Modern Estate Planning Blog

For many individuals and families in the Sacramento area, Medicaid plays a vital role in providing access to health care and long-term care services. As laws and eligibility requirements continue to evolve, it becomes increasingly important to understand how these changes may affect your coverage and planning. At Chubb Law Firm PC, we help Sacramento-area families stay informed so they can make confident decisions about their future.

In 2025, Congress passed a sweeping federal spending and budget law known widely as the One Big Beautiful Bill Act (officially H.R. 1), which included major changes to the Medicaid health insurance program. Among the most significant new policies are national work requirements for Medicaid enrollees. States are required to implement the work requirements by January 1, 2027, but states can roll out implementation earlier.

Although some states, such as Georgia and Arkansas, have implemented Medicaid work requirements, this is the first time such requirements are being introduced at this scale. Previous implementations of Medicaid work requirements led to large-scale coverage losses and administrative burdens.

Under this new law, most low-income adults on Medicaid will need to show that they are participating in community engagement activities, such as working, volunteering, going to school, or participating in job-related programs, to keep their health coverage. Individuals who fail to meet the work requirements and who are not exempt from the requirements will also be disqualified from receiving marketplace subsidies on health insurance.

The nationwide Medicaid work requirements have sparked recent discussions among advocates of older adults, including nonprofit Justice in Aging, which recently hosted a webinar focused on how these rules will be applied and the risks they pose to people who rely on Medicaid.

Who Will Be Required to Participate

The new work requirements generally apply to most adult Medicaid enrollees who are between the ages of 19 and 64 and who do not meet work requirement exemptions. To stay eligible for Medicaid, these adults will need to document that they meet a minimum of 80 hours per month of qualifying activities such as:

• Paid work
• Community service or volunteering
• Job training programs
• Half-time or greater enrollment in school
• Or some combination of these activities

The new law requires Medicaid enrollees to comply with work requirements at least one month prior to enrollment or redetermination. (Note that states can require compliance up to three months prior to enrollment.)

The law also requires Medicaid enrollees to report their compliance at least as often as when they go through the redetermination or renewal process. This used to be once each year but is now required at least every six months. However, states can require enrollees to submit their renewals or redeterminations more frequently, even monthly.

Who Is Exempt From the New Rules?

The law and current guidance include several exemptions. Medicaid recipients who qualify for an exemption will not need to meet or report any work or engagement hours.

Mandatory Federal Exemptions

Some groups of people are generally excluded from meeting work requirements, such as:

• Individuals receiving Medicaid for pregnancy or postpartum coverage
• Those who are under age 19 or over age 65
• People who are also enrolled in, or are entitled to, Medicare (referred to as dually eligible)
• Medicaid enrollees who are aged, blind, disabled, or who have a serious or complex medical condition
• Parents, guardians, caretaker relatives, and family caregivers of a disabled individual or dependent child who is 13 years old or younger
• Foster care and former foster care youth under the age of 26
• Disabled veterans with a total disability rating

The Centers for Medicare & Medicaid Services provides more information on who is eligible for Medicaid.

Optional or State-Level Hardship Exemptions

States may provide short-term hardship exceptions for individuals facing special circumstances, such as:

• Receiving care in a hospital, nursing facility, psychiatric facility, or other intensive care setting
• Residing in counties with an unemployment rate higher than 8 percent or 1.5 times the national unemployment rate
• Living in a federally declared disaster area
• Having to travel outside their community for medical care, either for themselves or their dependent, to treat a serious or complex condition for an extended period

What This Could Mean for People With Medicaid

Supporters of the work rules argue they can encourage engagement and align Medicaid with other benefit programs. However, advocates and health policy analysts, including those at Justice in Aging, warn that:

• These rules could lead to coverage loss if people miss reporting deadlines or paperwork requirements.
• Administrative burdens and verification systems may be inconsistent across states.
• Evidence from prior work requirement implementations suggests that more people lose coverage because of technical violations rather than for lack of work.

Since adults aged 50 to 64 are more likely than younger adults to have chronic conditions and caregiving responsibilities, they are more likely to have trouble holding down a job. But they are more likely to need consistent health coverage.

The new Medicaid work requirements are likely to hit these older adults especially hard, as they may be unable to handle physically demanding work they could do when they were younger. Some of these older adults may also face education or technology barriers or age discrimination when trying to reenter the workforce.

Though there is a range of exemptions, qualifying for them could prove to be a barrier for some due to the vagueness of some parts of the law. For example, individuals who are deemed “medically frail” can be exempt from the work requirements; however, it is not clear which disabilities and conditions qualify as medically frail.

According to the AARP, a handful of states have implemented Medicaid work requirements in the past. In these states, tens of thousands of people either lost coverage or were projected to lose coverage because the administrative hurdles were so great.

Don’t risk a loss of coverage: Understanding the new work requirements and keeping precise records is essential for people enrolled in Medicaid to navigate these upcoming changes safely. To seek out further guidance, contact your state Medicaid agency.

Changes to Medicaid eligibility and reporting requirements can create uncertainty, especially for older adults and those relying on consistent health coverage. Understanding your rights and planning ahead can help you avoid unexpected disruptions. If you have questions about Medicaid, long-term care planning, or protecting your benefits, you can call Chubb Law Firm PC at (916) 241-9661.

Additional Reading

For additional reading on topics related to Medicaid, check out the following articles:

• What to Do If You Lose Your Medicaid Coverage
• How Gifts Can Affect Medicaid Eligibility
• Medicaid Expansion: What Might It Mean for You?

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