State tracker

North Dakota — Medicaid Coverage Retention

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

North Dakota 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: NDBuys (Ivalua platform) and SPO Online via ND OMB State Procurement Office (omb.nd.gov); ND HHS posts its own program solicitations at hhs.nd.gov/procurement. ND also lists on BidNet Direct. Federal solicitations would appear on SAM.gov. · Implementation funding: Pending. No ND-specific state appropriation or contract value identified for work-requirement comms/system work. At the federal level, H.R.1/OBBBA appropriated $200M to CMS in FY2026 plus $200M directed to states ($400M total nationwide) for community-engagement implementation; ND's share is not separately published. The $600M industry pledge (Medicaid technology vendors) is a national resource, not an ND contract.

Latest detail

North Dakota is a Medicaid expansion state and must implement H.R.1/OBBBA community-engagement (work) requirements for ACA expansion adults (19-64), with the federal effective deadline of January 1, 2027 and mandatory direct member outreach due no later than August 31, 2026. As of 2026-06-03, ND HHS has stood up consumer-facing messaging on its website directing members to the self-service portal (per Georgetown CCF's May 2026 outreach review), but no dedicated procurement for work-requirement member communications/outreach or for a community-engagement/eligibility-system build has been posted on the ND HHS procurement page or the NDBuys/SPO state portal. Current ND HHS solicitations are unrelated (behavioral health residential beds, CCWIS, cost-of-dispensing survey, fiscal agent services, level-of-care determinations). CMS/GSA are streamlining a GSA-Schedule procurement pathway so states like ND may modify existing eligibility-system vendor contracts rather than issue new standalone RFPs, which is consistent with the absence of an ND solicitation given the tight late-2026 system-readiness timeline.

Medicaid expansion status	Expanded
Implementation status	Pending state guidance — awaiting federal CMS specifics (expected 2026); not a 2026 early implementer
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 North Dakota?

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 North Dakota members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in North Dakota?

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