The recent changes in the Medicaid program, signed into law by President Trump on July 4, 2025, have introduced significant modern requirements for states, particularly regarding perform conditions for eligibility. Beginning January 1, 2027, states will be mandated to implement work requirements for individuals enrolled through the Affordable Care Act (ACA) Medicaid expansion pathway, along with certain state waivers. This legislation aims to streamline compliance by allowing states to verify work activity or exemption status using available information without the demand for additional documentation from individuals.
One of the critical intersections in this new regulatory landscape is the relationship between Medicaid and the Supplemental Nutrition Assistance Program (SNAP). Both programs cater to low-income households, and many individuals benefit from both. In fact, a significant majority of SNAP recipients are as well covered by Medicaid. Due to this overlap, some states have developed integrated systems to share data between the two programs, facilitating smoother compliance with the new requirements.
As the new Medicaid work requirements are set to take effect, changes to SNAP work requirements are also anticipated, leading to potential impacts on enrollment in both programs. According to estimates from the Congressional Budget Office (CBO), the implementation of Medicaid work requirements could result in an increase of 5.3 million uninsured individuals over the next decade, while approximately 2.4 million people may be expected to drop out of SNAP participation monthly during the 2025-2034 period. This highlights the significant overlap in the populations that may lose benefits from both programs.
Understanding Medicaid and SNAP Work Requirements
Under the new law, starting January 1, 2027, states will require adults enrolled in Medicaid expansion programs, including those in partial expansion waiver programs like Georgia and Wisconsin, to complete 80 hours of work or community service each month or meet specific exemption criteria to remain eligible for coverage. Verification of work or exemption status will be mandatory at both application and renewal times.
The law outlines mandatory exemptions, such as those for individuals in households receiving SNAP benefits who are not exempt from SNAP work requirements. Other exemptions include parents or caretakers of children aged 13 and under, individuals deemed “medically frail,” and pregnant or postpartum individuals. If a state cannot verify a participant’s compliance or exemption status through data matching, it must provide a notice of noncompliance and may deny or disenroll individuals who cannot demonstrate compliance within 30 days.
SNAP Work Requirements and Their Changes
SNAP has its own set of work requirements and exemptions, which do not entirely align with those of Medicaid. Most adults on SNAP must meet general work requirements, while “able-bodied adults without dependents” (ABAWDs) must work or engage in a work program for at least 80 hours monthly to maintain SNAP benefits beyond three months within a 36-month period. Recent changes to SNAP, effective at the end of 2025, expand the population subject to these requirements by including adults aged 55 to 64 and parents with children aged 14 and older, while also removing previous exemptions for veterans and young adults transitioning from foster care.
Impact on Enrollment and Coordination Between Programs
Approximately one in five adults covered by Medicaid who will be subject to the new work requirements also receives SNAP benefits. This overlap is largely due to similar eligibility criteria in Medicaid expansion states, where the income limit for adults is set at 138% of the federal poverty level (FPL). For 2026, this translates to an income limit of $22,024 for an individual. Meanwhile, the SNAP income eligibility limit is 130% FPL, or $1,696 per month, with a net income limit of $1,305 reflecting certain deductions.
Given this overlap, many states are already using SNAP information to help determine Medicaid eligibility. For instance, 29 states allow individuals to apply for both Medicaid and SNAP via a single online application, and 24 states utilize a shared system for eligibility determinations. 33 states plan to use SNAP data to identify changes in eligibility during renewals, which can streamline processes and reduce administrative burdens.
Leveraging SNAP Data to Implement Medicaid Work Requirements
States can effectively utilize SNAP data to identify individuals who may qualify for exemptions from Medicaid work requirements. By leveraging existing data, states can facilitate compliance and alleviate the administrative burden on both enrollees and Medicaid staff. While formal guidance from the Centers for Medicare & Medicaid Services (CMS) is pending, it is anticipated that states will be required to access SNAP and Temporary Assistance for Needy Families (TANF) data to verify compliance with work requirements.
The experience of Arkansas, which implemented work requirements in 2018, serves as a case study for how states can utilize SNAP data. In February 2019, Arkansas found that 87% of individuals subject to work requirements were either meeting the requirements or exempt, thanks to data matching efforts. This approach demonstrates the potential for states to streamline verification processes without adding undue burden on individuals.
As states move forward with these changes, the integration of Medicaid and SNAP eligibility systems will be crucial. States that currently lack connections with SNAP will need to develop data-sharing interfaces, which may present challenges. States that have integrated systems will need to prioritize completing work requirement changes for SNAP, which may delay Medicaid changes.
Looking ahead, the implementation of these new work requirements will require careful navigation by states to balance compliance, resource allocation, and the needs of low-income families reliant on both Medicaid and SNAP. As these changes unfold, it will be essential for stakeholders to monitor the impacts on enrollment and access to benefits.
This article is intended for informational purposes only and does not constitute professional advice. Readers are encouraged to share their thoughts and insights in the comments below.
