What Are Medicaid Work Requirements?
Changes are coming to the Medicaid program, including MO HealthNet, in the form of work and community engagement requirements. These new policies, which must be deployed by the state by Jan. 1, 2027, make continued Medicaid eligibility contingent on participation in work or other qualifying activities. These requirements typically apply to low-income adults ages 19-64 who earn up to 138% of the Federal Poverty Level or certain waiver programs who are eligible for health insurance coverage through Medicaid.
Signed into law on July 4, 2025, the One Big Beautiful Bill Act (H.R. 1) is an extensive federal budget reconciliation bill that introduced several changes to Medicaid, including mandatory work requirements and phased-in funding cuts. Under the new federal law, eligible individuals must complete 80 hours per month of one or more of the following:
- paid employment
- workforce training or job search programs
- half-time enrollment in an educational program
- community service
- a combination of these activities
Exemptions may exist for certain individuals including children, seniors, the medically frail, caregivers of young children or disabled individuals, and veterans with disabilities.
In addition, increased eligibility verification also will take effect Jan. 1, 2027, for the low-income adult enrollee population, meaning they must verify employment status twice a year.
What Does This Mean for Missouri?
Various reports estimate as many as 96,000 Missourians ages 19 to 64 could lose coverage related to compliance with the new requirements and navigating the process twice per year.
Additionally, states, including Missouri, face a complex and likely costly implementation process. They must:
- build systems to track work hours and exemptions
- redesign eligibility processes
- prepare for potential coverage losses and increased uninsured rates
What Comes Next?
The U.S. Department of Health and Human Services (HHS) is required to release implementation guidance by June 1, 2026. States must comply by Dec. 31, 2026, unless granted a temporary extension through 2028 for demonstrating good-faith efforts.