New Jersey is asking federal officials to simplify the documentation process before the eligibility requirement takes effect.
TRENTON, NJ – Approximately 540,000 New Jersey adults could be screened under a new federal Medicaid work and community activity requirement beginning Jan. 1, 2027, prompting state officials to ask for fewer forms and broader use of information the government already possesses.
The New Jersey Department of Human Services said Aug. 17 that it submitted comments asking the Centers for Medicare & Medicaid Services to simplify the rule, particularly for people with serious physical illnesses, mental health conditions or substance-use disorders.
The requirement generally applies to nonpregnant adults ages 19 through 64 who receive Medicaid through the Affordable Care Act expansion group and are not enrolled in Medicare.
Under the CMS rule, an affected adult can qualify for a month by:
- Working, performing community service or participating in an approved work program for at least 80 hours.
- Attending an educational program at least half time.
- Combining qualifying activities to reach 80 hours.
- Earning at least $580 during the month in 2026, equivalent to 80 hours at the federal minimum wage.
The rule contains exemptions for several groups, including pregnant and postpartum residents, former foster youth, American Indians and Alaska Natives, totally disabled veterans, people considered medically frail, participants in drug or alcohol treatment, and parents or caregivers of children age 13 or younger or people with disabilities.
States may also offer temporary hardship exceptions in areas with high unemployment or a declared disaster, or when a resident must travel for certain medical care.
Compliance will be checked at application and renewal. If New Jersey cannot verify that a resident met the requirement or qualified for an exemption, it must provide 30 days for that person to submit proof. An application can be denied or an enrollee can lose coverage if the issue is not resolved. A disenrolled resident may reapply.
New Jersey is asking CMS to reduce the amount of medical documentation residents must produce, streamline renewals, rely more heavily on existing government data and give states additional implementation guidance, according to the Aug. 17 Human Services announcement.
CMS says states must conduct outreach before implementing the requirement. New Jersey’s announcement did not establish a new resident filing deadline or ask enrollees to submit work records now.
The potential consequences extend beyond people who are not working. Residents who work, attend school or qualify for an exemption can still face a coverage interruption if the state cannot verify their circumstances.
In a May assessment of the broader federal Medicaid eligibility changes, New Jersey estimated that more than 300,000 NJ FamilyCare participants could eventually lose coverage. That projection covers more than the work requirement alone and remains subject to federal guidance, state implementation decisions and enrollment patterns, the state analysis cautions.
The interim federal rule became effective July 31 and requires states to implement the program no later than Jan. 1, according to the Federal Register.
Editor’s note: This article explains upcoming Medicaid work and community activity requirements based on information from the Centers for Medicare & Medicaid Services, the New Jersey Department of Human Services and the Federal Register. The rules are scheduled to affect certain New Jersey Medicaid recipients beginning Jan. 1, 2027. Eligibility and exemption decisions depend on individual circumstances and state implementation. Residents should rely on official NJ FamilyCare and government notices for instructions and should not submit documents solely because of this report.