New Medicaid & SNAP Rules: What Changes Indicate for Millions
Starting January 1, 2027, significant changes to Medicaid and the Supplemental Nutrition Assistance Program (SNAP) will take effect, impacting millions of Americans. A recent reconciliation law introduces new work requirements for Medicaid eligibility and aligns SNAP requirements more closely with those of Medicaid. These changes are projected to increase the number of uninsured and reduce participation in SNAP.
Understanding the New Work Requirements
Beginning in 2027, states must require adults enrolled in Medicaid expansion programs and certain waiver programs to complete 80 hours of work or community service each month, or meet specific exemption criteria to maintain coverage. States are directed to utilize available data to verify compliance, minimizing the burden on individuals to provide additional documentation.
SNAP also has work requirements, particularly for “able-bodied adults without dependents” (ABAWDs), who must work or participate in a work program for at least 80 hours monthly to receive benefits for more than three months in a 36-month period. Recent changes to SNAP requirements, effective at the finish of 2025, expand the population subject to these requirements to include adults ages 55 to 64 and parents with children ages 14 and older, while removing some previous exemptions.
The Intersection of Medicaid and SNAP
A significant overlap exists between Medicaid and SNAP recipients. Approximately one in five Medicaid-covered adults likely to be subject to the new work requirements also receive SNAP benefits. This overlap is particularly pronounced in states that have expanded Medicaid. Income eligibility limits are similar, with Medicaid at 138% of the federal poverty level and SNAP at 130% gross and 100% net monthly income.
Many states are already coordinating eligibility processes between the two programs. As of January 2025, 29 states allow a single application for both Medicaid and SNAP, and 24 states share a single eligibility determination system. 15 states use SNAP income determinations for Medicaid enrollment, and 33 utilize SNAP information to identify eligibility changes.
How States Can Leverage SNAP Data
States can utilize SNAP data to streamline the implementation of Medicaid work requirements. This includes identifying individuals exempt from Medicaid work requirements due to their SNAP status and verifying compliance with work hour requirements. Data matching can reduce administrative burdens and minimize the risk of eligible individuals losing coverage due to documentation issues.
Arkansas’s experience in 2018, when it implemented work requirements, provides a case study. The state was able to verify the work or exemption status of 87% of individuals subject to the requirements through data matching, primarily utilizing information related to existing employment, SNAP participation, dependent children, and medical frailty.
Challenges and Considerations for States
While data sharing between Medicaid and SNAP can be facilitated by integrated eligibility systems, states may face challenges. States without existing linkages will need to establish new interfaces to share data. States must balance implementing SNAP and Medicaid changes while also preparing for changes to the Medicaid payment error rate measurement (PERM) program, which could impact federal funding.
Beginning in 2028, states may be required to pay a portion of SNAP benefit costs based on their payment error rate. Starting October 1, 2029, federal Medicaid financial participation may be reduced for states exceeding a three percent PERM eligibility error rate.
FAQ
Q: When do the new Medicaid work requirements take effect?
A: January 1, 2027.
Q: Will everyone on Medicaid have to meet work requirements?
A: No, exemptions exist for certain individuals, including those receiving SNAP benefits and not exempt from SNAP work requirements, parents with young children, and those who are medically frail.
Q: How will states verify compliance with work requirements?
A: States are directed to use available data from reliable sources, including SNAP, to verify work or exemption status.
Q: What is the PERM program?
A: The payment error rate measurement (PERM) program assesses the accuracy of Medicaid eligibility determinations and can impact federal funding.
Did you know? Approximately 5.3 million more Americans are projected to be uninsured over the next ten years due to the new Medicaid work requirements.
Pro Tip: If you are concerned about how these changes may affect your Medicaid or SNAP benefits, contact your state’s Medicaid agency or SNAP office for more information.
Stay informed about changes impacting your healthcare and food assistance benefits. Explore additional resources on the Kaiser Family Foundation website and your state’s official government websites.
