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Wednesday, September 2, 2026

Nearly one in five Medicaid-eligible adults may miss new 80-hour work rule

Trump covering health coverage for more people

By Boston University

Edited by Gaby Clark, reviewed by Robert Egan


Map of the Proportion of Adults Age 18 to 64 Years at Risk of Noncompliance Who Were Plausible Medicaid Expansion Enrollees and Potentially Subject to Work-Reporting Requirements, by State. Credit: JAMA Health Forum (2026). DOI: 10.1001/jamahealthforum.2026.2938

A new study found that nearly 20% of eligible adults in Medicaid expansion states are in danger of not meeting the minimum work hours that will be required nationwide beginning Jan. 1. Women, unmarried people, white individuals and those with limited education all had a higher risk of losing their health coverage due to noncompliance with these new requirements.

Up to 10 million people may lose Medicaid coverage in the United States due in part to new work requirements and eligibility redeterminations under the One Big Beautiful Bill Act (OBBBA), which mandates a reduction of nearly $1 trillion in Medicaid spending over a decade.

While the administrative burden associated with meeting and maintaining these work requirements is expected to be the primary driver of disenrollment, a new study led by researchers at Boston University School of Public Health (BUSPH) and the Arnold School of Public Health at the University of South Carolina (Arnold School) found that millions of Medicaid enrollees may lose their health coverage because they are unable to achieve the required work hours.

Who is most at risk

Set to take effect nationwide on Jan. 1, 2027, the new federal Medicaid work reporting rules require adults enrolled in the Affordable Care Act's Medicaid expansion to show that they are working, volunteering, enrolled in school and/or participating in job training for at least 80 hours per month, with certain groups exempt. But the new study found that nearly 20% of Medicaid-eligible adults living in states that expanded Medicaid are at risk of noncompliance because they are unlikely to fulfill the minimum required hours once the rules take effect. The findings are published in JAMA Health Forum.

Certain groups were more at risk of noncompliance than others. Women had a 22% higher probability of having insufficient or inconsistent work hours than men, while married Medicaid enrollees had an 18% lower probability of noncompliance than unmarried enrollees.

Despite misconceptions by Medicaid work requirement proponents that able-bodied Medicaid recipients do not work, the study showed that more than 66% of applicable Medicaid recipients are in the labor force and, among that group, more than 85% worked more than 35 hours on average.

Unstable jobs, unstable eligibility

However, many working Medicaid recipients may experience challenges that prevent them from completing 80 hours of work each month. Many Medicaid recipients hold low-wage positions in the retail, hospitality, food service, health care and agriculture industries, which often provide inconsistent and unpredictable work hours and positions. These workers may also encounter challenges with reliable transportation to and from work, affordable and reliable child care, and unrecognized disabilities or chronic health conditions that make it difficult for them to complete job tasks week after week.

"These results show that the ideological narrative of Medicaid recipients just needing to pull themselves up by their bootstraps does not consider the precarious employment and other real-world barriers that often prevent them from maintaining stable work over time," said study lead and corresponding author Dr. Paul Shafer, associate professor of health law, policy & management at BUSPH and codirector of the Boston University Medicaid Policy Lab. "These new work requirements are going to be tougher to fulfill for people with less education, part-time jobs or gig work, who have less control over their hours, and those who have substantial health concerns that may not rise to the level of a documentable disability."

Furthermore, he said, "ample evidence suggests supporting people through Medicaid actually helps them to have stable employment because their health is better managed. Without Medicaid coverage, it is unlikely they will be able to meet both basic and critical health needs."

State-by-state gaps emerge

For the study, the team used federal social and economic data to examine employment among nonelderly adults plausibly eligible for Medicaid in the 40 Medicaid expansion states and Washington, D.C., from 2023–2025. The researchers estimated the prevalence of adults at risk of noncompliance because they were near the 20-hour-per-week threshold or reported variable hours (both +/- 5 hours) within the last week compared with their normal weekly hours.

They found that 19.8% of eligible Medicaid recipients were in danger of not meeting the work requirements, with 13.6% near the minimum hours threshold and 7.6% having highly inconsistent work hours. There were substantial differences in both employment activity and the prevalence of noncompliance across expansion states, spanning multiple regions. States such as Connecticut, Ohio, Arkansas and Nevada had among the highest proportions of people at risk of noncompliance due to insufficient work hours, while Massachusetts, Wisconsin, Colorado and Washington were among the states with the highest proportions of people at risk due to variable work hours.

"Work and community engagement requirements assume Medicaid expansion-eligible individuals have predictable schedules that translate into the same hours worked as scheduled," said study senior author Dr. David Anderson, assistant professor in the Department of Health Services Policy and Management at the Arnold School. "Our study shows that this is not the case. People who are trying to meet these requirements are at higher risk if they face short look-back periods and limited hardship exemptions."

Single mothers face a squeeze

Single mothers with high school-aged children may be among the most affected groups, Shafer said.

"Parents are only exempt if their children have a recognized disability or are under the age of 14, so single moms with older children must meet and report these work requirements to remain eligible," he said.

In addition to differences based on education level, sex and marital status, the researchers also observed racial and ethnic disparities in risk of noncompliance: Eligible Black and Hispanic Medicaid recipients had a lower risk than eligible white recipients. Those with higher education levels also had a lower risk compared with individuals who held less than a high school diploma.

Longer look-backs could widen barriers

The researchers also pointed out that these findings may be conservative estimates, as several states are expected to determine Medicaid eligibility based on multiple months of preemptive compliance prior to enrollment.

"States must look back to the prior month for compliance before the Medicaid application is filed, but they can look back as far as three months," said study co-author Dr. Timothy Callaghan, associate professor of health law, policy & management at BUSPH. "That means that, in some states, individuals must demonstrate work over several months to qualify for benefits. This will slow the access of newly employed individuals to Medicaid benefits in these states and could lead to disparities in Medicaid access for those with inconsistent work."

Publication details

Paul R. Shafer et al, Medicaid Work-Reporting Requirements Under HR 1 and Insufficient or Inconsistent Work Hours, JAMA Health Forum (2026). DOI: 10.1001/jamahealthforum.2026.2938

Journal information: JAMA Health Forum