Trump Administration Imposes Mandatory 80-Hour Work Requirements on Medicaid Beneficiaries

By Sally Pipes
Monday, 22 June 2026 11:05 AM EDT

The Trump administration just released a new rule making clear that Medicaid’s work requirements are just that — requirements.

Beginning in 2027, able-bodied adults who gained Medicaid coverage through Obamacare’s expansion of the program will generally need to spend at least 80 hours per month working, studying, participating in job training, or engaging in community service to remain eligible.

The new rule includes guidance on who may be exempt from those requirements for being “medically frail.”

Critics argue the rule is too strict because it does not automatically exempt broad categories of beneficiaries based solely on their condition or diagnosis.

The rule is designed to ensure that the medical-frailty exemption remains a safeguard for the truly vulnerable rather than a loophole that undermines Medicaid’s integrity and drains resources from those most in need.

The need for stronger safeguards is urgent given how far Medicaid has drifted from its original purpose.

Congress established the program in 1965 to serve low-income children, seniors, and people with disabilities.

Obamacare dramatically expanded Medicaid by extending coverage to working-age adults with incomes up to 138% of the federal poverty level — a group that now accounts for nearly one-fourth of all beneficiaries nationwide.

Obamacare also created a powerful financial incentive for states to prioritize expansion enrollees.

Washington covers 90% of their costs.

For many traditional Medicaid beneficiaries, the federal contribution is far lower.

A broad definition of medical frailty would allow states to keep more expansion beneficiaries on the rolls — and preserve the flow of federal dollars attached to them.

The requirements themselves are modest.

Beneficiaries generally need to devote about 20 hours a week to work or other qualifying activities in exchange for taxpayer-financed health coverage.

A beneficiary earning just $580 a month — the equivalent of 80 hours at the federal minimum wage — is automatically deemed compliant.

If they can earn that sum with fewer hours of work, then they need not log all 80 hours.

Nudging more people into the workforce can be beneficial for them — and for society.

According to a recent analysis from the Department of Health and Human Services (HHS), Medicaid work requirements could increase family income by more than $12,000 and lift between 1.6 million and 2.9 million people out of poverty.

Of course, people whose health conditions prevent them from complying with the requirements should not lose Medicaid coverage.

The new guidance allows states to exempt medically frail beneficiaries from them.

The catch is that they need to verify their condition.

Medical frailty is about functional limitation, not diagnosis.

People experience illnesses differently. Some conditions are debilitating. Others are well-managed or improve over time.

If certain diagnoses automatically triggered exemptions, states could effectively exempt large portions of the expansion population from the policy — and keep the generous federal funding attached to those beneficiaries.

That appears to be what many states were hoping for.

Prior to CMS issuing its guidance, analysts at the Foundation for Government Accountability found that at least 29 states planned to allow beneficiaries to self-attest to medical frailty.

In some cases, individuals could have secured an exemption without providing meaningful evidence that their condition limited their ability to work, study, volunteer, or participate in job training.

That approach would have invited abuse and undermined the purpose of the law.

Medicaid already struggles with weak eligibility verification and improper payments. Federal officials admit that the program made more than $37 billion in improper payments, many tied to documentation and eligibility problems, in 2025 alone.

Medicaid should be compassionate and accountable.

The truly vulnerable should be protected.

But states should not be allowed to convert the medical-frailty exemption into a backdoor mechanism for nullifying work requirements.

The administration’s rule helps ensure that exemptions are reserved for beneficiaries who truly need them — and redirects Medicaid’s resources toward the vulnerable populations it was created to serve.

Sally C. Pipes is President, CEO, and Thomas W. Smith Fellow in Healthcare Policy at the Pacific Research Institute. Her latest book is “The World’s Medicine Chest: How America Achieved Pharmaceutical Supremacy — and How to Keep It.”