Picture someone who loses a job in December and applies for Medicaid on January 5. They expect the office to ask about January. Under the new work rule, it may ask about December instead, and if they spent December helping at a food pantry with nobody writing it down, that month is hard to prove.
That's the look-back period. It surprises people because it points backward. Here's how it works, which months your state will check, and what to do this fall so you're ready.
What is the Medicaid work requirement look-back period?
If you're on Medicaid through your state's expansion, the new rule asks you to show 80 hours a month of work, school, a job program, or community service (or a mix). If you're new to the rule, start with our guide to Medicaid work requirements and volunteering.
The look-back period (CMS calls it the "review period") is the month or months your state looks at to decide if you met it. There are two kinds:
| When | Which months your state checks | Who picks the number |
|---|---|---|
| When you apply | 1, 2, or 3 months in a row, right before the month you apply | Your state, between 1 and 3 |
| When you renew | At least 1 month, in a row or not, since your last eligibility decision | Your state, at least 1 |
The application rule comes straight from the CMS interim final rule on Medicaid community engagement, at 42 CFR 435.556. It says your state must require proof "for at least one, but not more than 3 consecutive months, as specified in the State plan, immediately preceding the month of application."
So the month you apply in doesn't count for the application. The months before it do.
How many months does my state check?
Most states picked the shortest option. When KFF surveyed states in spring 2026, KFF found that most states will look back one month. Of 43 states that answered, 36 said they'll look back one month at application. Idaho and Indiana said three months. Five hadn't decided yet.
States can still change their plans, so check yours. Our state-by-state table shows the look-back months we've confirmed for each state, with the source. If yours isn't listed, call your Medicaid office and ask: "How many months do you look back when someone applies?"
A worked example: applying in January 2027
Every expansion state must start the rule by January 1, 2027, unless it gets extra time. So January is when a lot of people will meet the look-back for the first time.
Say you apply on January 12, 2027, and your state's rule is in effect.
| Your state's look-back | Months that must show 80 hours (or an exception) |
|---|---|
| 1 month | December 2026 |
| 2 months | November and December 2026 |
| 3 months | October, November, and December 2026 |
In a 3-month state, all three months count, not just one of them. CMS says an applicant meets the rule "if they demonstrate community engagement for all of the months elected by the State."
What if December was short? If you apply in February instead, the 1-month look-back moves to January. Timing your application isn't always possible when you need care now, so don't delay getting care to game the calendar. Apply, answer every notice, and ask your caseworker what counts.
The 80 hours can be a mix. Ten hours of a part-time job a week plus some volunteering can add up. Our Medicaid 80-hour calculator helps you check a month before it ends.
Keep records in November and December
The holidays are when a lot of people volunteer: food drives, toy drives, holiday meals, coat closets, church dinners. They're also when sign-in sheets get lost, coordinators take time off, and nobody thinks about paperwork.
If you might apply for Medicaid in January, your December hours may be the ones that count. In a 3-month state, October and November count too. Here's what to do now:
- Write down every shift the day you do it. Date, start and end time, what you did, and who supervised you. Our printable volunteer hours log has a column for each.
- Get the month signed before the holiday break. Ask the coordinator to sign your December hours before they leave for the holidays, or in the first week of January.
- Make sure the letter has a contact person. CMS lists what helps a state check community service hours: the program, the dates and hours, what you did, the organization's name and address, and "a point of contact at the organization who can confirm the hours completed."
- Keep one letter per month. If your state checks three months, you want three clean records, not one lump total.
- Keep a copy of everything, or a photo on your phone.
What about renewals?
Once you're enrolled, the look-back works differently. Starting in 2027, most expansion adults will renew every 6 months. At renewal, your state looks at the time since your last eligibility decision and asks you to show at least 1 month (or more, if your state chose that).
Two things work in your favor here. First, the months don't have to be in a row. Second, CMS says your state can't "dictate the specific month(s)" you must use. If your state requires 1 month, any one good month in the period can count. KFF found 34 states plan to look back one month at renewal.
A few states plan to check more often than every renewal. KFF named Indiana and New Hampshire as planning quarterly checks. Our guide to keeping your hours ready for renewal covers the 6-month cycle in detail.
Documents now vs. after January 1, 2028
Your state has to check its own data first, like wage records and SNAP files. Volunteering rarely shows up there, so volunteers are the people most likely to be asked for proof.
- Before January 1, 2028, the rule says your state "may require documentation or accept other information" when its records can't confirm your hours. States will handle this differently, and some may ask for less paperwork at first.
- Starting January 1, 2028, your state "must require documentation whenever documentation is reasonably available." For volunteering, CMS gives "a document from a community service organization that demonstrates the number of hours an individual volunteered" as an example.
Either way, a state can't deny you just because documents don't exist. It has to accept other information instead. But a signed monthly letter is the proof least likely to be questioned, now or later. Get in the habit this year.
Why the number of months matters
Advocates pushed states toward the shortest look-back. Families USA argued that one month is the least burdensome option, because people with uneven hours, like seasonal and gig workers, can have a slow month without losing coverage over it. A longer look-back means more months to prove and more chances for one missing letter to cause trouble.
You can't change your state's choice. You can make sure every month in your window has a record.
Where Verified Hours fits
Verified Hours keeps a signed record of each month's shifts, confirmed by the coordinator, with a QR code your caseworker can scan. When the office asks about December, the record is already there. It's free for volunteers and nonprofits. A paper log and a signed letter from your coordinator do the same job, and plenty of people will meet the rule that way.
If you think you'll apply for Medicaid early next year, count backward from the month you'll apply. Those are your months. Start writing them down now.