The 2027 Work Requirements, Step by Step

The work requirement reaches tens of thousands of Idaho adults, it follows a calendar with legal deadlines, and it is built from a long chain of definitions where one wrong month or one misread notice can cost someone coverage. This lesson goes through that chain in the order a person meets it. It uses the statute, the CMS interim final rule and DHW's published guidance, and it labels invented examples so you can test the arithmetic without confusing a made-up person with a real case.

What the law says and who writes which part

Congress added the requirement to the Social Security Act as Section 1902(xx), in Public Law 119-21, signed July 4, 2025. The Federal Register calls that law the "Working Families Tax Cut legislation," and it is also known as H.R. 1 and the One Big Beautiful Bill Act. The codified text is 42 U.S.C. 1396a(xx), a subsection with eleven numbered paragraphs. CMS issued an interim final rule, CMS-2454-IFC, published at 91 Fed. Reg. 33348 on June 3, 2026, effective July 31, 2026, with new 42 CFR 435.550 through 435.563. For the layers behind this, see lesson 4.

Idaho layered its own law on top. House Bill 345 of 2025 told DHW to seek approval for work requirements. House Bill 913 of 2026, a Ways and Means Committee bill introduced March 17, 2026, passed the House 59 to 9 (2 absent or not voting) on March 23 and the Senate 28 to 6 (1 absent or not voting) on March 31, and Gov. Brad Little signed it April 10, 2026 (session law chapter 334). It amended Idaho Code 56-267 to require DHW to implement the federal requirements by December 31, 2026, to require new enrollees to show compliance for the three consecutive months before applying, and to require DHW to disenroll current enrollees who cannot show compliance. Idaho chose the longest lookback federal law allows.

Key dates

Date	What happens	Source
July 4, 2025	Public Law 119-21 signed; Section 1902(xx) added	42 U.S.C. 1396a(xx)
April 10, 2026	Idaho House Bill 913 signed; Idaho Code 56-267(6) amended	Idaho bill page
June 3, 2026	CMS interim final rule published	91 Fed. Reg. 33348
July 2026	DHW notifies expansion enrollees of the coming rules	Idaho Capital Sun, Sept. 1, 2026
July 31, 2026	IFR effective; comment period closed	Federal Register
December 31, 2026	Deadline in Idaho Code 56-267(6) to implement	Idaho Code
January 1, 2027	Federal start date; DHW begins reviewing people whose coverage periods end on or after this date; retroactive coverage drops to one month for expansion applicants	Statute; DHW expansion page
January 1, 2028	States must require documentation where reasonably available instead of accepting self-statements	42 CFR 435.557(b)(2)
December 31, 2028	Latest date any good-faith exemption can run	42 U.S.C. 1396a(xx)(11); 42 CFR 435.560

The statute says a state must begin "not later than the first day of the first quarter that begins after December 31, 2026," which works out to January 1, 2027. A state may start earlier. Nebraska did, announcing it would enforce in May 2026, according to Stateline reporting republished by the Idaho Capital Sun. A state that cannot meet the date may ask the Secretary of Health and Human Services for a good-faith exemption. CMS regulations say initial exemptions last no more than six months, extensions are possible, and none can run past December 31, 2028 (42 CFR 435.560). As of October 2026, I found no report that Idaho has asked for one.

Who is covered, who is excluded, who is exempt

The statute defines an "applicable individual" as a person enrolled or eligible to enroll in the expansion group (adults 19 to 64 with incomes up to 138 percent of the federal poverty level), plus people covered by waivers that provide equivalent coverage and who are 19 to 64, not pregnant, not on Medicare and not otherwise eligible. In Idaho, that means the roughly 80,000 to 85,000 people in the expansion group. Capital Sun reported in April 2026 that the requirements cover about 80,000 people; a state figure in a September article put expansion enrollment at about 85,000. Dates and definitions explain the gap, and lesson 3 covers who the group includes.

The people who are not subject fall into two statutory buckets, which DHW calls exclusions and exemptions.

Specified excluded individuals

These people never have to show activity. The state determines status, and under the CMS rule it must apply an exclusion whenever it has enough information, even if the person also meets the hours test.

• Young adults under 26 who aged out of state child welfare custody (the group described at Social Security Act 1902(a)(10)(A)(i)(IX)).
• American Indians and Alaska Natives, including people eligible for Indian Health Service care and California Indians.
• A parent, guardian, caretaker relative or family caregiver of a dependent child 13 or younger, or of a person with a disability.
• A veteran with a disability rated as total.
• People who are medically frail or have special medical needs, including people who are blind or disabled, have a substance use disorder (unless in stable recovery for five or more years) or a disabling mental disorder, have a physical, intellectual or developmental disability that significantly impairs activities of daily living, or have a serious or complex medical condition.
• People who comply with TANF work rules, or who are in a household receiving SNAP benefits and are not exempt from the SNAP work rule.
• People in a drug or alcohol treatment and rehabilitation program.
• People in a public institution such as a jail or prison.
• People who are pregnant or entitled to postpartum coverage.

