Episode Details

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 med