State tracker

Maryland — Medicaid Coverage Retention

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

Maryland 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.

Procurement portal: eMaryland Marketplace Advantage (eMMA, emma.maryland.gov) is the statewide eProcurement portal; the Maryland Health Benefit Exchange posts its own solicitations at marylandhbe.com/solicitations, and MDH lists business opportunities via health.maryland.gov/ocmp. SAM.gov for any federal-pass-through pieces. · Implementation funding: State implementation funding (not a dedicated comms RFP): Gov. Wes Moore earmarked ~$13M in general funds for HR1/OBBBA administrative implementation to reduce needless coverage loss; MDH allocated ~$2M for 25 new positions to handle new eligibility/work-requirement/redetermination work. WYPR (Apr 2026) reports federal Medicaid/SNAP changes will cost MD ~$71M over FY26-27. Separately, MD is deploying ~$168M in OBBBA rural-health transformation funds (distinct program). No state line item tied to a work-requirement member-communications procurement has been published.

Latest detail

As of 2026-06-03 Maryland is in an early administrative-preparation phase, not active procurement, for the H.R.1/OBBBA community-engagement (work) requirement, which it must implement no later than Jan 1, 2027 (state plan amendment due March 2027); CMS issued its interim final rule (CMS-2454-IFC) on June 1, 2026, and federally mandated member outreach must occur by Aug 31, 2026. MDH, the Maryland Health Care Commission (MHCC), and the Department of Human Services are coordinating to prevent paperwork-driven coverage loss among the ~300,000 affected adults (ages 19-64), and MDH reported it is racing to put agreements and Requests for Applications in place to obligate dollars by the end of October 2026. Funding to date is administrative (~$13M state GF + ~$2M MDH staffing) rather than a published communications/advertising or eligibility-system solicitation. No RFP/RFI/IFB for work-requirement member communications, outreach, or community-engagement eligibility-system implementation was found on eMMA, MDH, or the Maryland HBE solicitations page; Maryland is not yet listed among early-implementer states in the KFF 1115 tracker.

Medicaid expansion status	Expanded
Implementation status	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.
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 Maryland?

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 Maryland members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in Maryland?

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 Maryland 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 Maryland publishes guidance. State-specific rules are evolving. Not legal or eligibility advice.