State tracker

Kentucky — Medicaid Coverage Retention

Applies Last updated 2026-06-03 · confidence: medium

Kentucky is subject to federal Medicaid community-engagement/work-requirement implementation beginning January 1, 2027, unless modified by future federal or state guidance.

Procurement / RFP activity

None identified

No public RFP for work-requirement communications/outreach identified as of 2026-06-03. Kentucky is implementing H.R.1/OBBBA community-engagement requirements by MODIFYING its existing integrated eligibility system contract with Deloitte rather than issuing a new competitive solicitation. Per KFF Health News, Kentucky's integrated eligibility system (Medicaid/SNAP) is run by Deloitte under a 5-year contract worth more than $157 million; days after the federal bill was signed in July 2025, the state made $1.6M of "high priority" / "emergency" system changes (some SNAP changes took effect almost immediately). No separate member-communications/outreach RFP, RFI, IFB, or ITB was found on the Kentucky eProcurement portal (finance.ky.gov / Vendor Self Service), SAM.gov, or BidNet Direct. The state-required H.R.1 member outreach (mail + electronic, due June 30 to Aug 31, 2026) is not, as of this date, tied to any publicly posted procurement.

Procurement portal: Kentucky eProcurement / Vendor Self Service (finance.ky.gov/eProcurement); also BidNet Direct (bidnetdirect.com/kentucky) and Kentucky Business One Stop (onestop.ky.gov). Federal: SAM.gov. · Implementation funding: Federal: H.R.1 appropriated ~$100M nationally in FFY2026 for state eligibility-system buildout (states draw down a share). Kentucky-specific: existing Deloitte integrated-eligibility contract >$157M/5yr; ~$1.6M in emergency "high priority" system modifications made post-enactment (total compliance cost not disclosed by KY officials). State implementation funded via HB 2 (2026 RS), "AN ACT relating to Medicaid, making an appropriation therefor," which also funds Auditor of Public Accounts Medicaid/KCHIP audits; specific outreach-comms line item not separately identified.

Latest detail

Kentucky's work-requirement mandate stems from HB 695 (2025 RS, enacted via veto override March 2025) directing CHFS to seek a "community engagement waiver," reinforced by HB 2 (2026 RS, enacted ~April 2026) requiring CHFS to condition Medicaid eligibility on community engagement no later than Jan 1, 2027, add cost-sharing/copays, and move to 6-month redeterminations by July 1, 2026. DMS projects reduced enrollment of ~4,295 in FY2027 and ~9,660 in FY2028 from the requirement (affecting roughly 478,900 expansion adults). Implementation is being executed primarily through modifications to the existing Deloitte-run kynect/integrated eligibility system rather than a new vendor procurement, consistent with KFF's finding that the compressed Jan 2027 timeline discourages states from running fresh RFPs. CMS issued its interim final rule (CMS-2454-IFC) on the federal requirement around June 1-3, 2026; tracking begins December 2026 with enforcement January 2027.

Medicaid expansion status	Expanded
Implementation status	Pending state guidance (federal default applies)
Who may be affected	Yes — expansion adults
Reporting frequency	Pending state guidance
Reporting method	Pending state guidance
Renewal cadence	Every 6 months for expansion adults (H.R.1)
Notice timing	Pending state guidance
Self-attestation allowed?	Pending state guidance
State system / vendor	Pending state guidance
Major Medicaid MCOs	Pending state guidance
Languages likely needed	Pending state guidance

Key exemption categories to monitor

80 hours/month of work, job training, education, or community service — or qualifying monthly income.
Targets many ACA Medicaid expansion adults (19–64); non-expansion states largely have no such group.
Federal enforcement: January 1, 2027 (states implement; some earlier).
New: expansion adults redetermine every 6 months (not annually).
Commonly-defined exemptions: pregnancy/postpartum; medically frail; primary caregiver; disability; SUD treatment; certain students; tribe (AIAN); short-term hardship. Exact definitions set by CMS rule and each state.

Short-term hardship exemptions to track

Short-term hardship exemptions — adoption pending state guidance.

Member communication risk

Risk detail pending.

What MCOs & state partners should do now

Segment affected members
Identify likely exemptions
Send plain-language multilingual notices
Deploy SMS/email/IVR reminders
Track retention outcomes

Operating in Kentucky?

The member-notice window is open now and closes August 31, 2026. Complete a Coverage Retention Readiness Audit while there is still time to act — we build CMS-compliant, plain-language, multilingual outreach to keep eligible Kentucky members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in Kentucky?

Many ACA Medicaid expansion adults ages 19–64 who do not qualify for an exemption. Final scope is set by CMS rule and state implementation.

When do Kentucky Medicaid work requirements start?

Federal enforcement begins January 1, 2027 (some states may implement earlier). Member notices are expected in the federally-required window of June 30–August 31, 2026.

What exemptions are available?

Federal baseline categories include parent/caretaker of a child under 14, pregnant/postpartum, disabled/medically frail, American Indian/Alaska Native, and those already meeting SNAP/TANF work rules. Short-term hardship exemptions and exact definitions are set by CMS rule and state implementation.

Sources

This page tracks publicly available implementation information and is updated as Kentucky publishes guidance. State-specific rules are evolving. Not legal or eligibility advice.