This episode is hosted by Patti Boozang, Manatt Health Senior Managing Director and 80 Million editor. She is joined by MassHealth Chief Operating Officer Elizabeth LaMontagne, Massachusetts’ Health Care For All Deputy Executive Director Ashley Blackburn and Manatt Health Partner Kinda Serafi to discuss what implementation looks like on the ground — and what states are doing to mitigate harm.
Authors: Ashley Blackburn, Elizabeth LaMontagne and Kinda Serafi
Editors: Patti Boozang and Amanda Eisenberg
tl;dr
* Medicaid work reporting requirements take effect Jan. 1, 2027, creating a complex new set of eligibility and verification rules for states to implement.
* About 5.7 million people nationally are projected to lose coverage by 2034 due to new work reporting requirements and six-month eligibility checks. MassHealth, the Commonwealth of Massachusetts’ Medicaid program, estimates up to 175,000 residents could lose coverage because of work requirements and six-month eligibility checks.
* Massachusetts is partnering with community organizations, like Health Care for All Massachusetts, using data to identify people who qualify for exemptions and preparing to address problems as they arise — work that will need to continue well beyond the initial launch.
The 80 Million Impact
Starting Jan. 1, 2027, states must implement new federal work and community engagement requirements for certain adult Medicaid enrollees. What some would describe as a straightforward new eligibility requirement — demonstrating 80 hours a month of work or other qualifying activities or establishing an exemption — is anything but.
States must build new eligibility processes, update technology systems, train staff on and help members navigate complicated rules. It’s logistically challenging and the consequences of getting it wrong are significant: People who remain eligible for coverage could lose their access to health care because they misunderstood a notice, missed a deadline or struggled to document an exemption.
One of the biggest challenges is distinguishing Medicaid enrollees who must meet work reporting requirements from those who qualify for an exemption. Medical frailty is particularly difficult to assess. Having a serious medical condition like cancer doesn’t automatically qualify someone for an exemption; states must determine whether that condition affects a person’s ability to meet the requirements, often with incomplete information.
Massachusetts is trying to reduce the burden on enrollees and applicants by using existing data to identify people who are exempt or already compliant. However, not everyone can be identified automatically — making clear consumer communication and accessible assistance essential.
MassHealth is working closely with community organizations and providers to help members understand what the new rules mean for them. Health Care for All Massachusetts has expanded its community-based partner network from about 30 organizations to nearly 50, building on lessons from the state’s post-pandemic Medicaid renewal effort.
Massachusetts found that people often turn to trusted local organizations, health centers and help lines before they turn to a state agency. Still, those partners need the training and resources on these new and complicated requirements to help members navigate the process — which is where states can step in.
Massachusetts estimates that up to 175,000 residents could lose coverage due to work reporting requirements and six-monthly eligibility checks. Nationally, Manatt Health estimates nearly one in 10 Medicaid enrollees nationwide may lose coverage from such changes.
A large swath of those losses will stem from administrative hurdles, not because people fail to meet the requirements, and those challenges will grow in 2028 when more frequent renewals and tighter limits on self-attestation add further demands. States will need to track enrollment patterns, listen to community partners and respond quickly when problems arise, rather than wait months for the data to tell the full story.
The Bottom Line
Listen to the full episode of The 80 Million Podcast to hear how Massachusetts is preparing, where the biggest risks lie and what other states can learn from its approach.
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