Does volunteering count for Medicaid work requirements?

For millions of adults, keeping Medicaid will soon depend on proving how they spend their time. If you got Medicaid through your state's expansion, you'll soon be asked to show 80 hours a month of work, school, a job program, or community service. The good news is that volunteering counts. The hard part is proving it.

Here's what the federal rule actually says, in plain words.

Who has to meet Medicaid's work requirement

The rule comes from the 2025 budget law (H.R. 1) and a rule from CMS, the federal Medicaid agency, published June 3, 2026. It applies to you if you're:

• 19 through 64, and
• covered through your state's Medicaid expansion (the adult group), and
• not pregnant and not on Medicare.

If your state didn't expand Medicaid, this rule mostly doesn't apply. Georgia and Wisconsin cover some adults through special waivers, so check those states' details. Our state-by-state table shows where each state stands.

When it starts

States must start by January 1, 2027. Some went early. According to KFF, Nebraska started May 1, 2026, Montana started July 1, 2026, Arkansas began a soft start the same day, and Iowa planned December 1, 2026. A state can ask for more time if it's making a good-faith effort, but never past December 31, 2028.

If you're already on Medicaid, you'll usually be checked at your first renewal on or after your state's start date.

What counts toward the 80 hours

Each month, any one of these meets the rule:

• 80 hours of work. Paid, unpaid, or in-kind all count.
• 80 hours of community service.
• 80 hours in a work program, like a job training program.
• Going to school at least half time.
• A mix of these that adds up to 80 hours.
• Earning at least $580 a month, which is 80 hours at the federal minimum wage.

So 30 hours at a part-time job plus 50 hours at a food bank works.

Does volunteering count? What the rule says

Yes. The federal rule defines community service as:

"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."

In everyday words, your volunteering counts if it's:

1. Unpaid.
2. Part of a real program, not a favor.
3. Run by a public agency or nonprofit. It doesn't have to be a 501(c)(3). CMS says states "must not restrict community service" to 501(c)(3) groups. Local government and religious nonprofits can count.
4. For the community, not one person.
5. Not partisan.

The rule also says the organization should track the activity, dates, and hours, and have "a point of contact who can confirm the hours completed."

Examples from the rule

Helping with moves or yard work can count if it's through an organization that does it for the whole community.

Who is exempt

You don't have to meet the rule if, for example, you:

• Are a parent or caregiver of a child 13 or younger, or of a person with a disability.
• Are pregnant or postpartum.
• Are medically frail, which includes serious or complex medical conditions, disabilities, and some mental health and substance use conditions.
• Are a former foster youth under 26.
• Are American Indian or Alaska Native.
• Are a veteran with a total disability rating.
• Are in a drug or alcohol treatment program.
• Are in jail or prison, or were released in the last 3 months.
• Get SNAP and aren't exempt from SNAP's work rule, or are meeting TANF's work rules.

States can also give short-term hardship exceptions, like during a hospital stay or a disaster. Some states use these. Some don't. If you might be exempt, tell your Medicaid office. Don't wait for them to figure it out.

How Medicaid will check your hours

This is where volunteers get the most paperwork.

1. Your state checks its own data first, like payroll records. That works well for jobs.
2. Volunteering usually isn't in any database. KFF found states expect they "probably could not get information for most volunteer activities" from data.
3. So the state asks you. The federal rule gives "a document from a community service organization that demonstrates the number of hours an individual volunteered" as an example of proof.

Good proof includes the organization's name and address, the dates and hours, what you did, and a contact person's phone or email. Our free volunteer hours letter template has all of that.

How often and how far back

• When you apply, your state looks at 1 to 3 months before you applied. Most states chose 1 month.
• At renewal, it looks at one or more months since your last check.
• Renewals move to every 6 months for expansion adults starting in 2027. Indiana and New Hampshire plan to check every quarter.

Until January 1, 2028, states may accept your word for some things. After that, they must ask for documents when you can reasonably get them. Start keeping signed monthly records now, so you're never scrambling.

If you get a notice

You should get a notice and at least 30 days to respond, and your coverage continues while you do. Don't ignore it. In Nebraska's first months, KFF found that 84% of people denied, and 92% of people who lost coverage at renewal, lost it for not responding, not for falling short on hours.

If you do lose coverage, you can apply again.

Where Verified Hours fits

The tricky part isn't doing 80 hours. It's having a clean, signed record of them on the day your state asks. Verified Hours keeps that record for you: you log shifts, the nonprofit confirms them, and you get a signed monthly letter with a QR code your caseworker can scan. It's free for you and the nonprofit. A paper letter or your state's form works too. Just don't wait until the notice arrives to start collecting proof.

If you're also on SNAP, read how volunteering counts for SNAP. And if your nonprofit isn't sure what to sign, share our guide on verifying volunteer hours.

These rules put a lot on people who are already stretched thin. You can meet them. Keep a record every month, open your mail, and answer every notice.