- Bidisha Gupta
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Medicaid work requirements arrive in 2027. CMS issued an interim final rule on June 1, 2026. Under it, states must generally put the new community engagement requirement in place by January 1, 2027. Some may start earlier. It covers certain adults in the Medicaid expansion group and some Section 1115 demonstrations, across 43 states and the District of Columbia. Those adults must show 80 hours a month of work, school, or community service, or monthly income of at least $580 in 2026.
For health plans, the hard part is reaching members in time. Some members who meet the requirement, or qualify for an exemption, may still lose coverage. The usual cause is an unanswered state notice. This guide explains who is affected and what plans can and cannot do. It then sets out how to run Medicaid member outreach before the first notices go out.
Who Is Subject to Medicaid Work Requirements, and What Do They Require?
The requirement applies to non-pregnant adults aged 19 to 64 who are not on Medicare. They must be in the Medicaid adult group or certain Section 1115 demonstrations. It does not apply to every Medicaid member in a state. The table below summarizes the key terms from the CMS fact sheet.
| Rule element | What it means for members |
|---|---|
| Who is covered | Non-pregnant adults aged 19 to 64 in the Medicaid adult group or certain Section 1115 demonstrations, not enrolled in Medicare |
| Where and when | 43 states and the District of Columbia; states must generally implement by January 1, 2027, and may start earlier |
| The monthly test | 80 hours of work, community service, a work program, or at least half-time education, alone or combined |
| Income alternative | Monthly income of at least 80 times the federal minimum wage ($580 a month in 2026) |
| Applicants | Must meet the requirement for one or more months before the month they apply, as set by each state |
| Current members | Must meet it for one or more months between renewals; states verify at renewal and may check more often |
| If the state cannot verify | The member gets a notice and 30 calendar days to show compliance or that an exception applies |
| Mandatory exemptions | Include medically frail adults, parents and caregivers of young children or disabled individuals, veterans with a total disability rating, people in substance use treatment, and others |
Two details matter most for outreach. First, the 30-day window is short, and it starts when the notice is sent. A notice at that stage is not a final decision; it is a chance to show compliance or an exception. Second, exemptions are not always automatic. For example, a member who is medically frail may still need to tell the state, or provide records, before the exemption counts.
States may also offer short-term hardship exceptions. These cover situations such as a hospital stay, a declared disaster in the member’s county, or high local unemployment.
Why Notices and Documentation Drive Coverage Risk
CMS expects real enrollment losses. Its impact analysis in the Federal Register rule projects enrollment to fall by about 2.3 million people in fiscal year 2027. That analysis covers two groups. One is people who do not meet the requirement. The other is people who may meet it, or qualify for an exception, but do not successfully show that status.
The second group is where health plans can make a difference. These members missed a letter, did not know an exemption applied, or could not get their hours recorded in time. That makes timely notices, documentation, and Medicaid member communication operational issues for plans, not only policy questions for states.
The pattern will feel familiar to anyone who worked through Medicaid redeterminations. Members move, change phone numbers, and ignore mail that looks official. Meanwhile, many affected adults juggle hourly jobs, caregiving, and transport. So plans that reach members early, by phone and text and in their own language, will help more of them keep coverage. A clear eligibility verification checklist for staff helps here too.
How Can Health Plans Support Members Without Making Eligibility Decisions?
The rule draws a clear line. Managed care plans can help members meet the requirement, but they cannot decide whether a member complies. According to the interim final rule, plans may support outreach, education, and referrals. They may also share information that helps states identify members who may be exempt. However, eligibility and compliance decisions stay with the state.
States may delegate some functions to plans, with conflict-of-interest safeguards. Yet the state must keep certain activities, including formal noncompliance notices. So outreach should point members to the state’s own process, never replace it. The table below sets out the boundary.
| Health plan can support | State retains responsibility |
|---|---|
| Explain the requirement using state-approved information | Decide whether the requirement applies to a member |
| Help members find the correct state reporting channel | Verify qualifying activity, income, and exceptions |
| Identify members who may qualify for an exception and point them to the state process | Grant or deny exceptions |
| Provide contact details, reminders, and referrals to work or training programs | Issue formal notices and make eligibility decisions |
| Route members with support needs to care management or community resources | Decide whether coverage continues |
Within that boundary, plans still hold real advantages. A plan often knows more about a member than the state does: conditions, providers, and a current phone number. Used well, that knowledge helps members act before a deadline passes.
How Should Health Plans Prepare for More Member Calls?
Every state notice creates calls. Members will call their health plan because its number is on their card, even when the question belongs to the state. They will ask whether the letter is real, whether they are exempt, and what counts as work. Many will call in the last few days of the 30-day window.
Volume will not arrive evenly. Instead, it will follow each batch of state notices and each renewal cycle. So the peaks depend on how your states schedule their mailings. A plan that staffs for an average week will miss the spike. Equally, a plan that hires a permanent team for a temporary peak will carry cost long after the wave passes.
Language adds pressure. Plans with large Spanish-speaking membership need native speakers on these calls, not a translated script read slowly. Rules about hours, exemptions, and deadlines are hard to explain in a second language. That is why bilingual call center capacity belongs in the plan from the start, along with coverage for other languages your members use.
