Workforce Wonkery / Practice / California
When H.R. 1 Work Requirements Meet Real Life
What California’s new rules could mean for people with changing work hours, complicated records, and small food benefits.
This is a companion to the H.R. 1 California WDB Implementation Desk. It explains who may experience new paperwork, what published estimates actually measure, and how workforce boards can make referrals and verification more useful. It is not a benefits eligibility calculator.
A worker is not a statistic
In 2020, the California Health Care Foundation interviewed 19 people working while enrolled in Medi-Cal. One said:
“People need to realize just because we are on Medi-Cal doesn’t mean we are not working.”
Interview participant in CHCF’s 2020 report. The interview predates H.R. 1 and is not a report of a 2026 work-requirement experience.
The report described workers who could not obtain affordable health insurance through their jobs, including those holding several part-time jobs. It is a useful reminder that paid employment and public benefits often overlap. It does not prove these interviewees are now subject to any particular H.R. 1 provision.
The worker whose hours change every month
A restaurant worker, farmworker, or staffing-agency employee may have substantial earnings in one month and far fewer hours in the next. PPIC found that 64% of potentially affected CalFresh adults in its historical study had employment near enrollment, but more than half of working adults cycled between employment and unemployment during benefit participation. Having worked is not proof of meeting an 80-hour rule during each required period. A useful workforce response might be payroll verification, help obtaining an employer statement, and a service with a genuine opening when the hours fall short. Source: PPIC, August 2026.
The older adult who has been out of the workforce
Adults ages 55–64 accounted for roughly 31.3% of California’s projected ABAWD population, although they represented 9.6% of the overall CalFresh caseload in a July 2025 state data snapshot. For someone recently laid off or living with a health limitation, a generic job-search referral may not resolve the issue. The first step is county review of possible exemptions and appropriate activities, followed by meaningful employment assistance when it is wanted and available. Source: CDSS/CalSAWS data presented April 29, 2026.
The person without a stable address
The same earlier state snapshot included about 253,800 adults recorded as experiencing homelessness among people projected potentially subject to the CalFresh ABAWD rules. Homelessness alone no longer provides the former categorical federal ABAWD exemption. This makes correct exemption screening, reliable ways to receive notices, and a named county contact especially important. This figure reflects historical administrative classification, not a count of people currently failing work requirements. Source: state hearing materials, April 2026.
The household receiving a small monthly benefit
Illustrative situation, not an interviewed participant: Consider a household that receives $75 a month in CalFresh and is asked for additional records. That family may find the time, transportation, telephone access, or paperwork difficult to manage. We do not know how many affected households receive under $100, or how many would choose not to recertify because of it. A workforce professional should not assume a small allotment is unimportant to the household, or that an incomplete case is a voluntary decision to leave.
A January 2026 NBER study found that ABAWD work rules increased procedural and overall SNAP denials in the states studied. This is evidence of administrative burden, but it is not an estimate of Californians who will decide that keeping a particular allotment is not worth the work. Source: Cook, Cox, and East, 2026.
The California numbers, explained
- About 562,000 CalFresh recipients were estimated to be at risk of discontinuation in FY 2026–27 under expanded ABAWD rules, using June 2026 assumptions. This is the newer LAO budget figure, not an observed loss. LAO, October 2026.
- About 179,500 were expected to meet the CalFresh work or community-engagement rule among approximately 954,800 adults with no already documented exemption in an earlier state model. This is a model assumption based on quality-control data, not a measured count of people with current paperwork complete. California Senate budget materials, March 2026.
- About 64% had jobs near enrollment in PPIC’s earlier study of potentially affected working-age CalFresh adults. This does not equal 64% meeting required hours or avoiding reporting barriers. PPIC, August 2026.
- About 3.5 million Medi-Cal expansion enrollees were estimated by the LAO in March 2026 to become subject to the new requirement after anticipated exemptions. This is a different program with a different rule. LAO county administration analysis.
These are separate populations, assumptions, and time frames. People receiving both programs may be counted in both sets, and new information or federal implementation decisions can change projections. Never add the numbers together to estimate unique residents.
What can we say for each county?
For CalFresh ABAWD exposure, already-compliant workers, and recipients with allotments below $100, no verified 58-county projection was located in the public sources reviewed. CDSS’s quarterly STAT 47 report tracks ABAWD and work registrant information, but its historical caseload tables do not by themselves identify newly affected H.R. 1 adults, qualifying work hours, or the distribution of low allotments. The DFA256 report gives county participation and total benefit issuance, not the required linked benefit-by-work-status distribution. CDSS STAT 47 and CDSS DFA256.
For Medi-Cal, a county-level projection is available, but it answers another question. The UC Berkeley Labor Center and UCLA Center for Health Policy Research modeled a high-end scenario of approximately 2.98 million fewer residents with full-scope Medi-Cal by 2028 under five combined federal and state policy changes. About 1.87 million of the statewide estimate was attributed to work requirements, but the county table below includes work requirements, eligibility renewals, immigration eligibility changes, a state enrollment freeze, and premiums. It does not show the county number subject to work requirements, failing to report, losing all insurance, or needing employment services. The projection uses February 2026 assumptions and is subject to change. Read the full UC Berkeley/UCLA methods and chart.
