Coverage Retention Tracker
Medicaid Work Requirement & Coverage Retention Tracker
A 50-state + DC tracker for Medicaid community-engagement rules, exemptions, notice obligations, and procedural-disenrollment risk under H.R.1 / OBBBA. Updated as states publish guidance.
| State | Requirement applies? | RFP? | Implementation status |
|---|---|---|---|
| Alabama | Largely N/A | None identified | Pending state guidance — no ACA expansion population subject to the requirement |
| Alaska | Applies | None identified | Pending state guidance — Alaska DOH evaluating implementation approaches with federal partners; published a Feb 2026 coverage-impact modeling report |
| Arizona | Applies | Awarded | Planning for Jan 1, 2027 (federal deadline Dec 31, 2026). CMS approved Arizona's Section 1115 "community engagement" demonstration amendment on March 3, 2026 — Arizona is the first state whose approval includes a federally-recognized-tribe exemption. AHCCCS member outreach/communications required to begin by Sept 1, 2026. |
| Arkansas | Applies | Planned/Expected | Early implementer — soft launch July 1, 2026; hard enforcement Jan 1, 2027. Renewal 1115 waiver application submitted Dec 2025. |
| California | Applies | Planned/Expected | Planning for Jan 1, 2027 (DHCS implementation plan published; operational details pending CMS guidance and state rulemaking). California is implementing under protest — AB 2161 (Bonta) seeks to shield Medi-Cal coverage and minimize procedural loss. |
| Colorado | Applies | None identified | Actively planning/implementing for Jan 1, 2027; leveraging existing contractors. State Board of Medical Services to adopt rules; data publication begins March 1, 2027. |
| Connecticut | Applies | Open RFP | Planning / communications strategy in development for Jan 1, 2027; state may seek good-faith-effort delay (potentially to 2029) |
| Delaware | Applies | None identified | Pending state guidance (no DE-specific implementation plan verified; federal default applies) |
| District of Columbia | Applies | None identified | Pending state guidance — no DHCF-published implementation plan verified as of June 2026 |
| Florida | Largely N/A | None identified | Not applicable — Florida has not adopted ACA Medicaid expansion and has no expansion adult group, so the H.R.1 / OBBBA community-engagement (work) requirement has no subject population in Florida. No state implementation planning is required unless/until Florida expands Medicaid. A citizen ballot initiative to expand was paused from 2026 to a 2028 target after HB 1205 changed initiative rules. |
| Georgia | Pending | None identified | Established work-requirement program already operating (Pathways since July 2023). Waiver extended through Dec 31, 2026; state must come into compliance with the H.R.1 federal framework effective Jan 1, 2027. Transition/alignment details (e.g., moving from annual to twice-yearly reporting, broadening exemptions to the federal baseline) are Pending state guidance. |
| Hawaii | Applies | None identified | Pending state guidance |
| Idaho | Applies | None identified | State law enacted (HB 913, signed April 10, 2026); directs adoption of OBBBA work requirements by Dec. 31, 2026 with federal enforcement Jan 1, 2027 |
| Illinois | Applies | Awarded | Pending state guidance — planning for federal Jan 1, 2027 enforcement. HFS confirms changes begin affecting some Medicaid customers Oct 1, 2026 and Jan 1, 2027. No early-implementer 1115 waiver announced; HFS running an HR1 stakeholder webinar series (Module 3 Work Requirements & Community Engagement on Jul 14, 2026; Module 4 Exemptions on Jul 22, 2026). |
| Indiana | Applies | None identified | Planning for Jan 1, 2027; state work requirements (SB 2, 2025) delayed to align with federal timeline |
| Iowa | Applies | None identified | Early implementer — targeting Dec 1, 2026 (ahead of federal Jan 1, 2027 deadline) |
| Kansas | Largely N/A | None identified | Pending state guidance — requirements do not currently apply because Kansas has not expanded Medicaid; would apply only if Kansas expands in the future |
| Kentucky | Applies | None identified | Pending state guidance (federal default applies) |
| Louisiana | Applies | None identified | Planning/implementing for Jan 1, 2027 enforcement; LDH has published a dedicated work-requirements page with state-specific guidance |
| Maine | Applies | None identified | Planning for Jan 1, 2027; DHHS upgrading online system and hiring staff to administer requirements |
| Maryland | Applies | None identified | Planning for Jan 1, 2027 implementation; coordinating cross-agency data feeds (MDH/MHCC/DHS) to auto-apply exemptions; reported to be using AI to assist implementation. State Plan Amendment required by March 2027. |
| Massachusetts | Applies | None identified | Pending state guidance — MassHealth awaiting CMS guidance; planning for Jan 1, 2027 effective date |
| Michigan | Applies | None identified | Planning for Jan 1, 2027; member outreach to begin by Sept 30, 2026 |
| Minnesota | Applies | None identified | Pending state guidance — DHS preparing for federal default implementation; maintains a dedicated "Federal Medicaid changes" page |
| Mississippi | Largely N/A | None identified | Pending state guidance — no ACA expansion adult group exists, so H.R.1 community-engagement requirement has no defined target population in Mississippi |
| Missouri | Applies | Planned/Expected | Actively planning/building for implementation; constructing a Community Engagement Platform integrated with existing MEDES and FAMIS systems to track 80 hrs/month |
| Montana | Applies | None identified | Early implementer — rolling out work/community engagement requirements July 1, 2026 (ahead of federal Jan 1, 2027 deadline) |
