Medicare 2026

Medicaid Work Requirements in 2027: What Adults 50 to 64 Should Know Before Medicare

If you are between 50 and 64 and currently have Medicaid, big changes are coming in 2027 that could affect your coverage before you ever reach Medicare age. A federal law passed in 2025 adds a new "community engagement" requirement, often called a work requirement, and shortens how often many adults have to renew. Here is a plain-English look at what is changing, who is affected, and how it connects to Medicare down the road.

What the new law does

Section 71119 of the 2025 budget reconciliation law (Public Law 119-21) tells states they must make a community engagement requirement a condition of Medicaid eligibility for certain adults no later than January 1, 2027. A state can start earlier, and HHS may grant a temporary exemption to a state showing a good-faith effort to comply, but that exemption must end no later than December 31, 2028. So the exact start date can differ from state to state.

Under CMS's interim final rule (CMS-2454-IFC, published June 3, 2026, effective July 31, 2026), the rule applies to non-pregnant adults ages 19 to 64 who are not entitled to or enrolled in Medicare and who are in the Medicaid adult (expansion) group or in certain section 1115 demonstrations with comparable coverage. CMS says 43 states and the District of Columbia cover these adults. U.S. territories are not subject to the requirement.

How you meet the requirement

In a given month, an adult meets the requirement by:

• Working, doing community service, or participating in a work program for at least 80 hours;
• Being enrolled at least half-time in an educational program;
• Combining those activities for at least 80 hours; or
• Having monthly income of at least the federal minimum wage times 80 hours — $580 a month in 2026 ($7.25 × 80).

A person who is entitled to or enrolled in Medicare Part A, or enrolled in Part B, for part or all of a month is treated as meeting the requirement for that month.

Who is exempt

The law exempts several groups, including people who are medically frail or have special medical needs (which the law says includes people who are blind or disabled), veterans with a disability rated as total, and parents, guardians, caretaker relatives, or family caregivers of a child 13 or younger or of a person with a disability.

States may also choose to excuse short-term hardships — for example, receiving inpatient hospital or nursing facility care; living in an area with a federally declared disaster or with high unemployment (at or above the lesser of 8% or 1.5 times the national rate); or traveling outside the community for an extended time to get medical care for a serious or complex condition not available locally.

Paperwork and timing

A new applicant may have to show compliance for 1 to 3 consecutive months before applying (the state picks the number). An enrolled adult may have to show compliance for one or more months between renewals. If a state cannot verify compliance, it must send a notice and allow 30 calendar days to respond with proof of compliance or an exemption; coverage continues during that period. A person disenrolled for not meeting the requirement may reapply at any time.

Important for Marketplace shoppers: under the law, an adult who would qualify for Medicaid except for not meeting the requirement is treated as Medicaid-eligible for premium tax credit purposes. That means, CMS says, that person cannot get advance premium tax credits to lower the cost of a Marketplace plan.

Separately, Section 71107 of the same law requires states to renew Medicaid eligibility every 6 months, instead of every 12, for most adults in the expansion group, beginning with renewals scheduled on or after January 1, 2027. People in non-MAGI groups — including Medicaid groups for people 65 or older, blind, or disabled — continue to be renewed at least every 12 months.

Why this matters as you approach Medicare

Many people in their late 50s and early 60s are counting the years to Medicare at 65. A few points to keep in mind:

• Once you enroll in Medicare Part A or Part B, you are treated as meeting the Medicaid work requirement for those months.
• Annual Enrollment for 2027 Medicare coverage runs October 15 – December 7, 2026, with choices taking effect January 1, 2027.
• In 2027, the Part D out-of-pocket cap rises to $2,400 (up from $2,100 in 2026), and the most any Part D plan may charge as a deductible is $700. The Part D base beneficiary premium used in the late-enrollment penalty calculation is $41.33 for 2027; individual plan premiums are set plan by plan.
• The 2027 Part B standard premium and deductible, and the 2027 IRMAA income brackets, had not been released as of this writing. CMS announces them in the fall, usually November.
• Social Security announced a 3.6 percent cost-of-living adjustment for benefits payable beginning January 2027.

If you have both Medicaid and Medicare — or Extra Help with Part D — remember that since 2025 there is a monthly Special Enrollment Period to switch to Original Medicare with a stand-alone Part D plan, or to switch stand-alone Part D plans. Full-benefit dual-eligible people can also join an integrated D-SNP in any month.

Choosing coverage at 65

When you reach Medicare, you will generally choose between Original Medicare (often paired with a stand-alone Part D plan and, if you want, a Medigap policy) and Medicare Advantage (which usually bundles Part D). Each path has trade-offs — provider access, out-of-pocket structure, extra benefits, and rules for using in-network care — and the right fit depends on your health, budget, and preferences. This article does not recommend one over the other.

Where can you get help with Medicare questions?

For official information on Medicare rules, enrollment windows, and plan comparisons, visit Medicare.gov or call 1-800-MEDICARE (1-800-633-4227), TTY 1-877-486-2048. For Medicaid questions specific to your situation, contact your state Medicaid agency.

Source: CMS — Medicare enrollment periods (medicare.gov).