Show county-by-county Medi-Cal projections (all 58 counties)
Read before using: These are modeled high-end losses in full-scope Medi-Cal from five combined policy changes by 2028. They are not work-rule compliance counts, actual enrollment changes, or CalFresh forecasts. Estimates rounded to thousands; the statewide model total is rounded.
| California county | Projected fewer full-scope Medi-Cal enrollees by 2028 |
|---|---|
| Alameda | 127,000 |
| Alpine | Under 1,000 |
| Amador | 1,000 |
| Butte | 14,000 |
| Calaveras | 2,000 |
| Colusa | Under 1,000 |
| Contra Costa | 73,000 |
| Del Norte | Under 1,000 |
| El Dorado | 7,000 |
| Fresno | 27,000 |
| Glenn | 1,000 |
| Humboldt | 10,000 |
| Imperial | 2,000 |
| Inyo | 1,000 |
| Kern | 29,000 |
| Kings | 3,000 |
| Lake | 2,000 |
| Lassen | 1,000 |
| Los Angeles | 1,113,000 |
| Madera | 6,000 |
| Marin | 18,000 |
| Mariposa | 1,000 |
| Mendocino | 9,000 |
| Merced | 9,000 |
| Modoc | Under 1,000 |
| Mono | 1,000 |
| Monterey | 21,000 |
| Napa | 8,000 |
| Nevada | 5,000 |
| Orange | 249,000 |
| Placer | 14,000 |
| Plumas | Under 1,000 |
| Riverside | 189,000 |
| Sacramento | 111,000 |
| San Benito | 1,000 |
| San Bernardino | 177,000 |
| San Diego | 210,000 |
| San Francisco | 65,000 |
| San Joaquin | 18,000 |
| San Luis Obispo | 14,000 |
| San Mateo | 59,000 |
| Santa Barbara | 46,000 |
| Santa Clara | 129,000 |
| Santa Cruz | 19,000 |
| Shasta | 9,000 |
| Sierra | Under 1,000 |
| Siskiyou | 1,000 |
| Solano | 30,000 |
| Sonoma | 33,000 |
| Stanislaus | 15,000 |
| Sutter | 2,000 |
| Tehama | 2,000 |
| Trinity | 1,000 |
| Tulare | 19,000 |
| Tuolumne | 2,000 |
| Ventura | 61,000 |
| Yolo | 12,000 |
| Yuba | 2,000 |
| Statewide | 2,980,000 (model total) |
For local planning, do not use the table as a referral target. A board serving several counties should instead compare actual county-provided work-rule caseload estimates, county waiver status, existing work and school participation, and available service capacity.
The CalFresh ABAWD geographic waiver for November 1, 2026 through October 31, 2027 covers Colusa, Imperial, Kings, Merced, Monterey, Plumas, and Tulare counties. That waiver applies to the CalFresh ABAWD time limit, not to the broader Medi-Cal projection above. CDSS current ABAWD guidance.
The under-$100 question is important, but still unanswered
A countywide average CalFresh benefit cannot reveal how many affected households receive less than $100 per month. Even a count of all small-benefit households would not answer how many include an adult subject to the ABAWD time limit. Benefits are issued to households, while the work rule typically applies to individuals; that difference matters.
To answer the question responsibly, California needs a privacy-safe aggregate tabulation, by county and reporting month, that cross-tabulates the ABAWD-screened adult population with the household’s monthly allotment band, known exemption status, and known qualifying activity. Proposed allotment bands: $1–$49, $50–$99, $100–$199, and $200 or more. It should separately count records missing work verification, actual noncompliance decisions, and other discontinuation reasons. Rates must include appropriate denominators and suppression of small cells.
A separate survey or voluntary interview study would be needed to learn why people stop reporting or leave benefits. Administrative data alone cannot establish that someone judged the amount to be too small to justify the effort.
What this means for workforce boards
- Ask the county for the right denominators: number screened, already exempt, potentially subject, known to meet activity, missing proof, needing activity, and with an urgent benefits notice. Separate CalFresh from Medi-Cal and identify the data month.
- Make work already done easier to document: coordinate with employers, colleges, and training providers to supply records the county can actually use, without creating a new benefits database.
- Plan for variable hours: include short-term jobs, seasonal work, older workers, and people who face irregular schedules in service design.
- Ask whether support reaches the person: track accepted referrals, actual service starts, access barriers, and corrected records using approved systems and aggregate reporting.
- Listen to residents directly: with consent, obtain short first-person accounts of applying, documenting work, and navigating notices. Use the person’s own words, verify context, and never present an invented composite as a real case.
Editorial standard: This page separates real interviews, illustrative scenarios, historical observations, and forecasts. It does not imply a resident must work when an exemption or exclusion may apply. The responsible county benefits agency makes eligibility decisions. Research checked November 3, 2026.