Workfare could offer path to meeting Medicaid work rules

The SNAP program could let some recipients satisfy new requirements with fewer hours.

An existing food assistance program alternative could allow some NJ FamilyCare members to meet new Medicaid work requirements by volunteering for far fewer than 80 hours a month. But it remains unclear whether the federal government will allow recipients to use the program that way.

Starting in 2027, certain adults enrolled in Medicaid will be required to meet an 80-hour monthly work requirement — a change that could cause more than 300,000 NJ FamilyCare members to lose coverage, according to an estimate from the New Jersey Department of Human Services (NJDHS).

The requirement generally applies to adults ages 19 to 64 who do not qualify for an exemption. The guidance from the state provides more information about separate work requirements for people who receive support from the Supplemental Nutrition Assistance Program, commonly known as SNAP.

Recipients of SNAP have long faced an 80-hour monthly work requirement under certain circumstances. Until recently, in most New Jersey counties, the federal requirements could be waived.

A program called Workfare allows some SNAP recipients to satisfy their work requirements by volunteering for fewer hours. The hours are calculated by dividing a recipient’s monthly SNAP benefits by the applicable minimum wage.

New Jersey’s minimum wage is $15.92 an hour. SNAP benefits vary, but David Rubel, a public policy consultant who has advocated for greater use of Workfare, estimates that many New Jersey recipients would have to volunteer about 12 hours a month.

People who can show they have satisfied SNAP work requirements can be excluded from the new Medicaid work requirement, potentially making Workfare an alternative for people enrolled in both programs.

Tom Hester, a spokesperson for NJDHS, said using Workfare to satisfy the SNAP requirement should also allow qualifying recipients to meet the Medicaid exclusion.

“The Medicaid exclusion does not require the Department to separately verify that the individual is complying with, or has satisfied, the applicable SNAP work requirement,” Hester said. “Using Workfare as the pathway for satisfying a SNAP work requirement should not, by itself, create a separate Medicaid work-requirement issue.”

Rubel has been pushing state and municipal governments to promote Workfare as a way for Medicaid recipients who also receive SNAP benefits to maintain their coverage with fewer required hours.

“New York City, I think, has gone the farthest, because they are actively recruiting, every day, new organizations to be part of their network of volunteering,” Rubel said. “They don’t have to reinvent the wheel. They don’t have to start from scratch. All they have to do is copy. It’s already set up for them.”

The New Jersey Department of Human Services has not taken the same steps to promote Workfare as an alternative for people subject to the Medicaid requirement. Hester pointed to a new law intended to make it easier for Medicaid recipients to access volunteer opportunities that count toward the requirement. Those opportunities could also help some SNAP recipients satisfy their Workfare obligations.

“We continue to provide notices to affected individuals/households that explain the work requirement and how to fulfill it. We also work with the NJ Department of Labor to ensure work activities are available in every county,” Hester said. “We also look forward to increasing volunteer offerings with the NJ Department of State’s Office of Volunteerism.”

The federal Centers for Medicare & Medicaid Services (CMS) has not issued guidance addressing how the agency will treat Medicaid exclusions obtained through compliance with SNAP requirements using Workfare. The New Jersey Department of Human Services has complained to CMS that federal guidance on the coming Medicaid changes is too vague.

A spokesperson for CMS did not respond to a request for comment on whether it intends to issue guidance addressing Workfare and the Medicaid requirement.

The end of some SNAP waivers, expansion of SNAP work requirements and introduction of Medicaid work requirements are part of H.R. 1, the federal tax and spending law signed by President Donald Trump in July 2025. The law is projected to increase federal deficits by about $4.1 trillion from 2025 through 2034, including additional debt-service costs, according to the Congressional Budget Office. The office has also estimated that the law will reduce resources available to households near the bottom of the income distribution while increasing resources for households in the middle and toward the top.

From July 2025, when the SNAP changes began taking effect, through May 2026, 43,608 New Jersey residents lost their SNAP benefits, a little more than 5% of all recipients.

The new Medicaid work requirements, along with other limits to Medicaid, will take effect Jan. 1, 2027.