Mandatory exceptions that count as compliance

The state must deem a person compliant for any month when the person was under 19, entitled to Medicare Part A or enrolled in Part B, in certain other mandatory coverage groups, or was in a public institution at any point in the three months ending on the first day of the month. In plain terms, someone released from jail in the past three months is deemed compliant while they get on their feet.

Optional short-term hardship exceptions

A state may choose to deem people compliant during a short-term hardship event. The statute lists three: an inpatient hospital, nursing facility or similar stay; residence in a county under a presidentially declared emergency or disaster or with an unemployment rate at or above the lesser of 8 percent or 1.5 times the national rate (the second test requires a request to the Secretary); and the need to travel outside the community for a long period for treatment of a serious or complex condition not available locally. Capital Sun reported on September 1, 2026 that Idaho had not yet decided on the high-unemployment option. Check DHW's page for the current list.

Question	Excluded individual	Mandatory exception	Hardship exception
Who decides?	The state, from its data or your report	The state	The state, if it elected the option
Must you prove activity?	No	No, for that month	No, for that month
Is it required by federal law?	Yes	Yes	No, optional
Example	Parent of a 9-year-old	Person on Medicare	Month in a hospital

The test itself: 80 hours or $580

For each month that counts, an applicable individual meets the requirement if any one of these is true:

• Works at least 80 hours.
• Completes at least 80 hours of community service.
• Participates in a work program (as defined in the SNAP statute, 7 U.S.C. 2015(o)(1)) for at least 80 hours.
• Is enrolled in an educational program at least half-time, which includes higher education and career and technical education.
• Does any combination of work, service and work programs totaling at least 80 hours.
• Has monthly income of at least the federal minimum wage under 29 U.S.C. 206 multiplied by 80 hours. At the federal minimum wage of $7.25, that is $580. The CMS rule says work includes in-kind and unpaid work.
• Is a seasonal worker whose average monthly income over the preceding six months meets that same income figure.

One note on wording. The statute counts enrollment in an educational program at least half-time. Under the federal rule, hours for less-than-half-time enrollment are converted from credit hours and can be combined with other qualifying hours (42 CFR 435.552(d)). If your situation depends on the difference, ask DHW in writing, or check 42 U.S.C. 1396a(xx)(2)(D).

Examples with the arithmetic

What counts as income

Income is counted under the Medicaid household income rules, which use modified adjusted gross income (MAGI) methods (42 CFR 435.552(f)(2)). DHW describes the income route as household income of at least $580 a month. Gross and take-home pay can differ near that line, so ask DHW in writing how a particular paycheck is counted.

The process, step by step

Step 1: you apply in month M

The requirement is a condition of eligibility. At application, the state must verify that you demonstrated community engagement for one to three consecutive months immediately before the month you apply, with the number set by the state. Idaho set it at three, the longest period the statute allows.

Step 2: the three-month lookback

Applicants also face a change in retroactive coverage. DHW says that from 2027 retroactive coverage is two months for Medicaid generally and one month for expansion applicants. A person who gets care in the month before applying may no longer have that care covered by a later approval.

Step 3: the ex parte data check

"Ex parte" means the state acts on information it already has, without asking you. The statute requires states to set up processes to use reliable information available to the state, such as payroll data, claims data or encounter data, without requiring the person to submit more where possible. The CMS rule goes further. It lists reliable information to include electronic data sources, other state and local agencies, federal data through a service the Secretary sets up, the state eligibility system, the case record, payroll data, claims adjudicated in the preceding 12 months and encounter data for the preceding 12 months. The state must check all of it, for all the relevant months, before it asks you for anything (42 CFR 435.557).

DHW applied this to its own rolls in July 2026. According to the Capital Sun, the state reviewed data for about 83,000 expansion enrollees and found that 68,400 already met the new requirements, with Medicaid Administrator Sasha O'Connell saying the vast majority were meeting them through SNAP and Department of Labor data. The arithmetic: 68,400 / 83,000 = 82.4 percent. The other 14,600, or 17.6 percent, were not verified by data on that pass. Some are probably excluded (caregivers, medically frail, and others the data cannot yet see), and some are working in ways the data misses. The figure does not say 14,600 people will lose coverage. It says that is the size of the group the state would have to resolve through exclusions, further data or contact with the person.

