If you receive a Medicaid work requirement notice in the mail this summer, it may not tell you that you're exempt.

Georgetown University's Center for Children and Families published an analysis on May 7, 2026, finding that states already sending work requirement notices, including Nebraska and Montana, are leaving out critical information about parental exemptions. Low-income parents enrolled in traditional Medicaid as parents or caregivers of minor children are categorically excluded from work requirements under Section 1931. But their states' notices don't mention it.

The result is predictable. Families receive a notice telling them to comply with work requirements, panic, and either lose coverage trying to meet a standard that doesn't apply to them or disenroll thinking they'll be cut anyway.

The June 30 through August 31 window is when most states will mail notices to all affected enrollees. Here's how to read your notice, identify whether you're categorically exempt, and document your status before the outreach period closes.

What Section 1931 Parental Coverage Is and Who Qualifies

Section 1931 refers to a provision in the Social Security Act that requires states to cover parents and caretakers of minor children at income levels equal to or above what was required for welfare eligibility in 1996. These are parents enrolled in Medicaid not because their state expanded the program under the Affordable Care Act, but because they have low income and are caring for dependent children.

If you're on Medicaid because you're the parent or caretaker relative of a minor child, and your income is below your state's Section 1931 threshold, you are not subject to Medicaid work requirements. Period. This exemption is broader and more protective than the medically frail or disability exemption. You don't need to prove a disability. You don't need to be blind or have a disabling condition. You're excluded because you're a parent caring for your child.

The problem is that states aren't explaining this in the notices they're sending.

Georgetown's analysis found that neither Nebraska's nor Montana's notices clarified this exemption. Parents who qualified for traditional Medicaid as caregivers received the same notice as adults on expansion Medicaid who are subject to work rules. The notice tells them to report hours worked or apply for an exemption, but it doesn't say that Section 1931 parents are categorically excluded and don't need to do either.

How to Tell If You're on Expansion Medicaid or Traditional Medicaid as a Parent

This matters because the two pathways are treated completely differently under the new work requirements.

Expansion Medicaid covers adults ages 19 to 64 with income up to 138% of the federal poverty level, regardless of whether they have children. If you're on expansion Medicaid, you're subject to work requirements unless you qualify for an exemption like disability, pregnancy, or caregiving for a disabled household member.

Section 1931 traditional Medicaid covers parents and caretakers of minor children at lower income thresholds that vary by state. If you're on this pathway, you're not subject to work requirements at all.

Your Medicaid notice or eligibility letter may not spell this out. Here's how to find out which pathway you're on.

Call your state Medicaid office and ask these specific questions:

• "Am I enrolled in Medicaid under Section 1931 as a parent or caretaker relative?"
• "Is my coverage based on being the parent of a minor child, or is it based on adult expansion eligibility?"
• "Does my eligibility category exempt me from work requirements, or do I need to apply for an exemption?"

Write down the answers. Get the name of the person you spoke to and the date. If the caseworker says you're on Section 1931 parental coverage, you're done. You're categorically exempt from work requirements.

If the caseworker says you're on expansion Medicaid and you have a disability or are caring for a disabled child, you'll need to document that you qualify for the medically frail or caregiver exemption. That's a separate process covered by the guidance on documenting your disability exemption status before the June 30 outreach window.

What to Document Before the June 30 Outreach Window

Between June 30 and August 31, 2026, states are required by federal law to notify all Medicaid enrollees affected by work requirements. CMS's interim final rule, due by June 1, 2026, is expected to outline what those notices must include. But Georgetown's analysis makes it clear that states are interpreting those requirements differently, and some are sending notices that omit key exemptions.

Here's what you need to document right now, before your state's outreach period begins:

1. Call your Medicaid office and confirm your eligibility pathway. Ask the questions listed above. Write down the answers, the caseworker's name, and the date.

The work requirements rollout is happening in 41 states by January 2027. Nebraska's enforcement started May 1, 2026. Montana's enforcement begins July 1. Arkansas starts July 1 with a soft launch. Iowa's deadline is December 1. Most other states must comply by January 2027.

