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Utah Medicaid and the new work rules
Adult Expansion Medicaid is run by Utah Department of Health and Human Services (DHHS), Division of Integrated Healthcare — with eligibility, applications and renewals run by the Utah Department of Workforce Services (DWS) through the myCase account. Utah expanded Medicaid on January 1, 2020, which is why the new federal work requirement reaches this state — and why what you do before January 1, 2027 matters.
From January 1, 2027, most adults have to show 80 hours a month
The requirement applies to adults aged 19 to 64 covered through Medicaid expansion — around 77,663 people in Utah. It is not only about paid work: study, job training, volunteering and a mix of them all count , and earning at least $580 a month satisfies it on its own.
Utah checks first and asks second. The state says it will look at wage records it already holds, Workforce Services data, SNAP and TANF participation, Medicaid claims and information from your health plan, and that if those records already show you working, in school or receiving other benefits, you may not need to send anything in at all. Utah elected the shortest look-back the federal rule allows: one month. A new applicant is judged on the month before the month they apply; a current member on the period between their last renewal or approval and now. Utah Code requires documentary evidence and bars the department from relying on self-attestation alone, so when the records do not show it, a letter comes — and from the date on that letter you have 30 days to answer.
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 describe you
Exemptions are meant to be applied by the state automatically from records it already holds, but records are imperfect. If one of these fits you and you still get asked to report hours, say so and ask them to check — don't assume the notice is right.
What you can earn and still qualify
Monthly income, before tax, for the whole household. These are the state's own published figures, which is what its caseworkers actually apply. If you are close to a line, apply anyway — some income does not count, and only the agency can run the calculation for your situation.
Adults 19 to 64133% of the poverty line
- 1 person
- $1,769
- 2 people
- $2,399
- 3 people
- $3,028
- 4 people
- $3,658
- 5 people
- $4,288
- 6 people
- $4,917
- 7 people
- $5,547
- 8 people
- $6,176
Pregnant139% of the poverty line
- 1 person
- $1,849
- 2 people
- $2,507
- 3 people
- $3,165
- 4 people
- $3,823
- 5 people
- $4,481
- 6 people
- $5,139
- 7 people
- $5,797
- 8 people
- $6,455
Source: Utah DHHS Medicaid Policy Manual, Table VII — Income Limits for Medical and Medicare Cost-Sharing Programs, effective March 1, 2026, read alongside the Utah Medical Program Summary (DWS form 5-996, January 2026) and the CHIP Table I income limits effective March 1, 2026. A note on precision: Utah's table sets the Adult Expansion limit at 133% of the poverty line, which is $1,769 a month for one person and $3,028 for a household of three — and then takes a disregard worth 5% of the poverty line off your income before the comparison is made, which is about $67 for one person and $114 for three. We publish the state figure.
Two other changes land on the same day
Renewals get more frequent, and back-dated coverage gets shorter.
P.L. 119-21 §71112, amending 42 U.S.C. §1396a(a)(34). Applies to applications submitted on or after January 1, 2027.
Utah has a law that would end expansion automatically
Coverage here is tied by statute to how much the federal government pays.
Who this reaches. The law covers adults 19 through 64 covered through Adult Expansion Medicaid — Utah's own health department has estimated that about 83,000 people would lose coverage if this fired, with the state's Medicaid program losing $1.4 to $1.5 billion a year.
Utah Code 26B-3-210(4)(a), as rewritten by House Bill 15 of the 2026 General Session and effective May 6, 2026. If the expansion matching rate is reduced below 90%, the department's authority to run Medicaid expansion sunsets the day after the Legislature adjourns from the next general session, and the department must then begin terminating the expansion waiver and changing its systems to carry the termination out.
This is a hard trigger, not a review clause. It ends the department's authority automatically, with no further vote needed, and the only discretion left is over timing. Utah is one of ten states that KFF and Georgetown CCF both classify as having a trigger that requires termination of expansion rather than merely mitigating action. The 2026 Legislature looked at it and tightened it rather than loosening it: House Bill 15 replaced an older sunset date of the next July 1 with the end of the next general session, and added a new duty at 26B-3-210(4)(c) requiring the department to abandon any discrete program that would itself cause the expansion matching rate to drop, before the first reduction hits. There is also a separate reporting duty at 26B-3-210(4)(d): within 60 days of determining the rate will fall below 90%, the department must put a proposal to the legislature's budget committees, and one of the seven options it is required to consider is eliminating coverage for optional populations inside the expansion.
