In 2025, Congress passed a sweeping federal spending law widely referred to as the “One Big Beautiful Bill Act” (H.R. 1). Among its many provisions are significant changes to the Medicaid program, including the introduction of nationwide work requirements for many Medicaid recipients.
States must implement these requirements by January 1, 2027, although some states may begin earlier.
For older adults approaching retirement age and for families who rely on Medicaid for health coverage, these changes could have important consequences. As elder law attorneys, we are closely monitoring these developments and helping clients understand how the new rules may affect their access to health care coverage.
Below is what we know so far.
Who Will Need to Meet Medicaid Work Requirements?
Under the new law, most Medicaid enrollees between the ages of 19 and 64 will need to demonstrate that they are participating in work or community engagement activities to maintain eligibility.
To remain eligible, individuals must complete at least 80 hours per month of qualifying activities, which may include:
- Paid employment
- Volunteering or community service
- Job training programs
- School attendance (at least half-time)
- A combination of these activities
Individuals must document their participation before enrolling in Medicaid or during eligibility renewals. The law requires reporting at least every six months, though states may require reporting more frequently.
Failure to comply could lead not only to loss of Medicaid coverage but also ineligibility for health insurance subsidies through the federal marketplace.
Who Is Exempt from the Work Requirements?
Fortunately, several categories of individuals are exempt from the new requirements and will not need to report work or engagement hours.
Mandatory Federal Exemptions
The law generally exempts individuals who fall into the following categories:
- Adults over age 65
- Individuals under age 19
- People who are dually eligible for Medicaid and Medicare
- Individuals who are aged, blind, disabled, or medically frail
- Pregnant or postpartum individuals
- Parents or caregivers of a dependent child age 13 or younger
- Caregivers of a disabled individual
- Foster youth or former foster youth under age 26
- Veterans with a total disability rating
These exemptions are particularly important for many older adults who rely on Medicaid alongside Medicare for long-term care or medical expenses.
Possible State-Level Hardship Exemptions
States may also provide temporary hardship exemptions in certain situations, including:
- Hospitalization or residence in a nursing facility
- Living in areas with high unemployment rates
- Living in federally declared disaster areas
- Traveling outside the community for serious medical treatment
Each state will have discretion in how it implements and evaluates these hardship exceptions.
Why Advocates Are Concerned
Supporters of Medicaid work requirements argue that they encourage employment and community engagement. However, many health policy experts and advocacy organizations, including Justice in Aging, have raised concerns about the potential impact.
Experience from states that previously tested Medicaid work requirements, such as Arkansas and Georgia, suggests that many individuals lost coverage not because they were unwilling to work, but because of reporting and administrative barriers.
Common challenges include:
- Confusing paperwork requirements
- Missed reporting deadlines
- Technology barriers for online reporting systems
- Inconsistent state verification procedures
For adults ages 50 to 64, these challenges may be particularly significant.
Why Older Adults May Be Disproportionately Affected
Individuals in their 50s and early 60s often face unique challenges when it comes to employment and health coverage.
Many in this age group:
- Live with chronic health conditions
- Provide care for aging spouses or family members
- Experience age discrimination in the workforce
- Have difficulty performing physically demanding work
Yet this same group often relies heavily on Medicaid for access to consistent health care and prescription coverage.
Even when exemptions are available, qualifying for them may require documentation and verification that can be difficult to obtain.
For example, individuals deemed “medically frail” may qualify for exemptions, but the definition of medical frailty remains somewhat unclear and could vary across states.
What Medicaid Recipients Should Do Now
Although the national work requirements will not fully take effect until 2027, Medicaid recipients should begin preparing now.
Practical steps include:
- Stay informed about your state’s Medicaid rules and timelines
- Keep records of work, volunteer activities, or educational participation
- Respond promptly to renewal notices or reporting requests
- Consult professionals if you believe you qualify for an exemption
Understanding the new rules early can help reduce the risk of unexpected coverage loss.
How Elder Law Attorneys Can Help
Medicaid rules are complex, and the upcoming work requirements may create additional confusion for many individuals and families.
An elder law attorney can help you:
- Understand whether the work requirements apply to you
- Determine if you qualify for an exemption
- Plan for Medicaid eligibility as you approach retirement
- Protect access to long-term care benefits and health coverage
For older adults and caregivers, proactive planning can make a significant difference.
Final Thoughts
The new Medicaid work requirements represent one of the most significant changes to the program in years. While many individuals will be exempt, others may face new reporting requirements that could impact their coverage.
As states begin implementing these rules, staying informed and seeking guidance will be critical to protecting access to essential health care services.
If you or a loved one rely on Medicaid and have questions about how these changes may affect you, the Elder Law attorneys at Mandelbaum Barrett PC can help you to explore your options and safeguard your benefits.