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Utah Medicaid's Work Requirement Starts Jan. 1, 2027: Who Must Report 80 Hours, Who Is Exempt, and What to Do Now

From Jan. 1, 2027, many Utah adults on Expansion or Targeted Adult Medicaid must show 80 hours a month of work, school or service, or $580 in earnings. Who is exempt and what to do now.

Starting January 1, 2027, tens of thousands of Utah adults on Medicaid will have to show the state that they are working, studying, training or volunteering to keep their coverage. The change comes from the federal budget law signed July 4, 2025, which Utah Medicaid refers to as H.R. 1, and it lands at the same time as a second change: more frequent eligibility reviews.

This guide explains who is covered by the rule, what counts, who is exempt, how Utah says it will check, and what to do now. It is drawn from Utah Medicaid's H.R. 1 pages, its July 2026 letter to members and its member FAQ, checked on November 13, 2026, along with reporting by The Salt Lake Tribune and KFF.

The short version

Who the rule applies to

Utah Medicaid says the requirement applies to adults ages 19 to 64 enrolled in two programs:

Utah Medicaid lists who may not be affected at all:

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If you are not sure which program you are in, your approval letter or your myCase account will say, or DWS can tell you.

What counts toward 80 hours

From Utah Medicaid's community engagement page and its member letter, you meet the requirement by doing one or a combination of these for 80 hours each month:

Two alternatives also satisfy it:

The earnings route matters for people with irregular schedules. Someone who works 15 hours a week at a wage that produces more than $580 in the month meets the rule even though 15 times four is less than 80.

Who is exempt

Utah Medicaid's list of people excluded from the requirement:

The member letter also lists people receiving other benefits, such as Social Security or SSI, and people on Medicare Part A or Part B.

Situations that count as already meeting it

Utah Medicaid separately lists circumstances in which you may have already met the requirement since your last review or approval, including:

An exemption that is not on the list

The Salt Lake Tribune reported in August 2026 that experiencing homelessness alone does not qualify someone for an exemption under the rule. People who are homeless may still qualify under another category, such as medical frailty, so it is worth asking.

Four examples

These are illustrations of how the published rules read, not eligibility decisions. DWS decides each case.

A part-time cashier. Ana works about 15 hours a week and earns about $650 a month. Her hours fall short of 80, but her earnings are over $580, so she meets the requirement through the earnings test.

A parent of a school-age child. Marcus is on Adult Expansion Medicaid and is raising his 10-year-old daughter. Parents and caregivers of a child 13 or younger are excluded, so the 80-hour rule does not apply to him, though he still goes through six-month reviews. When his daughter turns 14, the exclusion no longer covers him.

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A college student. Priya is 22, on Adult Expansion, and enrolled at least half-time at UVU. Going to school at least half-time counts toward the requirement. If she drops below half-time in the summer, she needs another activity, such as work, volunteering or the $580 earnings test, to count for that period.

A man in recovery. David is in an outpatient drug and alcohol treatment program. Participating in a treatment and rehabilitation program is an exclusion, and a substance use disorder is listed among the medically frail conditions. He should make sure the state has a record of his treatment.

The summer problem

The Tribune quoted a substitute teacher who said the 80-hour or $580 threshold is hard to meet in summer. Seasonal workers, school employees and students face the same gap. Utah Medicaid describes its look-back as requiring that you met the requirement in at least one month since your last approval or renewal, but how DWS applies the look-back to a given case is exactly the kind of detail to confirm with DWS rather than assume. If your work is seasonal, keep records of the months you do meet it, and ask DWS how your months will be counted before your review.

How Utah says it will check

The month-by-month mechanics are where people lose coverage under rules like this, so Utah's stated approach matters. Utah Medicaid says:

The Tribune reported that the state has been building a list of "medically frail" conditions, a self-screener and a medical form, and that DHHS and DWS expected to hire additional staff.

The other changes on January 1

Six-month reviews

Adults in Adult Expansion and TAM move from a renewal once a year to a review every six months. Members of other Medicaid programs keep their current schedule. American Indians and Alaska Natives with verified status stay on the 12-month cycle.

Less retroactive coverage

Medicaid has allowed applicants to ask for coverage of medical bills from up to three months before the month they applied. From January 1, 2027, Utah Medicaid says that window shrinks to one month for Adult Expansion and two months for most other programs. If you have unpaid medical bills or an emergency, apply right away.

Already in effect: the immigrant eligibility change

Separately, Utah Medicaid says that since October 1, 2026, Medicaid eligibility has generally been limited to U.S. citizens and nationals, green-card holders with at least five years in the U.S., certain Cuban and Haitian entrants, and COFA migrants. Refugees, asylees, humanitarian parolees and survivors of trafficking or domestic violence may no longer qualify, though children and pregnant people may still qualify for coverage. Our Utah health insurance guide covers how the same law changes Marketplace subsidies for 2027.

How many people, and what the state is worried about

A DHHS spokesperson told The Salt Lake Tribune in August 2026 that more than 40,000 Utahns on Medicaid would have to document whether they meet the requirement, an estimate the department said was subject to change. The same report said Utah Medicaid began sending warning letters to members on July 15, and that Utah had asked federal regulators several times for permission to run its own version of the requirement without receiving approval.

Utah Medicaid Director Julie Ewing told a legislative interim committee that parts of the federal rule were "causing states a lot of confusion," and warned of possible "large federal disallowances" if regulators found the state too lenient, the Tribune reported.

