Ohio is on the brink of significant changes to its Medicaid program. Starting in January 2027, recipients will need to meet new work requirements to maintain their health coverage. This shift, mandated by a federal law signed last year, aims to integrate work obligations into the Medicaid program, much like those already in place for the SNAP food assistance program.
The upcoming changes have sparked a mix of anticipation and uncertainty. While some details have been clarified, many questions remain unanswered. Tara Britton, director of public policy and advocacy at the Center for Community Solutions, captures the sentiment well: 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.
Understanding the New Work Requirements
The new rules stipulate that Medicaid recipients must prove they are working, engaged in community service, or enrolled in an education program for at least 80 hours a month. This requirement can be met through a combination of work, school, and community service. Unpaid work, such as caregiving or bartering for goods and housing, also counts toward this requirement, as noted by John Corlett, a senior visiting fellow at the Center for Community Solutions and former Ohio Medicaid director.
Implementation Timeline
The work requirements must be fully implemented by January 2027. However, states have the option to request an earlier start or a good faith extension to delay implementation until December 2028. Ohio’s Department of Medicaid has indicated it does not plan to seek an extension, meaning the state is on track to meet the January 2027 deadline.
Who Is Affected?
Not all Medicaid recipients will be subject to the new work requirements. Exemptions include children, seniors, and individuals who are pregnant or meet other criteria, such as having a disability. The work requirements apply to individuals aged 19 to 64 who do not qualify for an exemption. Importantly, the requirements do not apply to those with other types of insurance, such as Medicare, private insurance, or insurance purchased on the federal marketplace.
Proving Eligibility
One of the most challenging aspects of the new requirements is proving eligibility. Brian O’Rourke, a healthcare policy analyst at the Health Policy Institute of Ohio, notes that the state plans to verify as much as possible automatically using existing government data sources. This approach aims to minimize the need for additional paperwork.
For individuals who already work, the state will use income data from paychecks to verify eligibility. The minimum income required to prove 80 hours of work is $580 which is 80 times the federal minimum wage. Given that Ohio’s minimum wage is higher than the federal minimum, Ohioans will only need to work about 53 hours a month at the state’s minimum wage to meet the income threshold.
However, proving eligibility can be more complex for students, gig workers, volunteers, or those engaged in unpaid work. These individuals may need to provide paystubs, school enrollment documentation, or letters from employers or volunteer organizations. The Ohio Department of Medicaid has indicated that these documents will likely be required when applying for or renewing Medicaid coverage every six months.
Exemptions and Special Considerations
Several exemptions exist for individuals who cannot meet the work requirements. These include being a current or former foster child under the age of 26, being a parent or caregiver of a dependent child aged 13 or younger, participating in a substance use disorder treatment program, being incarcerated or recently released from incarceration, and meeting the work requirements for SNAP or TANF.
Medically Frail Exemption
One of the most significant exemptions is for individuals classified as medically frail. The federal government is still refining the definition of this term, which initially included individuals who are blind or disabled, have a substance use disorder, have a disabling mental disorder, or have a serious or complex medical condition. Advocates hoped this broad definition would exempt many participants from work requirements. In Ohio, it was estimated that 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.
However, recent guidance from the federal government has narrowed the definition, requiring individuals to prove that their condition impairs their ability to work or volunteer. Jesse Cross-Call, a leader at Families USA, notes that this change will likely make it more difficult for residents to meet the exemption, as they may need to provide a doctor’s note, which can be challenging for those without insurance.
The federal government is currently accepting public comments on the proposed definition of medical frailty and the rest of the work requirements. The final rule is expected to be issued in the coming months. Additionally, the rule is tied up in court, as 25 Democratic-led states have sued, arguing that the Trump administration’s definition of medical frailty will make it too difficult for ill and disabled people to remain on Medicaid.
Proving Exemptions
Proving eligibility for exemptions also presents challenges. The state hopes to use existing databases to automatically exempt everyone who qualifies. For those who do not, the State of Ohio currently lists documents or statements that can help verify a person is exempt from work rules. However, these requirements are subject to change as the federal government finalizes the rules.
Examples of documents that may be required include a verbal or written statement of pregnancy, a doctor’s statement, a disability award letter, a birth certificate, custody documents, a court order, a letter from a public children’s services agency, proof of release statement, bail-related documentation, a tribal identification card, and an official statement from a federally recognized tribe.
Applying for Medicaid Under the New Rules
The state will review 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 month before the application was submitted. Similarly, when a person renews their Medicaid coverage, 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.
Consequences of Non-Compliance
Individuals who do not meet the work requirements or qualify for an exemption may be denied or cut off from Medicaid benefits. If this happens, patients will receive a state notice explaining the decision and information on how to request a state hearing on the application. Corlett emphasized that residents can reapply for coverage at any time and are not subject to a waiting period, though they will be subject to the new rules.
