On January 1, 2027, a seismic shift will hit the nation’s public workforce system.
That’s the day the new federal Medicaid work requirements take effect. Created under last year’s One Big Beautiful Bill Act, 18.5 million adults will be required to complete 80 hours per month of work, community service, education, or participation in a qualifying work program to retain their health care coverage under Medicaid.
Millions of SNAP participants are already subject to expanded work requirements under the same law — including roughly 6.5 million adults without dependents who weren’t meeting the 80-hour threshold when last measured. The two groups overlap — about one in five adults subject to the Medicaid requirement also receives SNAP — and federal law treats SNAP compliance as satisfying the Medicaid requirement. That makes workforce boards the single front door for both: every person we help document 80 hours secures their food assistance and their health coverage at once.
The rules announced by the federal Centers for Medicare & Medicaid Services (CMS) are clear: WIOA Title I programs count as qualifying work activities. This means the public workforce system will be central to helping millions of people document, verify, and maintain compliance.
This is not a hypothetical policy change. It is a real, imminent operational burden that will fall squarely on local workforce boards, frontline staff, and the infrastructure they manage every day.
NAWB is submitting comments this week on the proposed federal rule and we are requesting a briefing from CMS for the workforce community because, as of this writing, many States have more questions than answers about how to fully implement this work.
What This Means for Workforce Leaders
The rule requires verification at application and every renewal that enrollees are meeting the 80‑hour requirement, which states are authorized to verify on a monthly basis. CMS encourages states to coordinate with workforce agencies on data sharing and alignment of job‑search activities to help meet these newly expanded federal administrative requirements.
In practice, this means:
The public workforce system is the only national infrastructure capable of supporting 18.5 million individuals who must now navigate work‑requirement compliance. But it cannot absorb this surge without meaningful federal investment.
The Stakes for FY27
The House Appropriations Committee approved a bill in June that would cut WIOA Title I formula grants by 62 percent, effectively eliminating WIOA Adult and Youth funding.
At the exact moment when the workforce system is being asked to support millions more people, federal funding is at risk of shrinking.
Workforce boards cannot meet the demands of the modern economy—or the demands of new federal mandates—without strengthened investment.
What Workforce Leaders Can Do Right Now
Congress needs to hear directly from workforce leaders about what the Medicaid work requirements will mean on the ground: the administrative burden, the surge in demand, the strain on staff, and the risk of leaving millions of people without the support they need to comply.
There are 18.5 million reasons to advocate today. Congress must hear from us before FY27 decisions are made.
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