What happens if you lose coverage

Two consequences make it worth acting early rather than late:

Utah Medicaid says that anyone who thinks they may be eligible for Medicaid or CHIP can apply at any time, and can reapply even after losing coverage before.

What to do now

  1. Update your contact information in myCase at mycase.utah.gov. Utah Medicaid calls this the best way to make sure you get its updates.
  2. Read every letter from Utah Medicaid and DWS. The state says it will send more information and a renewal letter when it is time to act.
  3. Figure out whether you are exempt. If you are a parent of a child 13 or younger, pregnant, have a disability, a mental health or substance use condition, or another excluded status, make sure the state knows. The state is building a self-screener and a medical form for medical frailty.
  4. If you are not exempt, start tracking. Keep pay stubs, school enrollment records or a log of volunteer hours with the organization's contact information, even before anyone asks.
  5. Use the earnings test. If your hours vary but you earn at least $580 in a month, that month counts.
  6. Get help if you need it. Take Care Utah's assisters help with Medicaid renewals and DWS letters at no cost: 801-433-2299. DWS eligibility questions: 1-866-435-7414.

If you get a notice that you did not meet it

Medicaid members have the right to a fair hearing when coverage is denied or ended, and the notice itself explains how to appeal and by when. Read the deadline first. If you believe you qualified for an exclusion the state did not know about, or your hours were not counted, gather the proof (a doctor's note, school enrollment, pay stubs, a letter from the place you volunteer) and appeal before the deadline. Take Care Utah's assisters help members respond to DWS notices at no cost, and our free legal help guide lists the legal aid hotline and clinics in Utah County.

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Where to volunteer or train in Utah County

If you need hours, community service and job training both count. Our volunteering guide lists organizations across the county, and a DWS employment center can point you to job training and work programs. Keep a record of each month's hours with a contact at the organization who can confirm them.

In Spanish

Our Spanish-language guide, Seguro médico en Utah para 2027, explains the work requirement, the immigrant eligibility change and CHIP in Spanish.

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Frequently Asked Questions

When does Utah's Medicaid work requirement start?
January 1, 2027. Utah Medicaid says that from that date, adults covered by the rule must show they are working or active in their community to keep coverage, and some adults will move from yearly to six-month eligibility reviews. The Department of Workforce Services enforces it.
Who has to meet the work requirement?
Adults ages 19 to 64 in Utah's Adult Expansion Medicaid and Targeted Adult Medicaid (TAM) programs, unless they qualify for an exclusion. Children, pregnant and postpartum members, people who get Medicaid because of a disability and people in other Medicaid programs are not covered by the rule.
What counts toward the 80 hours?
Working a job, training for a job or taking part in a work program, going to school at least half-time, and volunteering in community service, alone or in combination, for 80 hours a month. Earning at least $580 a month also satisfies it, and members can instead show why they cannot work or volunteer.
Who is exempt?
Per Utah Medicaid: people who are pregnant or on postpartum Medicaid; current or former foster youth; American Indians and Alaska Natives; parents, guardians or caregivers of a child 13 or younger or of a person with a disability; veterans with a 100% disability rating; the medically frail, including people with blindness, a disability, a substance use disorder or mental health condition, or a condition that makes daily tasks hard; people subject to SNAP or TANF work rules; people who are incarcerated; and people in a drug or alcohol treatment program.
Do I have to do anything right now?
Not yet. Utah Medicaid says members do not need to act now and will receive a renewal letter when it is time. The two things to do now are to make sure your address and phone number are correct in myCase at mycase.utah.gov, and to read every letter from Utah Medicaid or DWS.
Will I have to send in pay stubs every month?
Not necessarily. Utah Medicaid's letter to members says it will check records it already has first, and that members who already show work, school or other benefits in those records may not need to send paperwork. It says it will tell members if they need to report and what to do next. Proof may be required every six months at review.
How many Utahns are affected?
A Utah Department of Health and Human Services spokesperson told The Salt Lake Tribune in August 2026 that more than 40,000 Utahns on Medicaid would have to document whether they meet the requirement, and said the estimate was subject to change.
If I lose Medicaid for not meeting the requirement, can I get a Marketplace subsidy instead?
Generally no. KFF reports that under the 2025 federal law, adults who lose or are denied Medicaid solely for failing the work requirement cannot get premium tax credits on the Marketplace in 2027. That is a reason to report on time or claim an exemption you qualify for, rather than letting coverage lapse.

Sources

The facts in this guide were checked against these sources. Hours, fees and rules change, so confirm anything time-sensitive with the source before you go. How we make Provo.com.

  1. Community Engagement Requirement, Utah Medicaid (DHHS). Checked November 13, 2026.
  2. HR 1 (One Big Beautiful Bill Act, 2025): eligibility reviews, retroactive coverage, immigrant changes, important dates, Utah Medicaid (DHHS). Checked November 13, 2026.
  3. Community Engagement Requirement and Eligibility Review Member Letter (July 2026), Utah Medicaid (DHHS). Checked November 13, 2026.
  4. Utah Medicaid and HR 1: FAQ for members, Utah Medicaid (DHHS). Checked November 13, 2026.
  5. Medicaid Expansion (TAM transition July 1, 2027), Utah Medicaid (DHHS). Checked November 13, 2026.
  6. Medicaid work requirement could... (Aug. 4, 2026), The Salt Lake Tribune. Checked November 13, 2026.
  7. 9 Things to Watch for the 2027 ACA Open Enrollment Period, KFF. Checked November 13, 2026.
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