West Virginia adults 19 through 64 in Medicaid’s Adult Expansion Group must show 80 hours a month of work, school, a work program or volunteering, or earn at least $580 a month, to keep their coverage starting Jan. 1, 2027, the state Department of Human Services says. Seasonal workers can meet the income test with a six-month average of $580 a month. The department’s early count puts about 33,000 members short of the standard.
The requirement comes from the federal budget law Trump signed in 2025, the One Big Beautiful Bill Act, and West Virginia is on track to start on schedule. Christy Donohue, commissioner of the state Bureau for Medical Services, told lawmakers in August that enrollment effects are expected to begin in March 2027.
Who has to meet the 80-hour test
The rule covers low-income adults 19 to 64 in the expansion group who get coverage through the Mountain Health Trust managed care program and are U.S. citizens or meet the immigration rules. In its Aug. 27 announcement, the department said qualifying activities include a job, a work program, school and volunteering, and that hours can be combined.
The state’s Medicaid help site sets the income ceiling at about $22,025 a year for one person and $45,540 for a family of four. Paid, unpaid and in-kind work all count, as does an approved work training program, school at least half-time and volunteer community service. School hours below half-time still count toward the 80.
Unpaid and in-kind hours matter for people paid in trade, such as a worker whose pay is reduced rent. Donohue told the legislative oversight committee that those hours can now count, where before only work for not-for-profit agencies qualified, because the federal interim final rule opened the door to other agencies that count qualifying community service.
The income test is the simpler route for anyone with steady pay. Earning $580 a month satisfies the requirement without counting a single hour. A seasonal worker whose pay swings can average the last six months instead, which works out to about $6,960 over a year.
For anyone on the expansion program with irregular hours, a caregiving role or a mix of part-time jobs, the question is whether state records already show enough hours, enough income or an exclusion. The department says it checks its own records first and writes only when it needs more, by U.S. Mail or through the member’s PATH account. Members who get such a request have 30 days to answer or may lose Medicaid, and members who are not contacted do not need to send anything.
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Exclusions that remove the hours requirement
Several groups do not have to meet the test for all or part of at least one month in a renewal period. They include people who are pregnant or were within the last 12 months, parents, guardians and caregivers of a child under 14 or of a disabled person of any age, and people 19 to 25 who aged out of foster care.
The list also covers American Indian and Alaska Native members, veterans with a 100% VA disability rating, and members of a SNAP household subject to SNAP work rules. People in certain drug or alcohol treatment programs, TANF and WVWORKS recipients who already meet work rules, and people incarcerated at renewal time are excluded too.
A separate group of exceptions can satisfy the rule for the months they apply. Adults under 19 qualify, as do people incarcerated in the three months before an application or renewal, people eligible for Medicare Part A or enrolled in Part B, and people covered under a mandatory traditional Medicaid group such as low-income children.
Medically frail members are excluded as well. The state’s list names blindness or disability, serious or complex conditions that need regular care, disabling mental health conditions, and substance use disorder with less than five years of recovery. Donohue said people in recovery for five or more years are not exempt under the federal rule, and that the state would need to review data on stable patients on suboxone treatment because there is no clear definition of stable.
To spot frailty before asking members for paperwork, the state plans to use claims, prescription and managed care plan data, Donohue told lawmakers. The department is also studying a Louisiana model that works from diagnosis codes and prescriptions.
Counts, and a court ruling on medical frailty
About 156,000 West Virginians were in the expansion population when the department made its presentation. Roughly 119,000 are automatically excluded and about 4,460 already meet the requirement, which leaves the roughly 33,000 who do not currently meet it and are not automatically exempt. The department’s analysis predates the final federal rule on medical frailty, so the count could change.
On Oct. 29, a federal court in Massachusetts vacated the interim rule’s definition of medical frailty as contrary to law, according to Massachusetts Attorney General Campbell’s office. The court also issued a permanent injunction and gave the plaintiff states a six-month stay of enforcement.
The suit was led by Massachusetts, California and New Jersey, and West Virginia is not among the states the release lists as plaintiffs. The release does not say what standard replaces the vacated language, and the state’s own help page says its information is current as of October 2026 and subject to further guidance from the federal Centers for Medicare & Medicaid Services.
Applications, renewals and what to keep
Applicants may need to meet the test for the month before applying, such as December 2026 for January 2027 coverage. At renewal, members must meet the 80-hour rule or an exclusion for all or part of at least one month since their last renewal, and starting in January 2027 some members renew every six months instead of every 12.
When the department does ask for proof, it may request pay stubs, records of unpaid or in-kind hours, school attendance records, volunteer logs with the organization’s contact information and work training hours. Keeping those in one folder shortens the 30-day response window.
Members can call the DoHS Customer Service Reporting Center at 1-877-716-1212 or report changes in jobs, income or household at wvpath.wv.gov. The participating managed care plans are Aetna Better Health, Highmark Health Options, The Health Plan of West Virginia and Wellpoint West Virginia, and each member’s plan card shows which one applies.
Is a West Virginia Medicaid case ready for the 80-hour test?
A request for proof that goes unanswered for 30 days can end coverage, and the department’s own count shows about 33,000 expansion members not yet meeting the standard. For anyone who works odd hours, cares for a relative or volunteers, the hard part is knowing which exclusion fits before the letter arrives.
The SNAP & Medicaid Renewal Organizer explains the new Medicaid work requirement and who is exempt, so a household can match its own situation to the rule before the first renewal. It also holds 51 state packs, West Virginia’s among them, and a renewal document checklist for gathering pay stubs, school letters and volunteer logs.
Get the work-rule exemption guide and renewal document checklist for West Virginia →
This article was produced with AI assistance and edited for accuracy against the sources linked above.
