Assessing Ability to Work: How Historical SNAP Processes May Vary from Medicaid Authors: Amaya Diana and Jennifer Tolbert Published: Oct 22, 2026

https://www.kff.org/medicaid/assessing-ability-to-work-how-historical-snap-processes-may-vary-from-medicaid/ The Supplemental Nutrition Assistance Program (SNAP), which is the primary federal aid program addressing food insecurity among low-income households, has long included work requirements as a condition for participation for certain individuals. Starting January 1, 2027, or sooner at state option, 44 states will also be required to condition Medicaid eligibility for adults in the Affordable Care Act (ACA) Medicaid expansion group and enrollees in certain waiver programs on meeting work requirements. The law specifies mandatory exclusions from these requirements, including for individuals who are “medically frail,” if they have both a qualifying condition and demonstrate that the condition impairs their ability to fulfill the work requirements. CMS recently released information on an approach states can use to verify medical frailty exclusions; however, states are not required to adopt this approach, and it remains unclear what processes states will use.