With Medicaid work reporting requirements just a few months away, states are scrambling to make complex changes to their eligibility and enrollment systems and processes. States must also do targeted outreach to communicate new work reporting requirements (WRRs) to affected Medicaid expansion adults and new applicants. Many states launched websites this summer informing enrollees about upcoming federal law changes, and most states sent outreach notices in August to affected Medicaid expansion adults. CCF has been tracking and compiling state agency webpages, toolkits, flyers, FAQs, and outreach notices from the 43 states, including DC, implementing WRRs.
State outreach materials must communicate clear messages now, before implementation is in full swing, so that individuals know about the new requirements, if they are affected, and what they need to do to keep coverage. One of the many problems with past WRR experiments is that most enrollees don’t know about the WRRs and whether they are impacted by them. When Arkansas implemented WRRs in 2018, one third of the affected population surveyed said they had not heard anything about the policy, and nearly half said they were unsure whether the policy applies to them. Within two months of implementation, New Hampshire suspended its 2019 WRRs, in part due to a failure to reach affected enrollees.
Today, public awareness of the massive changes in 2027 remains dangerously low. Centers for Medicare and Medicaid Services (CMS) qualitative research from April 2026 found that Medicaid enrollees are largely unaware of work requirements and may have difficulty identifying if they are affected under the new law, with confusion highest among caregivers and people with disabilities. Recent focus groups in Missouri found that both Medicaid expansion enrollees and health providers don’t know that changes are coming.
A review of state notices, flyers, and toolkits developed so far reveals a few themes:
- States are struggling to clearly explain exactly who is subject to WRRs. Because WRRs apply to only some Medicaid enrollees, states are attempting to explain new requirements to those affected by WRRs, while also explaining who is not subject to WRRs – with mixed results. The law requires states to send outreach notices to adults enrolled in Medicaid expansion coverage – not people enrolled in Children’s Medicaid, Pregnancy Medicaid, or parents in Section 1931 Parent/Caretaker Relative coverage, for example. But, people are hearing about upcoming changes on the news or on social media, and getting confused as to whether they have to meet new mandates. This massive confusion is already playing out in Nebraska, a state that implemented WRRs early in May 2026. Adding to the confusion is the fact that Medicaid health insurance cards rarely specify coverage groups. It may not be clear to enrollees – and eligibility workers and application assisters – whether a person is enrolled in Medicaid expansion, Medicaid for pregnancy coverage, the state’s 1931 parent/caretaker coverage, or a disability-based Medicaid category.
To help reduce confusion, several states offer unofficial digital screening tools (CT, CO, IN, LA, MA, NJ, VT, WI, WV; find links here) that allow anyone to walk through questions, see if they are subject to WRRs, exempt, or meet the monthly income or work requirements under the new law. Individuals can check their status without logging into the state’s benefit portal or their Medicaid account. Some of these screeners are inspired by the Digital Integrative Guide (DIG) created by Civila, which offers a free template screener for states to adapt and integrate into their websites.
Additionally, a few states include specific language in their notices or websites explaining which Medicaid coverage groups ARE and ARE NOT subject to WRRs, such as Virginia’s notice and Colorado’s webpage. (Though this still won’t help individuals who aren’t sure what coverage group they are enrolled in.) - In 27 states and DC, almost all parents or caretaker relatives living with a child are either exempt or satisfy WRRs through income. Yet, very few states communicate this. Notices correctly describe the exclusion in H.R. 1 that parents and relatives caring for a child aged 14 or younger or a disabled individual are excluded from WRRs. But, the scope of parents who should not lose coverage due to WRRs is actually broader than that in most states. In 27 states plus DC, almost all parents or caretaker relatives living with a child (regardless of age) are either in another Medicaid coverage group (i.e., the state’s Section 1931 parent/caretaker coverage, and not subject to WRRs) or satisfy WRRs because they have household income above $580 per month. Minnesota’s webpage notes that parents in Medicaid who “live with their children under age 19” are not subject to WRRs, and Illinois similarly clarifies in its recent notice that WRRs only apply to “ACA Adults” – defined as those who “[d]o not have a child under 18 residing in your home who is related to you.” In most other states, the message for parents living with children is missing from outreach materials.
- State materials vary in how they highlight the $580 per month income proxy to satisfy WRRs. One of the most streamlined ways for states to verify WRR compliance is the income proxy: having a household income of at least $580 per month (based on federal minimum wage multiplied by 80 hours, in 2026). States must first use existing data to automatically determine or re-determine Medicaid eligibility – including checking data for income and for WRR compliance or exclusions – before requesting additional information from the applicant or enrollee (Learn more about state data processes in CCF’s IFR Explainer here). Yet, some notices bury this crucial $580 threshold under dense text explaining the qualifying work, school, and volunteer activities (e.g., West Virginia and Pennsylvania).
- Successful communication to enrollees should be action-oriented, yet state notices are often missing the “how to” on verification, which would help enrollees know HOW to show they are excluded from or meet WRRs. Code for America has developed extensive resources (Medicaid WRR Guide) and a Model Medicaid WRR Outreach Notice reinforcing ways to provide clear, plain language, and action-oriented communication. But, ever-changing CMS guidance to states and the June 2026 Interim Final Rule have left many critical questions about WRR implementation unanswered, especially when it comes to how enrollees show they are medically frail or meet other exclusions under H.R. 1. It is no surprise that states feel ill-equipped to give more details on their websites or outreach notices about how exactly enrollees should document and report that they meet an exclusion or satisfy WRRs. As an example, North Carolina’s notice outlines various WRR exclusions but simply tells enrollees to “Save any papers that show you are exempt. Your local Department of Social Services (also called DSS) may need to see them.” This lack of detail will inevitably increase anxieties and confusion about already-complex reporting requirements.
- For a sneak peak into how complicated verification will be nationwide, look to Montana, which implemented WRRs early in July 2026. Montana’s Verification Matrix is a sprawling, complex list of the various documents, self-declaration forms, and paperwork adults must submit (or the state must look at) to prove compliance or claim one of the 10 specific exclusions or short-term exceptions. Montana’s complex web of paperwork may soon be the reality nationwide for Medicaid expansion adults. Without clear, plain-language “how to” instructions on verification, enrollees will be more confused, anxious, and may lose health coverage they are eligible to receive.