Medicare due to a disability since their age doesn’t automatically make them exempt.
What Should Dual-Eligible Beneficiaries Actually Do Right Now?
Even though no action is required to satisfy the work requirement itself, three practical steps will reduce risk during this transition:
- Update your contact information with your state’s Medicaid office. There will be a lot of communication coming from Medicaid in the coming months. Make sure your contact information is updated so you receive information promptly.
- Open and respond to any mail from your state Medicaid agency. States are required to send outreach notices to all potentially affected enrollees, and not every notice will clearly distinguish exempt individuals from those who must report hours. Don’t assume a notice doesn’t apply to you.
- Submit your renewal application as soon as you get a notice. Processing delays could affect the timing of your renewal. You typically get your renewal notification a month or two ahead of time, so be sure to submit it as soon as possible to avoid delays or a lapse in coverage.
If you need help navigating your Medicare and Medicaid enrollment, reach out to a friendly, licensed agent who can help for FREE!
Frequently Asked Questions
No. D-SNPs are Medicare Advantage plans designed for dual-eligible individuals, and enrollment in Medicare through any pathway — including a D-SNP — confirms your Medicare status and therefore your exemption from the work requirement.
Yes. Medicare eligibility through disability counts the same as Medicare eligibility through age for purposes of this exclusion.
No. States implementing early are still bound by the same federal statutory exclusion for Medicare recipients.
Hi, My name is Butterfly. I have been a licensed agent for over 10 years. I am contracted and certified to assist Medicare beneficiaries through the Medicare process. I specialized in educating the public about Medicare enrollment rules, timelines, and coverage options. My goals is to help you understand your options and help you avoid common enrollment mistakes that can lead to penalties or gaps in coverage.