| Nebraska | Applies | None identified | Early implementer — FIRST state in the nation to implement H.R.1 community-engagement/work requirements. Live as of May 1, 2026, ahead of the federal Jan 1, 2027 deadline. Phased compliance checks begin for coverage periods ending on/after July 31, 2026, rolling through June 2027. |
| Nevada | Applies | None identified | Pending state guidance — implementation specifics (including any waiver decisions) to be determined per CMS rules before federal enforcement |
| New Hampshire | Applies | None identified | Planning for implementation; state must have requirements in place by Dec 31, 2026 (tracking starts ~Dec 2026, enforcement Jan 1, 2027). Awaiting federal guidance on exemptions/verification. |
| New Jersey | Applies | None identified | Planning for federal community-engagement enforcement Jan 1, 2027; 6-month redeterminations for expansion adults begin Dec 31, 2026. State has published an official OBBBA/Federal Changes page and a member-facing self-check tool ("NJ FamilyCare Activity Requirements Checker," njfcchecker.nj.gov). Detailed operational rules (reporting workflow, notices, self-attestation) still rolling out — Pending state guidance. |
| New Mexico | Applies | None identified | Planning for Jan 1, 2027 federal enforcement; state reported to be using AI to assist implementation |
| New York | Applies | None identified | Implementation active — NYS DOH will mail work-requirement notices by Sept 1, 2026; federal enforcement Jan 1, 2027. NY + 24 other states are suing over the June 2026 federal rules (medical-frailty exemption bar / no claims-data auto-verification). |
| North Carolina | Applies | None identified | Planning for implementation; community-engagement reporting effective Jan 1, 2027; 6-month redeterminations begin Dec 31, 2026 |
| North Dakota | Applies | None identified | Pending state guidance — awaiting federal CMS specifics (expected 2026); not a 2026 early implementer |
| Ohio | Applies | Planned/Expected | Pending state guidance for operational details. ODM has publicly stated it does NOT have a confirmed start date for the H.R.1 Work and Community Engagement Requirement because it needs federal (CMS) guidance first; federal full-enforcement deadline is no later than Jan 1, 2027 (good-faith delay possible through Dec 31, 2028). Separately, Ohio's own 1115 waiver carried a placeholder Jan 1, 2026 start subject to CMS negotiation. ODM presented an implementation update to its Medicaid Advisory Council in February 2026. |
| Oklahoma | Applies | None identified | Planning/early implementation for the H.R.1 community engagement requirements; OHCA has published a public Community Engagement Requirements page and a Work Requirements Screener. Targeting implementation in advance of the federal deadline. |
| Oregon | Applies | None identified | Planning stage; awaiting federal guidance. OHA states work/activity rules and 6-month renewals begin "in 2027 at the earliest." |
| Pennsylvania | Applies | None identified | Planning for Jan 1, 2027; DHS outreach to begin by September 2026; flagged significant implementation challenges (staffing, ~$50M tech upgrades, undefined "medically frail") |
| Rhode Island | Applies | None identified | Pending state guidance — RI confirms it must change its Medicaid program to implement the new community engagement (work) requirements and 6-month renewals for expansion adults; detailed implementation plan not yet published |
| South Carolina | Largely N/A | None identified | Pending state guidance — H.R.1 community-engagement requirement largely N/A absent an ACA expansion adult group; SC pursuing its own separate state work-requirement waiver (distinct from H.R.1) |
| South Dakota | Applies | None identified | Planning for federal enforcement Jan 1, 2027 (state HR1 guidance published; ~1,213 expansion adults estimated to lose coverage) |
| Tennessee | Largely N/A | None identified | Pending state guidance — no expansion adult group subject to the requirement; federal default applies to expansion/qualifying-1115 states only |
| Texas | Largely N/A | None identified | Not applicable — Texas has not adopted ACA Medicaid expansion, so there is no expansion group subject to the H.R.1 community-engagement requirement. No state implementation is required or planned for the expansion group as of June 2026. (Indirect fiscal effects from H.R.1 SNAP/ACA/financing provisions still expected, but no work-requirement program.) |
| Utah | Applies | None identified | Pending state guidance; DHHS publishing H.R.1/OBBBA partner FAQs (Jan 2026). Earlier voluntary state work-requirement waiver (target July 2026) reported as not advancing; federal Jan 1, 2027 mandate governs. |
| Vermont | Applies | None identified | Planning / member communications scheduled to begin August 2026; new-applicant enforcement Jan 1, 2027 |
| Virginia | Applies | None identified | Active implementation — DMAS has published guidance/FAQs; preparing for federal enforcement Jan 1, 2027 |
| Washington | Applies | None identified | Planning for federal implementation; HCA has indicated it will seek a federal exemption/delay (good-faith effort extension) of the enforcement date |
| West Virginia | Applies | None identified | Planning/preparing for Jan 1, 2027 federal deadline; DoHS partnering with WVU Health Affairs on systems and project management |
| Wisconsin | Largely N/A | None identified | Planning for Jan 1, 2027 effective date. Wisconsin DHS has publicly confirmed BadgerCare Plus work requirements take effect January 1, 2027; federal officials indicated they are unlikely to grant implementation extensions. Detailed operational rules pending state guidance. |
| Wyoming | Largely N/A | None identified | Pending state guidance — no expansion population subject to requirement |
Informational tracker compiled from public sources; updated as states publish guidance. State-specific rules are evolving. Not legal or eligibility advice.