Two limits apply. First, the medically frail category is hard for data to find. Under the CMS rule, a state must reverify medically frail status at least every 12 months. Capital Sun reported that DHW is working with a contractor to pull claims data automatically and that patients may need a doctor's note if the state lacks evidence of frailty. Second, the standard of proof changes on January 1, 2028. Before then the state may accept a self-statement when it has no reliable information. From that date it must require documentation whenever documentation is reasonably available, though it may not deny or end coverage only because a person cannot produce a document that does not exist (42 CFR 435.557(b)(2)).

Step 4: verified or excluded

If the state verifies you, you are enrolled, subject to the next verification. If it determines that you are a specified excluded individual, it must tell you so in your eligibility notice, and the CMS rule says that both the exclusion finding and the compliance finding are appealable decisions, with a right to a fair hearing under 42 CFR 431.220(a)(1). Losing excluded status and becoming subject to the requirement is also treated as an action that triggers notice rights.

Step 5: the notice of noncompliance and the 30 days

If the state cannot verify you, it must send a notice of noncompliance. The notice must say which months will be assessed, how to show compliance or an exclusion, the deadline, the ways to send information, the consequences for Medicaid and for premium tax credits on the health insurance marketplace, and how to reapply if coverage ends. The CMS rule treats the notice as received five days after the date on it unless you show you did not receive it in that time. You then have 30 calendar days from receipt to make a satisfactory showing of compliance, or that the requirement does not apply to you. The statute says that, for an enrollee, the state must keep providing coverage during those 30 days.

Two protections matter in practice. The state must not restrict a person from reapplying after a denial or disenrollment for noncompliance (42 CFR 435.558(e)). And if a person on MAGI-based coverage was disenrolled for failing to respond to the notice and sends the information during the reconsideration period in 42 CFR 435.916(a)(3)(iii), the state must reconsider eligibility. That period is at least 90 days after the date of termination, or longer if the state elects (42 CFR 435.916(a)(3)(iii)).

Consequences also reach beyond Medicaid. Under the statute, a person who would have been eligible for Medicaid but for the requirement is treated as eligible for minimum essential coverage for premium tax credit purposes. In plain terms, someone who loses coverage for not meeting the requirement generally cannot use the subsidized marketplace as a fallback, and DHW says they may not be able to claim the advance premium tax credit. They may still buy an unsubsidized plan through Your Health Idaho.

Step 6: six-month renewals

Federal law requires states to verify compliance at each regularly scheduled renewal, and states may verify more often. Separate federal law, Section 1902(e)(14)(L), brings redeterminations for expansion adults to every six months (the CMS rule refers to it in 42 CFR 435.916). Idaho Code 56-2205 had already told DHW to move to biannual redeterminations. DHW's expansion page, updated October 13, 2026, says renewals occur every six months and that participants must show three months of compliance during their current six-month certification period. That detail is the state's choice within the rule, which lets a state specify one or more months. Keep monthly records for at least three of every six months.

What the evidence says

Two states give the main U.S. evidence on work requirements in expansion populations, and a third set of figures is an estimate for Idaho. They measure different things, so the comparison below needs a label on each bar.

Arkansas, 2018

Arkansas ran the best-documented requirement. State figures compiled by KFF show that 18,164 people were disenrolled cumulatively from August through December 2018. Researchers led by Benjamin Sommers published two studies. The first, in the New England Journal of Medicine in June 2019, found that among adults 30 to 49, coverage in Arkansas fell from 70.5 percent in 2016 to 63.7 percent in 2018 and the uninsured rate rose from 10.5 percent to 14.5 percent, with no measurable increase in employment. Awareness was poor: about a third of the targeted adults with coverage had not heard of the policy, and nearly half were unsure whether it applied to them. The authors wrote that "bureaucratic obstacles played a large role" in the coverage losses.

The second study, in Health Affairs in 2020 (volume 39, issue 9, pages 1522 to 1530), compared Arkansas with other states over two years. It found that coverage for Arkansans 30 to 49 fell 13.2 percentage points in 2018 relative to comparison groups, that the uninsured rate rose 7.1 points relative to the comparison, that employment, hours worked and community engagement did not change significantly, and that more than 95 percent of the target population already met the requirement or should have qualified for an exemption. About 18,000 people were removed by early 2019, most of whom never submitted the required reports. The authors concluded that reporting barriers drove most coverage losses, and that few of the people removed had failed to meet the requirement itself. Coverage recovered in 2019 after a court blocked the policy.

Why do the two studies report different drops (6.8 points and 13.2 points)? They use different comparisons. The first compares Arkansas before and after. The second compares Arkansas's change with the change in comparison groups. Always report the design with the number.

