You've been volunteering for years: the pantry on Tuesdays, coaching on weekends, helping at your church. Now a Medicaid notice says you need 80 hours a month of "community engagement," and you're not sure which of those hours count. That's a fair question, and the answer turns on one paragraph of federal rule.
Here it is, one piece at a time, with what CMS said counts, what doesn't, and the gray areas your state gets to decide.
The exact definition
The 2025 budget law (H.R. 1) lets people meet Medicaid's new work rule with 80 hours of community service a month. CMS, the federal Medicaid agency, defined the term in its interim final rule on Medicaid community engagement, published June 3, 2026, at 42 CFR 435.552(b):
"Community service means unpaid work, completed voluntarily or because of a mandate by court order, with a structured program that is completed for the direct benefit of the community under the auspices of public or nonprofit organizations (including embedded activities of the program that allow an individual to develop skills necessary to complete community service)."
The rule goes on to say the organization "must provide oversight of the activity, which must not serve a partisan purpose," and must track "the type of community service activity, dates and hours the community service is completed, and a point of contact who can confirm the hours completed."
If you want the bigger picture first (who has to meet the rule, when it starts, and how hours get checked), read our guide to Medicaid work requirements and volunteering.
What counts as community service for Medicaid, piece by piece
Each part of the definition is a test. Your hours need to pass all of them.
| Piece of the rule | What it means for you |
|---|---|
| Unpaid work | You aren't paid. If you're paid, it's work, which also counts, but as work. |
| Voluntary or court-ordered | Both count. Court-ordered service is named on purpose. |
| Structured program | There's a real program with a schedule and a person in charge. Not a favor. |
| Direct benefit of the community | It helps the public, not one person or one family. |
| Public or nonprofit organization | A government agency, school, library, nonprofit, or religious nonprofit. |
| Oversight | Someone at the organization oversees what you do. |
| Not partisan | No work for a candidate, party, or political committee. |
| Tracking and a contact person | The organization records your dates, hours, and activity, and someone there can confirm them. |
| Embedded skill-building | Training that's part of the program counts too. |
A few of these need more explanation.
It doesn't have to be a 501(c)(3)
This trips people up. CMS wrote that a state "must not restrict community service to activities with an organization described in section 501(c)(3)." It gave examples of groups that may not be 501(c)(3)s but still count: "local government agencies, religious nonprofits (such as non-denominational ministries), and smaller social service providers." So a city parks department, a public library, or a small ministry's meal program can all qualify.
"Structured" means you can't do it on your own
CMS was direct about this: "an individual cannot complete a community service activity independently of an organization that fits the description in the definition." Picking up litter on your street by yourself is kind, but it won't count. Picking up litter with the city's park cleanup crew can.
Training inside the program counts
The phrase "embedded activities" means time spent learning to do the volunteer job. CMS's example is "attending a computer training class to learn a certain computer skill to provide tech tutoring for seniors." If your food bank requires a food safety class before your first shift, ask the coordinator to list those hours too.
Try this: for each place you volunteer, ask yourself four questions. Is it unpaid? Is there a program and a person in charge? Does it help the public? Will someone there sign for my hours? Four yeses means you're probably on solid ground.
Examples CMS gave: counts and doesn't count
CMS listed these examples in the rule. They're examples, not the full list. CMS chose not to list fields of service so it wouldn't "inadvertently limit" new kinds, and said technology is one field that could count.
| Counts | Doesn't count |
|---|---|
| Volunteering at a food bank | Helping a friend move |
| Mentoring or tutoring youth | Helping one person with yard work |
| Delivering meals to seniors | Going to a parent teacher conference |
| Cleaning public parks or grounds | Going to your child's school events |
| Court-ordered community service | Joining a dance or sports club |
| Campaigning for a partisan candidate or committee |
Notice the pattern. Moving furniture and yard work don't count when you do them for one person. CMS says they can count when you do them "for an organization that provides that assistance broadly to various members in the community," like a home repair ministry or a senior chore program.
Real questions people ask
Does volunteering at church count?
Often, yes, if it's the right kind of work. A church food pantry, clothing closet, or meal program open to the public fits the definition well. Singing in the choir or going to services isn't unpaid work for the community, so it's unlikely to count. Ask whoever runs the program to track your dates and hours.
Does online or virtual volunteering count?
The rule doesn't address it. Nothing in the definition says the work must be in person, but you still need a public or nonprofit program that oversees your work and tracks your hours. Your state decides this. Ask your Medicaid office before you count online hours, and get the answer in writing if you can.
Does caring for someone count?
Helping one neighbor on your own is the kind of one-person help CMS says doesn't count as community service. But caregiving has its own path. CMS says unpaid care for a child 13 or under, or for a person with a disability, who isn't related to you and doesn't live with you, counts as unpaid work. CMS's example: 55 hours of that care in a month counts, so you'd need 25 more hours from work, volunteering, school, or a job program. At 80 hours or more of that care a month, you may not have to meet the rule at all. Our guide to who is exempt from Medicaid work requirements explains the caregiver rules.
What about volunteering at my kid's school?
Going to school events or a conference doesn't count. A public school is a public organization, though, so a structured school volunteer program (like a reading tutor program with a sign-in sheet and a coordinator) may fit. The rule doesn't give a school volunteering example, so check with your state.
Does campaigning or political work count?
Not if it's partisan. CMS says "campaigning or volunteering for a partisan political candidate or committee" is excluded. Nonpartisan work, like a voter registration drive run by a nonprofit, isn't named either way, so ask your state.
Do mutual aid groups count?
It depends on how the group is set up, and the rule doesn't mention mutual aid by name. An informal group chat that shares groceries probably won't meet the "structured program" and "point of contact" tests. A mutual aid network that's part of a nonprofit or a church, with someone who keeps track of hours, has a much better chance. Your state makes the call.
Does court-ordered service count?
Yes. CMS wrote that "whether community service is completed voluntarily or because of a mandate, such as court-ordered community service, the community service still benefits the community." Our page on court-ordered community service and Medicaid covers using the same hours for both.
How to check with your state
CMS says plainly that "States are responsible for determining which activities qualify as community service." So the federal rule sets the floor, and your state fills in the details. Here's how to get a clear answer:
- Find your state's page. Our state-by-state table links to each state's official Medicaid work requirement page where we've found one.
- Call or message your Medicaid office. Say: "I volunteer at [organization], doing [task], about [number] hours a month. Will that count as community service for the work requirement?"
- Ask what proof they want. Some states have their own form. If not, a letter from the organization works.
- Write down the answer. Note the date, the name of the person you talked to, and what they said.
Proof that matches the definition
When your state can't find your hours in its own records, which is common for volunteers, it will ask you. CMS lists what good proof can include: "details about the general nature of the program; the dates and hours of community service completed; a description of the community service activity; the organization's name and address; and the name and contact information" of a person who can confirm the hours.
That list lines up with the definition on purpose. Our free volunteer hours letter template covers every item, and you can print it for your coordinator to sign.
Where Verified Hours fits
If the organization where you volunteer uses Verified Hours, you log each shift, the coordinator confirms it, and you get a signed monthly letter with a QR code your caseworker can scan. It's free for volunteers and nonprofits. But you don't need software to meet the rule. A signed letter on the organization's letterhead with the details above does the job.
These rules ask a lot of people who are already giving their time. Pick one place you volunteer, run it through the four questions above, and ask the coordinator this week if they'll track your hours.