State tracker

Wisconsin Medicaid Work Requirement & Coverage Retention Tracker

Q: When do Wisconsin Medicaid work requirements start?

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

Q: 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.

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

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

Medicaid expansion status	Partial/Waiver — Wisconsin did NOT adopt the ACA Medicaid expansion to 138% FPL. Instead, under its BadgerCare Plus Section 1115 "childless adults" waiver (approved through Dec 31, 2029), it covers non-elderly adults without dependent children up to 100% FPL. Per H.R.1/OBBBA and KFF, enrollees in partial-expansion waiver programs (only Wisconsin and Georgia) ARE subject to the new federal community-engagement requirements even though the state is technically a non-expansion state.
Implementation status	Planning for Jan 1, 2027 effective date. Wisconsin DHS has publicly confirmed BadgerCare Plus work requirements take effect January 1, 2027; federal officials indicated they are unlikely to grant implementation extensions. Detailed operational rules pending state guidance.
Who may be affected	BadgerCare Plus members ages 19-64 in the childless-adults (partial-expansion waiver) group, at or below 100% FPL, unless exempt. DHS describes the subject group as "childless adults." State nuance: because WI covers only to 100% FPL (not 138%), the subject pool is narrower than a full-expansion state; parents/caretaker relatives and pregnant members are generally outside this waiver group.
Reporting frequency	Monthly — members must demonstrate 80 hours of work or another approved activity each month. Federal compliance verification occurs at application and at every-6-month renewal.
Reporting method	Pending state guidance. WI confirms members must "prove" 80 hrs/mo and that non-compliant members get a notice with 30 days to provide proof, but the specific channel (online ACCESS/ForwardHealth portal, phone, mail, or automated data-matching) is not yet published. WI operates the ACCESS (access.wi.gov) and ForwardHealth member portals, which are the likely vehicles but not yet confirmed for work-requirement reporting.
Renewal cadence	Every 6 months for the applicable expansion/waiver adults, per H.R.1.
Notice timing	DHS has stated it will send notices in fall 2026 to all childless adults who will be required to meet the requirement (ahead of the Jan 1, 2027 effective date). This aligns with the federal member-notice window of approximately June 30 - Aug 31, 2026 plus state follow-on notices. Non-compliance notices give members 30 days to cure before disenrollment.
Self-attestation allowed?	Pending state guidance. Public DHS messaging emphasizes members must "prove" their hours/activities, which suggests documentation rather than pure self-attestation, but WI has not formally published whether self-attestation of hours or exemptions will be accepted.
State system / vendor	Pending. WI eligibility is determined in the CARES system, which interfaces with the interChange MMIS; member-facing tools are ACCESS (access.wi.gov) and the ForwardHealth Portal. The specific systems-integration vendor configuring the work-requirement module has not been verified in public sources.
Major Medicaid MCOs	Most BadgerCare Plus members are enrolled in managed care HMOs. Major BadgerCare Plus MCOs/HMOs include: Children's Community Health Plan (Chorus Community Health Plans), Dean Health Plan, Group Health Cooperative (GHC), Molina Healthcare of Wisconsin, MHS Health Wisconsin (Centene), Security Health Plan, Quartz, Anthem Blue Cross Blue Shield / Anthem BCBS WI, Network Health, (roster varies by geographic service area; verify current contracted HMOs on ForwardHealth)
Languages likely needed	Spanish, Hmong, Somali, Arabic, Chinese (Mandarin/Cantonese)

Key exemption categories to monitor

Parent/caretaker of a dependent child (federal framework — final age threshold set by CMS rule; broadly children under 14)
Pregnant and postpartum individuals
Individuals who are disabled / medically frail
American Indian / Alaska Native (and other Indian Health Service-eligible)
Individuals already meeting SNAP/TANF work requirements
Individuals compliant via 80 hrs/mo work, education (at least half-time), job training, or community service/volunteering, or qualifying income
Note: these are federal-framework categories; final definitions set by CMS interim final rule (CMS-2454-IFC) plus WI implementation

Short-term hardship exemptions to track

Pending state guidance. The federal framework provides for short-term exemptions (e.g., hospitalization/SNF admission, medical travel, disaster-declared counties, high-unemployment counties, recently incarcerated). WI has publicly confirmed only one specific exemption to date: individuals who are incarcerated or released from incarceration within the last 90 days. Adoption of the full menu of optional/short-term hardship exemptions is not yet detailed by DHS.

Member communication risk

Elevated. The monthly 80-hour proof requirement plus 6-month renewals and a 30-day cure window create meaningful procedural-disenrollment risk for the ~239,000 childless-adults waiver population, especially those with unstable work hours or limited digital access; reporting-channel details remain unpublished, increasing the chance of churn from administrative rather than substantive ineligibility.

What MCOs & state partners should do now

Identify and segment the BadgerCare Plus childless-adults (19-64, <=100% FPL) members in your panel now, flagging likely exemption categories (medically frail, AI/AN, recently incarcerated) to prepare proactive outreach lists
Stand up a member outreach campaign timed to the DHS fall-2026 notice wave to explain the 80-hr/mo requirement, the 30-day cure window, and how to report — in Spanish, Hmong, Somali, Arabic, and Chinese
Build workflows to help members document/report compliance and gather exemption proof once DHS publishes the reporting channel (likely ACCESS/ForwardHealth); pre-draft member materials
Coordinate with WI DHS on the still-pending implementation details (reporting method, self-attestation policy, full hardship-exemption menu) and feed member-impact data into the state's process
Implement a retention/redetermination support program for the every-6-month renewal cadence to minimize procedural disenrollment, including reminders and assisted reporting for high-risk members

Operating in Wisconsin?

Complete a Coverage Retention Readiness Audit before member notices begin — we build CMS-compliant, plain-language, multilingual outreach to keep eligible Wisconsin members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in Wisconsin?

BadgerCare Plus members ages 19-64 in the childless-adults (partial-expansion waiver) group, at or below 100% FPL, unless exempt. DHS describes the subject group as "childless adults." State nuance: because WI covers only to 100% FPL (not 138%), the subject pool is narrower than a full-expansion state; parents/caretaker relatives and pregnant members are generally outside this waiver group.

When do Wisconsin Medicaid work requirements start?

Federal enforcement begins January 1, 2027 (some states may implement earlier). Member notices are expected starting 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 Wisconsin publishes guidance. State-specific rules are evolving. Not legal or eligibility advice.