Georgia Pathways

Georgia Pathways is the other program with a track record. The Government Accountability Office, as reported in September 2025, described an eligible population of nearly 250,000 low-income Georgians. As of August 31, 2025, 9,175 people were enrolled. GAO reported $54.2 million in administrative spending from 2021 through April 2025 against $26.1 million in health care spending. About 90 percent of the administrative money came from federal funds. The GAO figure excludes $27 million paid to Deloitte Consulting for marketing and about $10 million in other consulting and legal fees, according to the report coverage I read. State officials attributed part of the cost to a two-year delay caused by legal battles, and GAO did not verify that claim.

Georgia is not Idaho. Georgia has not adopted full Medicaid expansion, and Pathways covers adults with incomes below the poverty line (about $15,650 a year in the report I read) who must document 80 hours a month of work, study or volunteering. Idaho's requirement applies to people already covered under expansion, with a federal rule that makes the state check its own data first. The comparison shows what can happen when a program is expensive to administer and enrolls few people. It does not predict Idaho's numbers.

National and Idaho estimates

• The Congressional Budget Office, as summarized by the Georgetown Center for Children and Families, estimated that the work requirement would increase the number of uninsured Americans by 5.3 million in 2034, before interactions with other provisions of the law.
• KFF analyzed 2023 survey data and found that 92 percent of Medicaid adults ages 19 to 64 who are not on SSI, SSDI or Medicare were working or had a reason they could not (caregiving, illness or disability, or school). Of these, 64 percent worked full or part time.
• A December 2025 DHW report found that about 48 percent of what it calls able-bodied adults on Medicaid were working, according to the Capital Sun. The 48 percent and the 64 percent are not in conflict, because the groups and definitions differ. Always ask who is in the denominator.
• Capital Sun reported in April 2026 that about 40 percent of Idahoans on Medicaid were removed during the 2024 redetermination, mostly for not replying to the state's requests for information. The pattern of paperwork-driven loss resembles Arkansas.
• The Urban Institute and Robert Wood Johnson Foundation estimate that 20,000 to 34,000 Idahoans could lose expansion coverage by 2028, a range the Capital Sun noted is lower than some other researchers' estimates.

The Idaho estimate is a model, and the Idaho data check is an observation. Each is useful alone. Together they point to the same group of people: the ones the data cannot see. For the 14,600 expansion enrollees not verified in July, the question is how many are excluded, how many can be found in other data, and how many get a notice. DHW can answer that with counts once the first notices go out, and you can request those counts under the public records law.

Idaho specifics to know

Choice	Federal rule	Idaho as of October 2026
Start date	No later than Jan. 1, 2027	Jan. 1, 2027; review for coverage periods ending on or after that date
Lookback at application	1 to 3 consecutive months	3 months
Verification for enrollees	At least at each renewal; more often optional	Six-month renewals; 3 months of compliance in the certification period (DHW page)
Hours or income	80 hours or 80 x minimum wage	80 hours or $580 a month
Hardship exception for high-unemployment counties	Optional, needs request to HHS	Undecided as of Sept. 1, 2026
Retroactive coverage	Cut to 1 month for expansion, 2 months for others	Same, from 2027
Evidence standard	Self-statement allowed before Jan. 1, 2028; documents after	Follows federal rule

The state-level debate matters too. House Bill 913 passed both chambers by wide margins. Reporting from the 2026 session shows a separate bill to end expansion at the end of 2026 and replace it with a capped program with work requirements did not advance out of committee. Sen. Julie VanOrden said she would not support repeal, and Gov. Little reportedly hinted he would not either. In short, the Legislature and the governor chose to implement the federal requirement while keeping expansion in place.

The fiscal side is small compared with the Medicaid budget. DHW's fiscal year 2027 budget request included $1.87 million for work requirements, split between federal and state funds, and $1 million for twice-yearly eligibility checks, $900,000 federal and $100,000 general fund, according to the Capital Sun's September 2025 report. Lesson 5 shows where such lines sit in the larger budget.

How a resident can have a say

The federal comment period on the interim final rule closed July 31, 2026, but several channels remain. DHW takes questions at its town halls; the first virtual town hall was held Monday, August 31, 2026, with replays and more planned. The 2027 Legislature will hear bills and budget requests. The Testifying course lesson on preparing and delivering testimony explains how to organize three minutes. A strong testimony here carries a specific case (with consent), the notice date, what the letter said and what should change. Lesson 10 of this course follows House Bill 913 from introduction to implementation.

If you only do one thing this week, find the most recent DHW letter for anyone you help, write the renewal date on a calendar, and write the three months before that date on the same line. That one habit covers the lookback for new applicants and the certification period for current ones.