H.R. 1 · §10102 and §71119
SNAP and Medicaid work requirements, side by side
Two separate provisions of the same law, with different clocks, different populations, and different exemption lists. They connect in exactly one place. Cells are drawn from the enrolled statutory text and, where the statute delegates, from the implementing regulations — each one cited. Where a provision is genuinely silent, this page says so rather than filling the gap by inference.
In force
Who it reaches
Able-bodied adults without dependents, ages 18 to 64.
H.R. 1 widened the band from 18–54 and removed the veteran, homeless, and former-foster-youth exemptions.
ACA-expansion adults only, ages 19 to 64 §1902(xx)(9)(A)(i).
Traditional Medicaid is untouched: children, pregnancy, aged, blind, disabled, and Medicare dual-eligibles fall outside the provision entirely.
The hour requirement
Unchanged. §10102 does not rewrite SNAP’s activity list or hour rules — those remain in pre-existing 7 U.S.C. 2015(o)(1)–(2). This section touches only exceptions, waiver triggers, and noncontiguous handling.
Newly written at §1902(xx)(2), with a broader menu than SNAP’s and the flexibility below.
What counts
- Paid work
- Work program
- Workfare
- Paid work, 80 hrs
- Community service at a public or nonprofit organization, 80 hrs
- Work program, 80 hrs
- Educational program at half-time — no hour count required
Can activities be combined to reach the threshold?
Yes — in the regulation rather than in §10102.
7 CFR 273.24(a)(1)(iii) allows any combination of work and work-program participation totalling 20 hours.
And (a)(2) defines working itself as three things that also combine, per (a)(2)(iv): work for money, work for goods or services (“in kind”), and unpaid work, verified under standards established by the State agency.
Volunteer hours already count here, and Hawaiʻi DHS sets what proof looks like.
Yes, expressly. §1902(xx)(2)(E) permits any combination of the four totalling 80 hours.
Can earnings substitute for hours?
Yes, but as an exemption rather than a way to count hours.
$217.50 / weekFederal minimum wage × 30 hours. A person employed or self-employed at 30+ hours a week, or earning that much regardless of hours, is exempt from SNAP work requirements 7 CFR 273.7(b)(1)(vii).
That exemption reaches the time limit too: 273.24(c)(5) excepts anyone otherwise exempt under 273.7(b).
Roughly $942/month — a higher bar than Medicaid’s $580, and it removes the requirement instead of satisfying it.
Yes. Monthly gross income of at least federal minimum wage × 80 hours.
$580 / monthPay stubs alone satisfy it. Seasonal workers may use a six-month average §1902(xx)(2)(F)–(G).
Who is exempt
- Under 18 or over 65
- Medically certified unfit for employment
- Parent or household member responsible for a dependent child under 14
- Otherwise exempt under subsection (d)(2)
- Pregnant
- Indian or Urban Indian; California Indian
§6(o)(3) — six categories.
- Indian, Urban Indian, California Indian, or otherwise IHS-eligible
- Parent, guardian, caretaker relative, or family caregiver of a child 13 and under or of a disabled person
- Veteran with a total disability rating
- Medically frail — blind or disabled, substance use disorder, disabling mental disorder, physical/intellectual/developmental disability, or a serious or complex medical condition
- Complying with TANF requirements, or in a SNAP household and not exempt from SNAP’s requirement
- In addiction treatment or rehabilitation
- Inmate of a public institution
- Pregnant or postpartum
§1902(xx)(9)(A)(ii) — substantially broader.
How compliance gets verified
Data the State already holds, first. Where an exception is questionable the agency must try its own records and other public-assistance data sharing before asking the person for documents 7 CFR 273.24(l) — the same instinct as Medicaid’s ex parte rule.
Hours are verified under 273.2(f)(1) and (f)(8) 273.24(a)(6). A drop below 20 hours is a reportable change 273.12(a)(1)(viii).
For unpaid work the regulation names no format: it is verified “under standards established by the State agency” 273.24(a)(2)(iii). Like Medicaid, the question of what a volunteer-hour record must look like is decided below the statute — here by the State, not HHS.
Ex parte first. The state must use data it already holds — payroll, claims, encounter data — before asking the person for anything §1902(xx)(5).
The statute names no acceptable document formats. That is delegated to HHS by rule, which is where nonprofit volunteer-hour records get decided.
What happens on noncompliance
Three months of benefits within a 36-month window, then the time limit applies.
The current window closes 2026-09-30; the next begins 2026-10-01.
Written notice, then a 30-day cure period. Coverage continues during the cure. Disenrollment no earlier than the end of the following month, with fair-hearing rights §1902(xx)(6).
Relief available to Hawaiʻi
Two geographic paths.
Automatic waiver trigger if state unemployment reaches 1.5× the national rate §6(o)(4)(A)(ii).
Plus a noncontiguous-state good-faith exemption on petition to USDA §6(o)(7). Hawaiʻi and Alaska qualify; Guam and the USVI are excluded. Sunsets 2028-12-31, non-renewable.
No geographic path. Hawaiʻi is on the same 2027-01-01 clock as every other state.
But the good-faith implementation exemption at §1902(xx)(11) is open to any state, Hawaiʻi included. It also sunsets 2028-12-31.
The requirement itself cannot be waived under §1115 — only the timing §1902(xx)(10).
The one place the two programs touch
SNAP compliance excuses you from Medicaid. Not the reverse.
A person is excluded from the Medicaid community-engagement requirement if they are:
“a member of a household that receives supplemental nutrition assistance program benefits under the Food and Nutrition Act of 2008 and is not exempt from a work requirement under such Act”— §1902(xx)(9)(A)(ii)(VI)(bb)
Congress avoided double jeopardy: a household on SNAP and subject to SNAP’s work requirement does not separately carry Medicaid’s. There is no mirror provision running the other way.
Operationally, dual-enrolled people are working one requirement rather than two. The households carrying a live requirement with no health-plan infrastructure behind them are the SNAP-only group, and they sit outside the QUEST-plan architecture entirely.