State tracker

South Carolina — Medicaid Coverage Retention

Largely N/A Last updated 2026-06-03 · confidence: high

South Carolina 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. Note: SCDHHS has adjacent, mostly SOLE-SOURCE procurement activity that could absorb work-requirement member-facing work rather than a competitive RFP: (1) "North Highland Company LLC" sole source posted ~09/23/2025 for outbound calling to Medicaid beneficiaries; (2) "Blue Cross Blue Shield of SC" sole source posted ~05/07/2026 for External Eligibility Communication (EEC) services to Medicaid applicants; (3) "Eligibility and Enrollment System Compliance and Integration Enhancement (E&E SCIE) Project" sole source posted ~04/02/2026 (eligibility-system implementation/enhancement). None of these is identifiably scoped to H.R.1/community-engagement work-requirement communications, so they should not be treated as a confirmed work-requirement comms RFP.

Procurement portal: South Carolina Business Opportunities (SCBO, scbo.sc.gov) and the state eProcurement system SCEIS (apps.sceis.sc.gov / procurement.sc.gov). SCDHHS posts solicitations/contracts via its Contract Library (scdhhs.gov/resources/contract-library); aggregator mirror at southcarolinabids.com. Procurement questions: SCDHHS procurement office. · Implementation funding: Pending. No state implementation funding figure or contract value for work-requirement communications identified. SC's work-requirement vehicle is the "Palmetto Pathways to Independence" 1115 waiver (resubmitted 06/23/2025), which would extend Medicaid to ~11,400 parents at 67-100% FPL with an 80 hr/month community-engagement condition; no appropriation tied specifically to an outreach/comms procurement was located.

Latest detail

South Carolina is a Medicaid NON-expansion state, so the federal H.R.1/OBBBA community-engagement mandate (effective Jan 1, 2027, targeting the expansion population) has limited direct application; SC's work-requirement effort instead runs through its own Section 1115 "Palmetto Pathways to Independence" demonstration. Gov. Henry McMaster requested reinstatement in Jan 2025; SCDHHS ran a 30-day state comment period (Apr 30-May 31, 2025) and submitted the waiver to CMS on June 23, 2025, with a federal comment period July 10-Aug 9, 2025; the waiver was still pending CMS approval as of this research and would impose an 80 hr/month requirement on the new PCR coverage group (~11,400 parents, 67-100% FPL). No competitive RFP for work-requirement member communications/outreach was found; relevant outreach and eligibility-system work appears to be moving through SOLE-SOURCE awards (North Highland outbound calling, BCBS-SC eligibility communication, E&E SCIE system enhancement) rather than open solicitation. The KFF 1115 work-requirements tracker did not list SC among states with approved/implementing work-requirement waivers as of this check.

Medicaid expansion status	Non-expansion
Implementation status	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)
Who may be affected	Largely N/A — non-expansion
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 South Carolina?

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 South Carolina members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in South Carolina?

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