Health advocates, hospital systems and Ohio residents on Medicaid are all bracing for one thing in coming months: new work requirements for people getting government-sponsored health insurance.
The Medicaid program — which insures about a quarter of residents across Ohio and close to one in three in Cuyahoga County — has never before required recipients to work.
But that will soon change as a result of a bill President Donald Trump signed into law last year, which also expanded work requirements for people in the SNAP program, or government food assistance.
Since the law passed, the federal government has begun rolling out more specifics. But a number of questions are still unanswered, even though the deadline to implement the new work requirements is January 2027.
“We don’t have certainty on a lot of these things, and we’re getting so close to when people are actually going to need to engage in the process,” said Tara Britton, the director of public policy and advocacy at the Cleveland-based Center for Community Solutions.
Here’s what we know about the new rules and what we don’t.
What are Medicaid work requirements?
Work requirements mean that people receiving Medicaid will have to prove that they work, do community service or are enrolled in an education program for 80 hours a month.
This can include unpaid work like caregiving or working in exchange for goods and housing, said John Corlett, a senior visiting fellow at the Center for Community Solutions and the former Ohio Medicaid director, in a recent webinar.
Any combination of work, school and community service that adds up to 80 hours can count.
When will the new work requirements start in Ohio?
The work requirements must be implemented by Jan. 1, 2027.
States can request to start them earlier or request a “good faith” extension to delay until December 2028. A spokesperson with Ohio’s Department of Medicaid said it does not plan to ask for an extension.
Who has to meet the work requirements?
The work rules don’t apply to everyone who has Medicaid. Kids and seniors don’t have to comply. Instead, the work requirement will fall on people who are between 19 and 64 years old who are not pregnant or do not meet another exemption, such as having a disability.
The work requirements don’t apply to residents with other types of insurance, such as Medicare, which is government-subsidized insurance for people over 65. They also don’t apply to people who buy insurance on the federal marketplace or who get private insurance through their work.
How do I prove I meet the new work requirements?
This is one area that still lacks clarity, said Brian O’Rourke, a healthcare policy analyst at the Health Policy Institute of Ohio.
The state plans to verify as much as possible automatically, O’Rourke said. That means using existing government data sources to confirm that someone works or is in school rather than ask them for more paperwork.
The hope is that people who already work will automatically qualify based on income that comes from paychecks, which the state tracks, Corlett said in an interview. The minimum income to prove a person works 80 hours a month is $580, he said: 80 times the federal minimum wage. Since Ohio’s minimum wage is higher than the federal minimum wage, Ohioans will only need to work about 53 hours a month at minimum wage to meet the income limit.
But it can get trickier for people who don’t automatically meet the income threshold, Corlett said — students, gig workers, volunteers or people doing unpaid work. Those residents may have to provide paystubs, documentation from school enrollment or letters from employers or volunteer organizations, the Ohio Department of Medicaid indicated in a presentation last fall. Those documents would likely need to be provided when applying for or when renewing applications every six months, Corlett said.
In general, tracking and proving hours will be difficult for individuals and county offices attempting to administer the Medicaid program, Corlett said.
Who is exempt from the work requirements?
Outside of age and pregnancy, there are other ways to qualify for an exemption from work requirements. Those include:
- Being a current or former foster child under the age of 26
- Being a parent, guardian or caregiver of a dependent child 13 years of age and under, or a disabled individual
- Participating in a substance use disorder (SUD) treatment program
- Being incarcerated or recently released from incarceration
- Meeting the SNAP or TANF work requirements
- Being “medically frail,” a definition that the federal government is still in the process of refining.
A full list of exemptions is here.
Who counts as ‘medically frail’?
The federal government is currently in the midst of defining “medically frail.” When the law passed last year, it was defined as someone:
- Who is blind or disabled as defined by the Social Security Administration
- Has a substance use disorder
- Has a disabling mental disorder
- Has a physical, intellectual or developmental disability that significantly impairs ability to perform daily living activities
- Has a serious or complex medical condition
Advocates initially believed the broad definition of medical frailty left the door open to exempting many participants from work requirements. In Ohio, the state estimated about 40% of the more than 769,000 people subject to the new work requirements would qualify as medically frail or could be reviewed for such an exemption, Corlett recently wrote in an article for Community Solutions.
But information the federal government recently published about how states should roll out the work rules is stricter. It requires people who are medically frail to show that their condition impairs their ability to work or volunteer.
That will likely make it more difficult for residents to meet the exemption, because states can’t automatically qualify a patient based on their medical records, said Jesse Cross-Call, a leader at Families USA, a healthcare consumer advocacy organization, in a recent webinar.
“The individual has to prove that because of this condition, they cannot work,” Cross-Call said. It might require a doctor’s note, he said, which would be difficult for someone without insurance to get.
However, this rule is not final. Public comment on the federal government’s proposed definition of medical frailty and the rest of the work requirements is open until July 31. The federal government will respond to feedback and finalize the rule in the next several months.
And, the rule is tied up in court: 25 Democratic-led states sued in June, saying the Trump administration’s definition of medical frailty will make it too difficult for ill and disabled people to remain on Medicaid.
How do I prove I meet an exemption?
This is another question that still lacks a solid answer, O’Rourke said.
The state hopes to use its existing databases to automatically exempt everyone who qualifies. For those who don’t, the State of Ohio currently lists documents or statements that can help verify a person is exempt from work rules. But they are subject to change as the federal government finalizes rules, the state wrote.
| Exemption | Verification |
| Pregnant or postpartum |
|
| Parent or caretaker to child age 13 and under or disabled Individual |
|
| Current or former foster care child up to age 26 |
|
| Disabled veteran (rated as total) |
|
| Medically frail including disability or hospitalization or serious illness |
|
| Drug or alcohol treatment |
|
| Incarcerated (current or released within prior 90 days) |
|
| Member of a Native American tribe |
|
I’m applying for Medicaid. Can I start working once I get on the program?
The state will be looking at whether individuals applying for Medicaid are working before they join the program. As part of the application process, the state will seek proof of work or community service in the one month before the application was submitted, O’Rourke said.
Similarly, when a person gets their Medicaid renewed, the state will review the prior six months to see whether they met the work requirement.
Ohio must begin reaching out to Medicaid recipients who may be impacted by the new work requirements no later than September, though the state expects the process to begin in July and August, according to the Health Policy Institute of Ohio.
What happens if I don’t meet the work requirements or qualify for an exemption?
You may be denied or cut off from Medicaid benefits.
If that happens, patients will receive a state notice explaining the decision and information on how to request a state hearing on the application, Corlett said.
If Medicaid is discontinued, Corlett emphasized that residents can reapply for coverage at any time and aren’t subject to a waiting period — though they will be subject to the new rules.
