Friday, October 3, 2025

Tracking Medicaid Patients’ Work Status

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Introduction to Medicaid Work Requirements

By Shalina Chatlani, Stateline.org

States must begin verifying millions of Medicaid enrollees’ monthly work status by the end of next year — a task some critics say states will have a hard time carrying out. A provision in the tax and spending bill President Donald Trump signed into law July 4 will require the 40 states plus Washington, D.C., that have expanded Medicaid to check paperwork at least twice a year to ensure those enrollees are volunteering or working at least 80 hours a month or attending school at least half time.

Challenges in Implementing Work Requirements

The new law provides states $200 million for fiscal year 2026 to get their systems up and running. But some experts say states will have difficulty meeting the deadline with that funding and worry enrollees might lose their health benefits as a result. A year and a half to comply is likely not going to be enough time for most states, especially since the federal government must craft guidance on how they should implement their programs, said Dr. Benjamin Sommers, a health economist at Harvard T.H. Chan School of Public Health.

State-Level Concerns and Preparations

A spokesperson for the North Carolina Department of Health and Human Services, Hannah Jones, told Stateline that “it will take a significant amount of time and investment in order to implement work requirements.” Jones said an estimated 255,000 people in North Carolina could lose coverage because of these requirements and their “administrative burden.” In contrast, Emma Herrock, a spokesperson for the Louisiana Department of Health, wrote in an email that the vast majority of the state’s Medicaid enrollees already work, and the agency expects few people to be disenrolled.

Historical Context and Lessons Learned

Previous attempts at implementing work requirements have ended up costing states millions in administrative and consulting fees. And in some cases, people who were eligible for Medicaid lost their coverage due to paperwork issues. Arkansas’ experience in 2018, where over 18,000 residents lost Medicaid coverage during the 10 months the requirements were in effect, serves as a cautionary tale. Most people were disenrolled because they didn’t know about the policy or made paperwork errors, not because they weren’t working.

Technical and Administrative Challenges

Each state has varying technological capabilities, and will have a different timeline and budget. Michael Heifetz, a managing director at consulting firm Alvarez & Marsal and a former Medicaid director in Wisconsin, noted that states will need to share data across agencies in new ways. “It will require some form of data sharing and communications with educational agencies, workforce training agencies and some other agencies that typically aren’t in the Medicaid ecosystem,” Heifetz said.

Other State Efforts and Federal Oversight

Efforts in other states to implement work requirements have had mixed results. In Georgia, for example, an experimental work requirement program cost taxpayers more than $86 million in its first 18 months but enrolled just 6,500 people during that time. The nonpartisan U.S. Government Accountability Office in 2019 looked at five states that tested systems to track Medicaid work requirements under the first Trump administration and found significant administrative costs that far surpassed the $200 million Congress has provided in the new law.

Conclusion

Implementing Medicaid work requirements poses significant challenges for states, from technological and administrative hurdles to concerns about disenrollment and loss of health benefits. While some argue that advanced technology can streamline the process, others warn that the burden will fall on patients, doctors, and state agencies, potentially leading to unintended consequences. As states navigate these requirements, careful consideration of the complexities and potential impacts on Medicaid enrollees is crucial.

FAQs

  1. What are the new Medicaid work requirements?

    • The new requirements mandate that Medicaid enrollees in expanded Medicaid programs work or volunteer for at least 80 hours a month, or attend school at least half-time, with states verifying this information at least twice a year.
  2. How much funding have states been given to implement these requirements?

    • States have been allocated $200 million for fiscal year 2026 to implement the work requirement systems.
  3. What are the concerns about implementing these requirements?

    • Concerns include the tight deadline, potential for enrollees to lose health benefits due to administrative burdens, and the significant costs associated with implementing and maintaining these systems.
  4. Can states receive an extension on the implementation deadline?

    • Yes, the Trump administration can grant states an extension until December 31, 2028, if they demonstrate a good faith effort to implement the requirements.
  5. How might these requirements affect Medicaid enrollees and healthcare providers?
    • Enrollees may face challenges in maintaining their coverage, and healthcare providers may bear additional administrative burdens in helping patients comply with the new requirements.
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