Since October 1, some lawfully present immigrants no longer qualify for Medicaid.

A federal change under H.R. 1 ended Medicaid and CHIP eligibility for many people who are in the United States legally — including refugees and people granted asylum who don't yet have a green card, humanitarian parolees, survivors of trafficking, and people with Temporary Protected Status. Emergency Medicaid still covers emergency care and childbirth. People who remain eligible include US citizens, green-card holders who meet the five-year rule, Cuban and Haitian entrants, and COFA citizens of the Marshall Islands, Micronesia and Palau. If this may affect you or someone in your household, open any letter your state sends and ask about a community health center near you — they charge on a sliding scale regardless of immigration status. Read the full explainer →

The new work rules start in 92 days — and they do reach some people in Tennessee See who →

All states Tennessee

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.

Work rules start Jan 1, 2027 Medicaid never expanded 1,524,000 enrolled
Start here

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:

Adults with no dependent child at home, who have no TennCare pathway at any income anyway.
Children, and anyone covered through CoverKids.
People who are pregnant, or within 12 months of a pregnancy.
People covered on the basis of age, blindness or disability.
Parents covered under the state plan's own mandatory pathway, below its income standard.

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.

Exemptions

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.

Parents or caretakers of a child 13 or under, or of a person with a disability
Pregnant or postpartum
Medically frail, or with serious or complex medical needs
Veterans with a total disability rating
American Indian or Alaska Native
In a drug or alcohol treatment program
Already meeting SNAP or TANF work requirements
Recently released from incarceration
The coverage gap

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.

54%
are in working familiesAt least one person in the household has a job. This is not a gap about not working.
22%
have a disabilityNot all disabilities meet the strict test that opens a Medicaid pathway.

Figures from CBPP, March 2026. Credible estimates range from 81,000 to 95,000; we quote the most recent.

Income limits

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.

Who you are
Income limit
What to know
An adult with no children at home
No pathway
No pathway at any income. Adults without a dependent child in the home, who are not pregnant and not aged, blind, or disabled, cannot qualify for TennCare at any income level, including $0.
A parent or caretaker relative
$2,277/mo
Must be a parent or caretaker relative of a dependent child under 18 (or 18 and a full-time student) living in the home. Figure shown is for a household of three.
A child, age 0 up to 1st birthday
$4,440/mo
195% of the poverty line, household of three.
A child, age 1 up to 6th birthday
$3,233/mo
142% of the poverty line, household of three.
A child, age 6 up to 19th birthday
$3,028/mo
133% of the poverty line, household of three.
A child, tenncare standard (children losing medicaid who are uninsured, no access to insurance)
$4,804/mo
211% of the poverty line, household of three.
Pregnant
$4,440/mo
195% of the poverty line. Coverage continues for 12 months of continuous coverage after the pregnancy ends after the birth. Consistent with the federal american rescue plan option all states must now follow. Pregnancy is also an exemption from the work requirement.

Source: TennCare Eligibility Reference Guide and TennCare Member/Applicant Eligibility Categories page (tn.gov/tenncare), current monthly income chart, 2025 Federal Poverty Guidelines.

January 1, 2027

What else changes that day

Back-dated coverage gets shorter It was 3 months. If you already have unpaid medical bills, applying sooner covers more of them.

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).

EnglishSpanishArabicChineseVietnameseKoreanFrenchAmharic

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.

If a letter arrives

“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.

Division of TennCare (Tennessee Department of Finance and Administration) · Notice of action

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.

1
The clock starts on this date. Not the day it reached you. Assume you have less time than it feels like.
2
Answer it, don't accept it. If you worked those hours, or an exemption fits you, say so — call 1-855-259-0701. You generally get 30 days to show the state what it could not see.
3
Your children's coverage is separate. The work requirement does not apply to them. A notice about you does not end their coverage.
4
You can ask for a fair hearing. It's free, you don't need a lawyer, and asking can keep your coverage running while it is reviewed.
Common questions

Questions people ask about this

Tennessee didn't expand Medicaid. Do the new work rules really apply here?
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 exactly does the work requirement affect 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.
How many hours, and what counts?
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 is exempt in Tennessee?
Exemptions include: Parents or caretakers of a child 13 or under, or of a person with a disability; Pregnant or postpartum; Medically frail, or with serious or complex medical needs; Veterans with a total disability rating; American Indian or Alaska Native; In a drug or alcohol treatment program; Already meeting SNAP or TANF work requirements; Recently released from incarceration.
What should I do before January?
Make sure the state has your current address and phone number, because everything about this arrives by mail. Then keep proof of whatever you do that counts — payslips, enrollment records, volunteer sign-in sheets, or evidence that an exemption fits you.
How do I apply for TennCare?
Online at TennCare Connect (tenncareconnect.tn.gov), or by phone on 1-855-259-0701. It is free, and Medicaid has no open-enrollment window — you can apply at any time of year.
How do I renew Tennessee Medicaid?
The state reviews eligibility at least once a year and mails or posts a renewal notice. Answer it before the date on the letter, even if nothing has changed. Keep your address and phone number current so the notice reaches you — most people who lose coverage lose it over paperwork, not because they stopped qualifying.

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) →