Unexercised. The matching rate has not fallen, expansion has run without interruption since January 1, 2020, and no Utahn has lost coverage through this provision. The trigger originated in the 2019 rewrite of Proposition 3, as Utah Code 26-18-415(5)(a), and was carried into 26B-3-210 by the 2023 recodification of Utah's health and human services title. Georgetown CCF has flagged an unresolved question that applies here as much as anywhere: whether a per-person cap on federal funding, as opposed to a direct cut to the matching rate, would pull a trigger written in terms of the rate. Nobody has answered it.
Nothing has changed, and this is not a reason to delay applying. It is a reason to keep your contact details current, open everything the state sends, and not assume coverage renews itself.
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 check whether an exemption applies to you.
About the phone numbers: The two main numbers do different jobs. Use 1-866-435-7414 for anything about applying, renewing, a review you have been sent, or an address change — that is Workforce Services, and it is the number that matters for the new work rules. Use 1-866-608-9422 once you are enrolled and need to pick or change a plan, find a provider, or get an interpreter. The Utah Medicaid Information Line has an unusual quirk worth knowing: its toll-free number, 1-800-662-9651, only works from Utah, Idaho, Wyoming, Colorado, New Mexico, Arizona and Nevada, and Utah's own page tells callers from anywhere else to use 801-538-6155 instead. Prior authorizations on that line are options 3, then 3, then your program.
Deaf, hard of hearing or speech-impaired: 711.
Free interpreter line: 1-866-608-9422.
Utah's language-assistance notice is printed in fifteen languages besides English — Spanish, Chinese, Ilocano, Portuguese, German, Vietnamese, Navajo, Japanese, Arabic, Greek, Serbo-Croatian, Russian, Tagalog, Korean and French — and it says plainly that free language help and accessible formats are both available on 1-866-608-9422. Interpreters are free, by phone and at any Workforce Services office, and the Medicaid application itself tells you in capital letters that you have the right to one at no charge. Two lists are worth knowing about, because they do not match: the Medicaid notice includes Navajo but not Samoan or Tongan, while Workforce Services keeps its own interpreter list that adds Burmese, Farsi, Karen, Kinyarwanda, Samoan, Somali, Swahili and Tongan but leaves Navajo out. If your language is on either list, ask. If it is on neither, ask anyway — the promise is to find someone who speaks your language, not to work from a list. Spanish is the one language with a full set of translated documents, including both application forms, the process guides and the whole of chipespanol.utah.gov; other languages are served by interpreters and by taglines rather than by translated paperwork, and the Medicaid member guide comes in Spanish and braille on request rather than as a download. The Translate button on medicaid.utah.gov is machine translation rather than a translated document, so use it to get your bearings and check anything that matters with an interpreter on 1-866-608-9422.
Most people who lose coverage lose it over paperwork, not eligibility
26% of the coverage losses recorded in Utah were procedural — a form, a deadline, or an address, rather than a real change in whether someone qualified. From January 1, 2027 that matters more, not less.
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.
What the federal data says about coverage here
Public federal data describes how each state runs its program. Almost all of it is written for policy analysts. Here is what those numbers mean if you are the person enrolled.
Of people who lost coverage here, this share lost it over paperwork rather than eligibility.
Open every letter. Keep your address current with the agency.
Doctors are scarce here by national standards.
Book an appointment before you need one, not when you do.
Coverage here runs through private health plans rather than the state paying providers directly. You pick a plan, and your plan decides your network.
Check your doctor is in the plan before you choose it.
Utah already had a work requirement of its own — and it has not been in force since 2020
You face one work requirement in Utah today, not two — and it does not start until January 1, 2027. Nothing you do at Workforce Services right now is required of you by Medicaid, and nothing you did in 2020 carries forward.
Utah's own page is unambiguous about this, and it is the most useful sentence on the state's website: "Adult Expansion Medicaid members do not need to register for work and do not need to complete the assessment, training programs, or job searches".
