How to handle the new Medicaid work rules if you don’t have a ‘real’ job

The Trump administration has achieved another victory in the battle to make life harder for people who are already having a hard time: proof-of-work requirements will be required for Medicaid and SNAP recipients starting Jan. 1. 

If you’re among the 3.5 million New Yorkers who rely on Medicaid to see a doctor and generally not die, and you have a non-traditional, cash or gig job, you might be wondering how the hell you’re supposed to prove you work enough to qualify. Well, city officials have a message for you: they don’t really know either. 

Up to 900,000 city dwellers are at risk of losing their coverage once the new rules go into effect, according data shared by Mayor Zohran Mamdani’s administration at a media roundtable in October. The city also has one of the highest participation rates for SNAP (Supplemental Nutrition Assistance Program, formerly known as food stamps) in the country, according to the administration. But for something that could throw so many people off their health plans and food assistance, the exact details still seem murky.

“Everything is so up in the air,” Jonathan K. Gray, director of member benefits for the Brooklyn-based Freelancers Union, told The Groove. Gray said he’s been encouraging members to keep track of hours and keep reading news of the work requirement. “If you talk to some people who are trained in Medicaid they couldn’t even tell you what I told you. No one knows what the hell is going on.” 

Trump’s federal H.R. 1 spending bill (which has an everyone-is-12-now name I won’t repeat here) that Congress passed in July 2025 reshaped a lot of levers of government funding, adding more to the Homeland Security budget and taking away from food assistance and Medicaid. On top of that, the law fulfills the longtime Republican fantasy of trying to prove that anyone on Medicaid or SNAP benefits is actually some sort of lazy grifter (instead of, as many of us are, victims of a system where your access to health insurance is tied to an increasingly hard-to-find job).

Recipients of those benefits will soon have to prove they work at least 80 hours a month, make at least $580 in income, attend school or volunteer. And starting Jan. 1, those recipients will have to renew their eligibility once every six months, instead of annually. 

For anyone with regular wage work, the state can check your pay stubs and taxes to verify that you still qualify. But for anyone else — whether you take gig work, deliver for Uber Eats, do in-kind work for housing, volunteer or just have one big paycheck every six months — the process is frustratingly vague. If you only get paid in cash, the challenge can be even greater. 

The city is stepping in to try to help navigate those questions. Mamdani’s administration set up a hotline and website to help New Yorkers keep their coverage. The Health and Affordability Resource Team has been contacting New Yorkers for the past month to inform them of the changes and help people prepare the necessary documents and contact info; it also set up a website that lays out some of the ways to prepare. 

“We're working closely with the state to help to try and clarify what the best way for — I'll call them gig workers — will be for them to have their work count,” Dr. Alister Martin, the city’s health commissioner, said at a media roundtable in City Hall on Oct. 23. 

One thing the city points to is the state’s new Truv program, an income-verification tool the state launched in July. It allows gig workers — with companies such as Amazon, Home Depot or UPS, for example — to connect their payroll accounts directly to New York State of Health, the state’s healthcare marketplace. The app then verifies the income. The state said it will start sending links to Truv to eligible workers starting in February. 

“It's that kind of innovation, ingenuity that we're going to try and keep up in our conversations with the state,” Martin said. 

A spokesperson for the state Health Department said the state is also trying to secure a county-wide hardship exemption in the Bronx due to the high rate of unemployment. The state is forced to comply with the Medicaid and SNAP rule changes, but it is still frustrated with the Trump administration. 

“This is a top-down mandate from the federal government that puts vulnerable communities in the crosshairs and threatens to push eligible Medicaid recipients off the rolls,” the spokesperson said. 

The city also launched a site, nyc.gov/workrules, that has a questionnaire to help users figure out if they still qualify for Medicaid and SNAP. The city’s main message is: don’t self-select out, and don’t be discouraged from at least trying, because that is what the Trump administration is hoping for. 

The mayor himself told reporters that while conservative legislators promote work requirements as a way to encourage people to get jobs, the actual intent is to simply to punish them. 

“What we have found time and again is the underlying interest is to remove people from the things that can keep them healthy and that can keep them safe,” Mamdani said at the roundtable. “That is the issue that we have with these programs. It's not that they could help people get to work. It's that what they're really looking to do is to find ways for disqualifying people from receiving these kinds of benefits.”

For freelancers, cash workers — or anyone who falls into the incredibly nebulous categories of “in-kind” or volunteer work — it’s still unclear how the verification system will pan out.

“I tell them to track your hours as best you can,” Gray said. “Really, freelancing, it leaves a lot of room for fraud. I could say I volunteer those 80 hours. I could say I did anything. Who is going to confirm if I did? It’s just a lot of open ends.” 

Like many the-cruelty-is-the-point pieces of action from the Trump administration, Gray said little attention was paid to the details. 

“I don't think there was really a plan for this to be honest with you. They just want to take stuff away from the little guys and give to themselves,” he said. 

The risk of fraud is high, as Gray mentioned, but is it really fraud if you’re getting one over on the guy whose entire vibe is fraud is good and fun? The website my80hours.com lists the various ways to capture your 80 required hours, including how to document volunteer work, for instance, with a form letter that you can fill out yourself with the number of hours, and self-certify the results, producing an official-looking PDF log. 

City officials encouraged anyone unsure of their status to still reach out. 

“We encourage individuals, anyone who does have income, to speak to us about it,” Scott French, head of the city’s Human Resources Administration said at the roundtable. “But that's really something on a case-by-case basis we really want to talk to individuals about, to understand what is the situation and then what might be the pathway to ensure that they can show compliance and remain on the benefits.”

Gray recommended anyone with questions to stay tied into the whisper network as the new rules roll out. 

“Just keep your ear to the ground,” he said. “Information sharing is just the biggest thing on this.”