An Outreach Timeline for the Weeks Before January 1
With January 1, 2027 about nine weeks away, a classic 90-day plan is already too long. The timeline below works back from that date. Then it repeats with each state’s notice cycle, because notices, not the calendar, should trigger staffing.
| When | Focus | Key actions |
|---|---|---|
| Now to November 15 | Know your states and members | Confirm each state’s start date, notice schedule, and approved messages; identify affected adults; flag members who may qualify for an exception; refresh phone numbers and language preferences |
| November 16 to January 1 | Reach members before notices | Run outbound calls, texts, and mail explaining what is coming; point likely-exempt members to the state process; publish a simple FAQ in English and Spanish; train inbound staff |
| Each state notice cycle, from January | Help members respond | Staff inbound lines for notice-driven calls; send reminders at day 10 and day 20 of each 30-day window; follow up with members who have not responded; report results by state |
If a state you serve has already started, or you have fewer than 60 days, compress the plan. Start with members who already have a notice outstanding. Next, contact members most likely to be exempt, since they have the most to lose from a missed response. Then widen outreach to everyone else in the expansion group.
Keep messages short and practical. Tell members what the requirement is, whether they might be exempt, and the one action they need to take. Also, give every member a direct way to reach a person. Many will not trust an automated message about losing coverage.
Outbound contact must also follow consent and calling rules, so involve your compliance team in channel choices early. Text messages, in particular, need clear consent records. Finally, record every contact attempt and outcome, because you will need the data to report results to the state.
What to Measure
Call volume alone will not tell you whether outreach is working. Instead, measure whether members responded in time and kept coverage. The table below lists the measures that matter most.
| Measure | Why it matters |
|---|---|
| Members reached before their first notice | Shows whether outreach is early enough to prevent missed deadlines |
| Members referred to the state exception process | Shows whether plan data is reaching members who may be exempt |
| Responses within the 30-day window | The clearest early signal of coverage that will be kept |
| Coverage kept at renewal | The outcome that matters to members, the state, and the plan |
| First-contact resolution on notice calls | Repeat calls mean members are confused, which raises the risk of missed deadlines |
Report these weekly by state and by language. If Spanish-speaking members respond more slowly, you will see it early enough to fix it. Likewise, if one state’s notices drive far more calls, you can move staff before the queue builds.
What to Confirm With Each State
Implementation details vary by state, and they may change as states finalize their processes. So rather than relying on a national summary, keep a short, dated checklist for each state you serve:
- State implementation date, and any approved delay
- Which Medicaid populations are covered
- Verification frequency and look-back period
- The state’s notice and response process
- Hardship exceptions the state offers
- Communication channels and messages the state has approved
- Escalation and referral contacts at the state agency
Review the checklist whenever a state issues new guidance. Then share the changes with every team that talks to members, including any outside partner.
What to Look for in a Medicaid Outreach Partner
Most plans will need extra capacity for 2027, at least for the first renewal cycles. Plans can hire and train temporary staff in house. Alternatively, they can work with a partner who scales a trained team with each wave of notices. In that case, a senior buyer’s first question should be how to add capacity without adding compliance or member-data risk.
- Experience with Medicaid member services or health plan outreach campaigns
- HIPAA obligations, business associate agreements, and data-access controls
- Fit with your state contracts on offshore access and subcontracting
- Use of state-approved scripts, clear escalation paths, and quality monitoring
- Native Spanish speakers, plus other languages your members need
- Surge staffing, training time, and schedule flexibility
- Reporting by state, campaign, language, and contact outcome
Check state contracts with your legal and compliance teams before you choose a partner or a location. Many state Medicaid contracts limit offshore work or restrict where member data can be accessed, and terms differ by state. Some may treat delivery from outside the U.S., including nearshore delivery, as offshore. So confirm what each contract allows first.
For plans whose contracts allow it, SkyCom provides bilingual member outreach and inbound support for health plans. Our teams work U.S. hours and can scale with each notice cycle. Learn more about our health plan outsourcing services, or see how we support Medicare programs with the same compliance discipline.
Frequently Asked Questions
When do Medicaid work requirements start?
States must generally implement the requirement by January 1, 2027. Some states may start earlier, so check the date in each state you serve.
What counts toward the 80-hour requirement?
Work, community service, a work program, or at least half-time education, alone or combined. Monthly income of at least 80 times the federal minimum wage, $580 in 2026, also meets it.
What happens if a member does not respond to a notice?
If a state cannot verify compliance, it sends a notice and gives the member 30 calendar days to show compliance or an exception. Members who do not may be denied or disenrolled, but they can reapply at any time.
Can Medicaid managed care plans decide who is exempt?
No. Plans can support outreach, education, and referrals, but the state decides whether the requirement applies and whether an exception is granted.
Who is exempt from Medicaid work requirements?
The rule lists mandatory exemptions. They include medically frail adults, parents and caregivers of young children or disabled individuals, and veterans with a total disability rating. People in substance use treatment are also exempt, among others.
Plan Your Outreach Before the First Notices Go Out
Medicaid eligibility changes in 2027 will test every plan’s ability to reach members quickly and clearly. The rule gives states the decisions, but plans hold much of the data and the member relationship. As a result, plans that start outreach now and find likely exemptions early will help more eligible members keep coverage.
Need extra capacity for 2027? Talk to SkyCom about bilingual member outreach for your Medicaid lines of business. We will build a staffing plan around your states’ notice schedules.