CMS approved Utah's community engagement requirement on March 29, 2019 and it took effect January 1, 2020. It applied only to Adult Expansion Medicaid, and only to people aged 19 through 59. It was not an hours rule at all. It asked four things, all of them once a year rather than every month: register for work through the state's online system with the Department of Workforce Services, complete an online assessment of your employment training needs, finish the job training modules that assessment picked out for you, and apply for work with at least 48 potential employers. All four had to be done within three months — the first three months of a twelve-month benefit year, or of being told the requirement applied to you, whichever came later. Do them and you were set for the rest of the year; then you did them again.
There is no fixed number of training modules, and there never was. Utah's waiver says the modules are whichever ones the online assessment determines are relevant to you. The only hard number in the whole scheme is 48 job applications.
Utah suspended it in April 2020 because of COVID-19, before it was ever fully operational. CMS began a withdrawal process in February 2021 and formally withdrew the authority on August 10, 2021, reasoning that the requirement was not in effect, that the pandemic made it infeasible, that a federal maintenance-of-enrollment condition barred it anyway while Utah claimed the enhanced match, and that on balance it was not likely to promote the objectives of the Medicaid statute. Utah did not ask to renew it. It has not operated on a single day since April 2020.
Does registering with Workforce Services count toward the new federal rule? Partly. Creating a job-seeker account is not by itself a qualifying activity. Time spent in an actual work program or in job training does count toward the 80 hours — Utah lists "training for a job or participating in a work program" among the ways to meet it. The more useful point is a different one: if you are already meeting SNAP or TANF work requirements, that is a full exclusion from the federal rule rather than merely credit for hours, and Utah checks for it automatically.
On July 15, 2025 Utah asked CMS for the authority back, for Adult Expansion Medicaid only — it deliberately did not ask for it over Targeted Adult Medicaid. That request is still listed as pending on medicaid.gov and has not been approved, and Utah has asked CMS to take it up as part of the 2027 to 2032 waiver renewal it filed on June 30, 2026. Utah has also said it would need at least six months of operational readiness after any approval before it could run the program. So the earliest a Utahn could face both rules is well into 2027, and only if CMS says yes.
If CMS does approve it, the two would run side by side on different logic, and the mismatch is worth understanding now. Federally, doing 80 hours a month of qualifying activity is how you comply. Under Utah's pending state rule, working 30 hours a week or more is what exempts you from the four-step Workforce Services pipeline — so the same activity is a compliance test in one scheme and an exemption trigger in the other, at different thresholds. Someone working 20 hours a week would satisfy the federal rule and still not earn the state exemption. The two also run on different clocks: a federal check at every six-month review against a state three-month participation window inside a twelve-month cycle. Utah's waiver application does not say how those reconcile, and no official document resolves it.
Utah's pending state exemption list is modelled on SNAP and diverges from the federal one in ways that would matter if it ever came back. Utah would exempt anyone 60 or over; federal law has no age exemption below 65. Utah's caregiver exemption reaches a child under 6; the federal exclusion reaches a child 13 or under. Utah would add people claiming or appealing unemployment insurance, people in the state Family Employment Program, people in refugee employment services, people completing court-ordered activities on probation or parole, and Justice Involved Waiver participants in their first six months after release. The federal list has veterans with a total disability rating, former foster youth and Medicare entitlement, which Utah's does not. Utah's pending design is also gentler on failure than its 2019 one: a three-month suspension rather than immediate closure, with eligibility restored retroactively if you complete the activities during it, and no need to reapply.
One correction to Utah's own account is worth making. The state's page attributes the withdrawal to federal courts, which conflates Utah's story with the national litigation over Arkansas and New Hampshire. Utah's requirement was never struck down in court — CMS withdrew it administratively, under 42 CFR 431.420(d).
Utah DHHS, medicaid.utah.gov/expansion/, section headed "Community Engagement Requirement is Withdrawn"; CMS approval letter of March 29, 2019 for Utah demonstration project numbers 11-W-00145/8 and 21-W-00054/8; CMS withdrawal letter to Utah of August 10, 2021, reproduced at jobs.utah.gov/customereducation/services/medicaid/081021publicnotice.pdf; Utah's pending Community Engagement Amendment, submitted July 15, 2025; medicaid.gov demonstration and waiver list entry 83321
The requirement also reaches a separate waiver group here
Utah is one of eight states CMS named for an extra 1115 waiver population.
Who that is. Targeted Adult Medicaid, known in Utah as TAM — a small group of adults 19 through 64 with almost no income who are chronically homeless, involved with the justice system, or in need of mental health or substance use treatment, and who get full Medicaid benefits through Utah's section 1115 demonstration rather than through the ordinary expansion group.
