The Centers for Medicare & Medicaid Services has told Georgia that its Pathways to Coverage Medicaid program expires December 31, and that the state must apply the federal Medicaid work requirement to Pathways enrollees no later than January 1, 2027. A letter dated September 25 says the program’s authorities end on December 31 “unless renewed or otherwise amended.” Georgia has 30 days from the letter, which falls on October 25, to accept the changes in writing.
For Pathways enrollees and applicants, the question is whether the 80-hour monthly rule they already meet is about to change. The letter leaves that Pathways requirement as written and layers the federal rule on top. Georgia says current members are not affected until their 2027 renewal, while new applicants must show work activity beginning with December 2026.
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What the CMS letter requires of Georgia
The letter was signed by Dan Brillman, CMS deputy administrator and director of the Center for Medicaid and CHIP Services, and addressed to Stuart Portman of the Georgia Department of Community Health. Its purpose is to conform the Pathways terms to Public Law 119-21, the 2025 budget law, which CMS calls the Working Families Tax Cut legislation.
The key sentence is blunt: Georgia “is required to implement the community engagement requirement for the specified demonstration population” not later than January 1, 2027, following CMS’s June 3, 2026, interim final rule. Georgia must also say in its state plan amendment that it runs a demonstration whose applicable individuals are covered only under Section 1115(a)(2) authority.
The federal rule adds a verification schedule. Applicants must show community engagement for one to three consecutive months before the application month, as the state chooses. Enrolled individuals must show it between renewals, or more often if Georgia elects. The Pathways terms keep their own limits: ages 19 through 64, income up to 95 percent of the poverty level, effectively 100 percent with a 5 percent disregard, and at least 80 hours a month.
The letter also points to exceptions. People who meet the criteria for a mandatory exception count as meeting the requirement for a month, and Georgia may elect a short-term hardship exception. A third group, “specified excluded individuals,” is not subject to the requirement. CMS also asks Georgia to keep monitoring the program and to maintain provider screening and fraud-referral safeguards.
What Georgia tells Pathways members
Georgia’s page on the H.R. 1 changes says they take effect January 1, 2027, and that current Pathways members will not be affected until renewal in 2027. New applicants must show community engagement starting with December 2026. Members must complete the activity each month during enrollment and at annual renewal.
The page keeps the 80-hour menu of work, community service, a work program or half-time school, and allows hours to be combined. It adds one new test: earning at least $580 a month, or an average of at least $580 over the previous six months for seasonal workers, while staying under the poverty line.
Activities no longer counted include job-readiness activities, inpatient hospital or short-term skilled nursing stays, habilitation or rehabilitation such as substance use treatment, and being a parent or guardian of a child under six. Some of those reappear as exemptions or hardship cases. Exempt groups include American Indians and Alaska Natives, former foster youth, medically frail people, pregnant women and caregivers of children 13 and under.
The hardship list covers inpatient hospital or acute-care stays, living in a county with a presidentially declared disaster, living in a county with unemployment at or above the lesser of 8 percent or 1.5 times the national rate, and extended travel for medical care. The two county-level hardships need CMS approval first. Starting January 1, 2027, applicants can also request coverage for up to two months before the application month.
The page tells current members to keep proof of activities, such as pay stubs, school records and volunteer logs, and to keep their address and phone number current with the Division of Family and Children Services. The agency’s customer line is 877-423-4746. Georgia warns that noncompliance can end benefits, with a chance to provide information first and appeal rights.
Noncitizen funding and the December 31 cliff
The letter makes a second change, effective October 1 through December 31, 2026. Federal Medicaid funding is limited to U.S. citizens and nationals, lawful permanent residents, Cuban and Haitian entrants and Compact of Free Association migrants, with exceptions for emergency Medicaid. Georgia’s eligibility terms now require citizenship, national status or satisfactory immigration status.
The expiry date is not new. CMS’s temporary extension of September 30, 2025, ran Pathways through December 31, 2026, and Georgia says it asked on April 28, 2025, for an extension of at least five years. The state’s October 1 application for a 90 percent federal match says the conditions in Public Law 119-21 cannot be waived, and that Georgia is prohibited from continuing its current Pathways program.
If Pathways is phased out, the program’s terms require a transition plan with public comment covering notices to members, eligibility review and continued coverage for people who remain eligible. Georgia’s application puts current enrollment at about 20,000 people and projects nearly 120,000 by June 30, 2028 if CMS approves its request.
The open question for a Pathways member is what December 31 brings. The letter makes the federal work rule a condition from January 1, 2027, while the authority behind the program still ends on December 31 unless renewed or amended.
Are Pathways members exempt when the federal rules start?
A member who misses an exemption, or goes a month without documented hours, can lose coverage that took months to get. With the federal rule arriving January 1, 2027, the paperwork for hours, exemptions and renewal dates all lands within weeks of each other.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, including Part 6, The New Medicaid Work Rule, and the 90-Day Rescue. It also has a renewal and reporting calendar and 51 state packs, so Georgia’s dates can be set beside the federal one.
Get the Medicaid work-rule exemption guide and renewal calendar in one organizer →
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