The outreach window is not optional. Your state will send you a notice. If that notice omits your exemption, you need documentation showing that you asked, that you were told you're exempt, and that the notice you received contradicts what your caseworker said.

What to Do If Your State's Notice Doesn't Explain Your Exemption

If you receive a work requirement notice and you know you're on Section 1931 parental coverage, here's what to do.

First, call your Medicaid office again. Reference the notice you received. Tell them you're a parent enrolled under Section 1931 and that you were told you're categorically exempt. Ask them to clarify in writing whether the notice applies to you.

Second, if your caseworker confirms you're exempt but the notice doesn't say so, ask how you're supposed to respond to the notice. Some states may tell you to ignore it. Others may require you to submit documentation proving your parental status even though you're categorically exempt. Get their answer in writing if possible. If not, document the call.

Third, if your state cuts your coverage based on failure to comply with work requirements and you're on Section 1931, appeal immediately (the deadline is typically 10 days from the date of the termination notice). Your Section 1931 status is your evidence. Attach the documentation you collected: call logs, eligibility confirmation, and household composition records.

Fourth, contact a legal aid organization in your state. Many states have legal aid programs that specialize in Medicaid appeals. They can help you navigate the appeal process and ensure your exemption is recognized.

State Readiness Varies Widely

Georgetown's analysis found that 29 states have a webpage or section on their Medicaid website describing the changes under HR 1, including work reporting requirements. Four states posted presentation slides or toolkits without full webpages. Ten states have no public-facing materials at all about Medicaid work requirements.

If your state is one of the ten with no materials, you're navigating this blind. The notice you receive in the mail may be the first time you hear about work requirements. If that notice doesn't explain the Section 1931 parental exemption, you won't know you're exempt unless you ask.

The Georgetown authors warned: "Without clear, accessible outreach materials, many individuals won't know how to comply or if they are exempt, and will be incorrectly kicked off Medicaid coverage."

It's already happening. Nebraska's enforcement began May 1, 2026, and families are receiving notices that don't distinguish between expansion enrollees subject to work rules and Section 1931 parents who are categorically excluded.

Who Is Subject to Work Requirements and Who Isn't

To be clear, not everyone on Medicaid is subject to work requirements.

Categorically excluded:

• Parents and caretakers enrolled under Section 1931 traditional Medicaid
• Children and adolescents under 19
• Pregnant individuals
• Adults over 64
• People receiving SSI (Supplemental Security Income)

Subject to work requirements but may qualify for exemptions:

• Adults ages 19 to 64 on expansion Medicaid
• Medically frail individuals (blind, disabled, substance use disorder, disabling mental disorder, serious or complex medical condition)
• Caregivers of disabled household members
• Full-time students
• People experiencing homelessness

The medically frail exemption is not the same as the Section 1931 parental exemption. The medically frail exemption applies to people on expansion Medicaid who have disabilities but don't receive SSI. According to KFF's work requirements tracker, 35% of Medicaid expansion enrollees have disabilities and do not receive SSI. They're subject to work rules unless they apply for and receive the medically frail exemption.

Section 1931 parents don't need to prove they're medically frail. They don't need to apply for an exemption. They're categorically excluded because they're parents caring for their children and enrolled through a different eligibility pathway.

The distinction matters. If you're a parent on Section 1931 and your state's notice tells you to apply for a medically frail exemption, the notice is wrong. You don't need an exemption. You're not subject to the requirement.

What Happens Next

CMS's interim final rule is due by June 1, 2026. States will then have until June 30 to finalize their outreach plans and begin mailing notices. The outreach window runs through August 31.

If you're a parent or caretaker on Medicaid, you need to know which pathway you're on before that notice arrives. Call your Medicaid office, ask the questions listed above, and document the answers. Don't wait for a notice that may not tell you what you need to know.

The law is clear. Section 1931 parents are categorically exempt from Medicaid work requirements. But if your state's notice doesn't say so, and you don't know to ask, you could lose coverage you're entitled to keep.