The new work rules were written for the ACA expansion group, but federal law also reaches adults covered through a section 1115 waiver that provides full coverage. CMS went through every state's waivers looking for groups that fit, and named thirteen populations across eight states. Utah's row lists two, and that needs explaining: Utah covers its expansion adults through the waiver rather than through the ordinary state plan, so Adult Expansion is itself one of the two. The genuinely extra one is Targeted Adult Medicaid. It is a route into full Medicaid for adults 19 through 64 without dependent children whose income is at or below 5% of the poverty line — $67 a month for one person — and who fall into one of three groups: chronically homeless, involved with the justice system, or needing substance use or mental health treatment. You cannot simply apply; you have to be referred by an approved agency, Utah only enrolls during open periods, and the rules let the state cap or close enrollment at any time, though it is open now. Once you are in, coverage runs for twelve months. About 6,900 people were in it in mid-2026, out of roughly 327,000 Utahns on Medicaid. From January 1, 2027 the work rules reach them too — Utah states it plainly on its own community engagement page, naming Adult Expansion and Targeted Adult Medicaid together.
Almost nothing about this coverage sounds like the expansion. You get into it by being chronically homeless or leaving jail or needing treatment, not by earning a certain amount. It has a different name, a referral process instead of an application, and a different income test an order of magnitude below the expansion line. Someone in it has every reason to read the news about Medicaid work requirements and conclude it is about other people. It is not. And the income route out is closed to them by arithmetic: the federal rule lets you satisfy the requirement by earning $580 a month, but Targeted Adult Medicaid caps income at about $67, so essentially nobody in this group can clear the bar that way. What they will clear it on is the exclusions.
Two things here are not settled. CCF reports that CMS has been working with at least some states with small targeted demonstrations to see whether an exception might be allowed; no government source confirms that and the rule itself contains no size-based exception, so treat it as advocacy reporting rather than fact. And Utah's pending 2027 to 2032 renewal is widely described as folding Targeted Adult Medicaid into Adult Expansion from July 1, 2027, which would dissolve this whole question six months after the rules start — but that detail was found only in a non-government explainer and could not be confirmed in Utah's own renewal document. What is settled is that CMS named the group, that Utah's own website says the rules apply to it, and that Utah had specifically asked CMS not to apply its state work requirement here.
If you are covered one of these ways rather than through the ordinary expansion group, the rules above still reach you. Don't assume otherwise because your coverage has a different name.
CMS interim final rule, 91 Fed. Reg. 33348, with the section 1115(a)(2) waiver population discussion at 33353-33354 (June 3, 2026); CMS, "Community Engagement Requirement for Certain Individuals - Interim Final Rule with Comment Period (CMS-2454-IFC) Overview Slide Deck," posted July 27, 2026, slide 9; Utah DHHS, "Community engagement requirement"; Utah Medicaid Reform 1115 Demonstration, project numbers 11-W-00145/8 and 21-W-00054/8, approval period July 1, 2022 through June 30, 2027, Special Terms and Conditions approved November 13, 2025 and expenditure authorities approved January 13, 2025; Utah Admin. Code R414-311, Targeted Adult Medicaid, last changed June 19, 2025
Questions people ask about this
Do the new Medicaid work rules apply to me in Utah?
How many hours a month do I have to work?
Who is exempt from the work requirement in Utah?
When do the Utah work rules start?
What is the income limit for Utah Medicaid?
How do I apply for Adult Expansion Medicaid?
How often do I have to renew Utah 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.
Utah's own Medicaid work requirement has not been in force since 2020, so nothing you do at Workforce Services today is required of you and nothing you did back then carries forward.
What is coming is a different, federal rule, and the date that matters is not January 1 but your own eligibility review: Utah says members who are already enrolled are first checked at reviews due in March 2027 or later, while anyone applying from January 1, 2027 is checked for the month before they apply. Adult Expansion and Targeted Adult Medicaid reviews also move from once a year to every six months on that date, so make sure myCase at jobs.utah.gov has your current address, phone and email — or call 1-866-435-7414 — because all of this arrives by mail.
Updating your address takes two minutes and protects everything else. Do that first, then check the exemption list above.
Go to myCase at jobs.utah.gov →