16 September 2026

Medicaid Work Requirements and State Readiness

For states navigating work requirements across Medicaid, SNAP, TANF, and other public benefits

Federal policy is reshaping Medicaid, SNAP, and other public benefit programs. As states redesign eligibility and reporting systems, millions of people will need to navigate new requirements to maintain access to benefits.

For state agencies, legislators, advocates, and community organizations, the challenge is clear: implement these changes effectively while minimizing unnecessary coverage and benefit loss.

AIR combines policy expertise, implementation research, and data-driven insights to help states translate new requirements into effective practice, minimizing unnecessary coverage and benefit loss for eligible individuals.

Understanding the Current and New Requirements

On June 1, 2026, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule implementing Medicaid community engagement (work) requirements for Medicaid expansion for adults ages 19–64. The rule implements provisions required under H.R. 1, the One Big Beautiful Bill Act.

Graphic: Changes in Medicaid Work Requirements Go Into Effect January 1, 2027

The policy affects the 43 states and the District of Columbia that expanded Medicaid under the Affordable Care Act (ACA).
The rule takes effect July 31, 2026 and full implementation is required starting January 1, 2027.
Qualifying activities include employment, education, job training, and volunteer or community service at a minimum of 80 hours per month.
H.R. 1 also includes community engagement provisions affecting SNAP participants. Learn more from CMS: Medicaid Community Engagement Requirement Interim Final Rule.

January 1, 2027, is approaching quickly. States, legislatures, advocates, and community partners have urgent decisions to make about how to implement new work requirements, verify compliance, and avoid unnecessary coverage or benefit loss for people who are working, exempt, or otherwise eligible for benefits.

Graphic: Timeline of Federal Medicaid Work Requirements

What the Evidence Shows: Implementation Matters

What determines whether eligible people keep their benefits? Evidence from Arkansas and Georgia work requirements, the Medicaid Unwinding, and years of SNAP and TANF research points to a clear answer: implementation matters.

The encouraging news is that states do not have to wait for new legislation to improve results. They can act now to strengthen systems, reduce administrative burden, and help eligible individuals remain connected to benefits.

Here’s what we know about quality implementation and how AIR can help:

User-centered technology protects coverage

Accessible, well-tested online systems represent one of the strongest levers states have for helping eligible individuals maintain coverage and meet reporting requirements. Yet, poorly designed portals have created new barriers instead, particularly for people with disabilities.

AIR works with agencies to test eligibility and reporting systems before launch, identify usability challenges, and strengthen accessibility so technology supports participation rather than becoming an obstacle.

The strongest employment outcomes come from connecting people to real supports

Evidence from Arkansas's Medicaid work requirement and from SNAP employment and training programs across the nation points in the same direction: employment gains are driven by access to job training, workforce services, and supportive programs, not reporting requirements alone.

AIR helps states design and evaluate implementation strategies that connect eligibility processes with meaningful workforce supports, helping participants meet requirements while improving long-term economic stability.

Multi-channel outreach works

States using community partnerships, and digital tools during the Medicaid Unwinding saw better renewal outcomes. Arizona, for example, achieved a 76% renewal rate using chatbots, surge call centers, and targeted tribal outreach.

Drawing on this evidence, AIR develops Community Readiness Implementation Frameworks that help agencies reach participants through multiple trusted channels. This reduces the risk that eligible individuals lose benefits because they never receive or understand critical information.

Data infrastructure enables rapid response

States with real-time monitoring and disenrollment tracking were better positioned to identify administrative errors and address problems before they resulted in significant coverage losses.

AIR partners with agencies to build dashboards, tracking tools, and implementation monitoring systems that provide actionable data when decisions matter most, helping leaders identify emerging problems and make course corrections before they affect large numbers of participants.

Work with AIR

As states prepare for the implementation deadline on January 1, 2027, they face critical decisions about program design, technology, outreach, workforce supports, compliance monitoring, and legislative reporting.

Contact Tonie Sadler for more information about how AIR can help.

AIR supports organizations throughout the implementation life cycle, from planning and assessment to real-time monitoring, evaluation, and reporting. We partner with state agencies, legislatures, federal agencies, advocacy organizations, and community-based partners to deliver research, technical assistance, and evidence-based guidance on Medicaid, SNAP, TANF, workforce development, benefits cliffs, and broader safety-net policy implementation.