Georgia Medicaid applicants who expect to apply under the Pathways program in 2027 are being told to start keeping proof of their activities in December 2026. The 80-hour-a-month test that federal law adds to Medicaid starts Jan. 1, 2027, and Georgia’s Pathways site says new applicants must meet it starting with the month before they apply. New Hampshire’s Granite Advantage program faces the same federal start date, with its own timing for people already enrolled.
Georgia Pathways: what to keep from December
The state’s Pathways page says the federal law known as H.R. 1 changes Georgia Pathways eligibility on Jan. 1, 2027. New potential applicants “should keep proof of community engagement activities beginning December 2026,” as the page puts it. Current Pathways members, it says, “will not be affected until renewal in 2027.”
Applicants can also request coverage for the two months before the month they apply. The page gives an example: someone applying in February 2027 could request December 2026 and January 2027. That person would still need to show 80 hours of activity in January 2027.
So a December record is the first month that can count, and it matters most to a person who applies early in the year and asks for the earlier months. A person who waits until summer to apply is judged on the month before that application, not on December. Anyone who starts keeping records in December has the widest choice of months to request.
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What counts toward the 80 hours and the $580 alternative
Georgia counts 80 hours per month of community engagement. That can be work, full or part time, including self-employment, as well as community service, a work program or at least half-time enrollment in an educational program. Activities can be combined to reach the 80 hours.
A new option lets an applicant meet the requirement by earning at least $580 a month, provided income stays at or below 100% of the federal poverty level. Seasonal workers can instead average at least $580 a month over the previous six months. The CMS fact sheet on the federal rule explains the dollar figure: the federal minimum wage multiplied by 80 hours, which comes to $580 a month in 2026.
The Georgia page describes the people covered as ages 19 to 64 with income at or below 100% of the poverty level, among other criteria. Certain groups are exempt, including people with Medicare, pregnant women and American Indian or Alaska Native individuals. Current members have to keep documentation of their activities for their 2027 renewal.
The federal rule behind both states’ deadlines
CMS’s fact sheet on its interim final rule says states generally must implement the community engagement requirement no later than Jan. 1, 2027, or earlier if they choose. New applicants must meet it for at least one month before the month they apply. The same sheet lets states offer short-term hardship exceptions and run more frequent compliance checks between renewals.
States also decide how many months existing enrollees must meet the requirement between renewals, according to the fact sheet. That is why Georgia’s advice to start keeping records in December is a Georgia instruction, not an automatic national one. Each state sets its own calendar inside the federal frame.
New Hampshire’s Granite Advantage members face the test at renewal
New Hampshire Public Radio reported on July 20 that beginning Jan. 1, 2027, Granite Advantage members ages 19 to 64 must log 80 hours a month in paid work or community engagement. The state counted 47,571 members as of July 1. NHPR said the rules apply to each member at that person’s first Medicaid redetermination in 2027.
The state’s Department of Health and Human Services told the station it was waiting for final guidance from the federal government on further details. Exemptions for pregnant women, former foster youth, certain veterans and people who are medically exempt were still being developed, NHPR said. What counts as qualifying work, and how members report it, had not been finalized at the time.
NHPR’s July report covers current members and does not address how the rules apply to new applicants. For applicants anywhere, the CMS baseline is the one-month look-back before the application month. New Hampshire’s own steps are posted on the state’s Stay Covered NH site, which DHHS says it keeps updating.
A December record against a January start
The two states share a Jan. 1, 2027 start and an 80-hour or $580 test, but the clock runs differently. Georgia has told applicants in plain terms to begin keeping proof in December 2026. New Hampshire has told current members that the test reaches them at their first 2027 redetermination.
For a Georgia applicant, the open question is which months to ask the state to look at. The Pathways page lets an applicant reach back two months, and a person with steady hours in December and January can use both.
Which December records will a Georgia Medicaid application want?
A Georgia applicant who starts keeping records late loses months that could have counted toward the 80 hours. The 80-hour test starts Jan. 1, 2027, and December is the month the state says to begin.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, so an applicant can see which group applies before counting hours. It also includes a renewal document checklist for assembling the papers.
The organizer runs 20 pages and includes a renewal and reporting calendar with 51 state packs.
Get the Medicaid work-rule guide and renewal document checklist →
This article was produced with AI assistance and edited for accuracy against the sources linked above.
