All states Tennessee
Tennessee's work rules reach further than people expect
TennCare is run by Division of TennCare (Tennessee Department of Finance and Administration). Tennessee never adopted Medicaid expansion — and the new federal work requirement still applies to some people here, because it reaches certain waiver coverage too.
Not expanding Medicaid did not put Tennessee outside the new rules
Yes. CMS has identified Tennessee as subject to the new federal work requirement, even though the state never expanded Medicaid.
The requirement is not limited to states that expanded Medicaid. It also reaches adults enrolled through a Section 1115 waiver that provides full coverage to people who are not otherwise eligible under the state's own Medicaid plan. TennCare III covers parents above the state plan's income standard up to the poverty line through exactly that authority.
Who this actually reaches in Tennessee
If you are a parent on TennCare and your income is in the upper part of the range — closer to $2,277 a month for a household of three than to the bottom of it — you are the group this reaches.
80 hours in a single qualifying month of work, volunteering, a work program, study, or any combination of them. Earning at least $580 in a month also satisfies it.
Who it does not reach. If one of these describes you, the requirement is not yours to worry about:
One thing genuinely still moving. CMS has said it is working with states whose affected groups are small to see whether some kind of exception is possible, so Tennessee's position could still change. Nobody should tell you this is settled either way — what is settled is that CMS has listed Tennessee.
Tennessee had not been building systems for this, because it was widely assumed that a state which never expanded Medicaid was outside the rule. CMS named Tennessee anyway.
If your hours swing from month to month, say so. The rule is written per month, which is the wrong shape for farm and fishing work, construction, tourism and seasonal retail — a good month and a dead month average out to a living, but the dead month is the one that fails. Federal law has a provision for exactly this: a seasonal worker can satisfy the requirement using their average monthly income over the previous six months instead of hours worked in the month being checked. It is at 42 CFR 435.552(a)(7), and the law defines who counts as seasonal by pointing at the tax code rather than listing jobs, so do not decide for yourself that it misses you. If your work is seasonal or your hours are irregular, tell the state that when you report, and ask for the six-month average to be used.
You do not have to prove anything if any of these fit you
The state is supposed to apply these automatically from records it already holds. Records are imperfect. If one of these describes you and you are still asked to report hours, say so and ask them to check rather than assuming the notice is right.
91,000 people here earn too much for Medicaid and too little for help buying a plan
Separately from the work rules, Tennessee leaves a group above its Medicaid limit but below the poverty line, where federal help with premiums begins. There is nothing in between.
Figures from CBPP, March 2026. Credible estimates range from 81,000 to 95,000; we quote the most recent.
What you can earn and still qualify
Monthly household income before tax. These are the state's own published figures, which is what its caseworkers apply. If you are near a line, apply anyway — some income does not count, and only the agency can run the calculation for your household.
Source: TennCare Eligibility Reference Guide and TennCare Member/Applicant Eligibility Categories page (tn.gov/tenncare), current monthly income chart, 2025 Federal Poverty Guidelines.
What else changes that day
P.L. 119-21 §71112, amending 42 U.S.C. §1396a(a)(34).
Do this now
Update your address and phone number first. Everything about the new rules arrives by mail, and a stale address is the most common reason people lose coverage they are still entitled to. Then keep proof of whatever you do that counts, and check the exemption list.
Deaf, hard of hearing or speech-impaired: 711 (or 1-800-848-0298).
TennCare provides free interpreter and translation help in any language, by phone, electronically, or in person — ask when you call TennCare Connect at 1-855-259-0701 (TTY 711 or 1-800-848-0298). Materials already translated include Spanish, Arabic, Chinese, Vietnamese, Korean, French, Amharic, Gujarati, Lao, German, Tagalog, Hindi, Russian, Japanese, and Persian, but TennCare does not limit help to that list — if your language isn't on it, ask anyway, since a qualified interpreter can still be arranged at no cost.
“Our records do not show” is not the same as “you did not”
The state checks against employment and benefit databases that are often incomplete or out of date. A notice saying it cannot see your hours is a gap in its records, which you can close.
NOTICE OF ELIGIBILITY DETERMINATION
Case number: ███████
Date of this notice: 1January 12, 2027
Our records do not show that you met the community engagement requirement for the reporting period.
2If you believe this is incorrect, or if an exemption applies to you, contact us on or before February 11, 2027.
3Coverage for other members of your household is not affected by this notice.
Questions people ask about this
Tennessee didn't expand Medicaid. Do the new work rules really apply here?
Who exactly does the work requirement affect in Tennessee?
How many hours, and what counts?
Who is exempt in Tennessee?
What should I do before January?
How do I apply for TennCare?
How do I renew Tennessee Medicaid?
Guides for neighboring states
The rules change completely at the state line. If you moved recently, or you're helping family somewhere else, start with their state rather than this one.
Tennessee was not expected to be covered by the new federal work rules, and CMS has now listed it anyway — for parents on TennCare whose income sits above the state plan's own standard.
The state has not finished building for it and the detail may still change, so if you are a parent on TennCare, keep your address current and hold on to proof that you work, study, volunteer or care for someone.
Updating your contact details takes two minutes and protects everything else. Do that first, then check whether an exemption fits you.
Go to TennCare Connect (tenncareconnect.tn.gov) →