State tracker

Tennessee — Medicaid Coverage Retention

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

Tennessee 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. However, TennCare's posted procurement pipeline contains several eligibility-system/verification solicitations directly relevant to community-engagement implementation: (1) Tennessee Eligibility Platform / TEP, RFP 31865-00648, projected 2nd Quarter 2026 (operate/enhance eligibility determination, appeals, member correspondence, member/partner portals + mobile app); (2) Social Service Employment and Income Verification Services, RFP 31865-00667, projected 3rd Quarter 2026 (real-time API verification of income/employment to determine TennCare eligibility — the data-matching layer work requirements rely on); (3) TennCare Connect Contact Center Solution / TCCCS, 31865-00663, released ~Nov 26, 2025 (member services contact center for obtaining/maintaining coverage). None of these is branded as an H.R.1/work-requirement member-communications or advertising/outreach RFP.

Procurement portal: Tennessee Edison Supplier Portal (hub.edison.tn.gov) for state solicitations; TennCare posts pipeline at tn.gov/tenncare Upcoming Procurements; general RFPs via TN Central Procurement Office (CPO). SAM.gov/BidNet Direct also aggregate. Note: TennCare requires a Blackout Period Attestation. · Implementation funding: Pending — no Tennessee-specific work-requirement implementation funding figure (e.g., a state GF appropriation or the federal H.R.1 implementation grant split) was verified in public sources as of 2026-06-03. TEP and verification procurements are funded through existing TennCare operating/MMIS budgets.

Latest detail

Tennessee is a non-expansion state but is pursuing work/community-engagement requirements on two tracks: state law HB1551/SB1728 directs TennCare to seek a Section 1115 waiver amendment for "able-bodied working-age adult enrollees without dependent children under age 6," and the federal H.R.1/OBBBA mandate requires community-engagement (80 hrs/month) compliance no later than Dec 31, 2026 with CMS's implementing Interim Final Rule due ~June 6, 2026. TennCare's TennCare III demonstration is approved through Dec 31, 2030. Implementation activity is currently flowing through eligibility-system and data-verification procurements (TEP, Social Service Employment/Income Verification, TennCare Connect contact center) rather than a standalone member-communications/advertising RFP. As of 2026-06-03 no CMS approval of the TN work-requirement waiver amendment and no dedicated outreach/communications solicitation were verified.

Medicaid expansion status	Non-expansion
Implementation status	Pending state guidance — no expansion adult group subject to the requirement; federal default applies to expansion/qualifying-1115 states only
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 Tennessee?

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 Tennessee members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in Tennessee?

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