medfrail.com
OBBBA takes effect · January 1, 2027

Keep your Medicaid patients enrolled.

Up to 10.1 million fewer people could be on Medicaid expansion coverage in 2028 under OBBBA work requirements and six-month renewals, in the Urban Institute’s low-mitigation projection. A meaningful share of them may qualify for a medical-frailty or caregiving-role exemption, but only if the documentation exists when the state checks. We are building the workflow that produces it: an AI draft, then a physician who signs it or declines it with the reason in writing. Planned, not open.

Today: the exposure estimator below, and a dated record families build on their own device. Review is planned, not open; nothing is priced.
Physician of record: Our medical director · licensed in all 50 states and DC · each case checked against the member’s state before review.
Projected impact · CBPP + CMS data
10M
Americans expected to lose Medicaid coverage under OBBBA work requirements — the largest single reduction in a generation.
Share of affected
likely to qualify for exemption
~40–55%
medical · caregiving · disability · modeled from KFF/Urban, not our data → source
Window to prepare
before first eligibility redetermination
~4 months
as of September 2026 → start now
Instant estimate · runs in your browser, sends nothing

Size the exposure before you send us anything.

Two inputs. Every number below is a model with its source named; replace the defaults with your own and the arithmetic updates. When you want the real cohort, the ROI report below uses your de-identified panel.

Modeled outputs · not measurements
—
members at risk of missing 80 hrs/month · 19.8%, Shafer et al., JAMA Health Forum 2026 →
—
of those, plausibly exemption-eligible (medical, caregiving, disability) · 40–55%, modeled from KFF/Urban enrollee surveys, not your data →
—
members kept covered per year by documenting the eligible share at your capture rate · this is the exposure the attestation program would address →

The model assumes every at-risk member who is not documented loses coverage, which overstates loss (some will comply or self-attest) and ignores members who lose coverage for non-hour reasons, which understates it. It is for sizing a conversation, not a budget line. Your ROI report replaces these assumptions with your panel.

The regulatory timeline

What's coming, and when it hits revenue.

OBBBA adds work requirements for able-bodied adult Medicaid enrollees. States must verify compliance. Enrollees who fail verification lose coverage. For health systems, disenrollment is revenue lost and uncompensated care incurred. The exemption process is the relief valve — if you file.

What your peers are already doing

One health system put its exposure on the record.

Guthrie — a nonprofit system across rural Pennsylvania and New York — told Spotlight PA how much net revenue it stands to lose from the federal Medicaid changes. About 70% of its patients carry government-funded insurance; 16% are on Medicaid. So it did something most systems have not done yet: it started treating enrollment retention as an operating function instead of a policy problem.

70%
patients on government-funded insurance · one system

Not a national projection. One mid-size rural nonprofit put its own net revenue at risk on the record, through its chief operating officer. Run the same arithmetic against your Medicaid mix before your budget cycle closes.

Read the Spotlight PA report →
310K
projected to lose coverage · PA alone

Out of 2.8 million Pennsylvanians on Medicaid — 22% of the state. State officials also anticipate a federal funding loss over the ten years beginning 2028. Every state has a version of this number.

PA DHS data reports →
80 hrs
met by volunteering · their answer

Guthrie expanded its volunteer program so patients can meet the monthly requirement on campus — greeting visitors, the gift shop, events, deliveries — and is calling Medicaid recipients directly to walk them through the new rules. Pennsylvania’s human services secretary called the system a trusted resource for helping people meet the requirement and stay covered.

See their program →
The half that is still missing

A volunteer program serves the patients who can do 80 hours. It cannot reach the ones who can't.

This is the right instinct and the right economics — a covered patient is a reimbursed patient, so retention belongs in revenue cycle. But it only closes one of the two doors. Community engagement works for the patient whose barrier is a scheduling gap. It does nothing for the patient whose barrier is clinical: the COPD exacerbation, the chemotherapy calendar, the psychiatric admission, the dementia caregiving load at home. Asking that patient to volunteer 80 hours is asking them to do the thing their condition prevents.

Peer-reviewed data published in JAMA Health Forum in August 2026 sizes that group: across all 40 expansion states, 19.8% of eligible adults are at risk of missing the hours — and the study's lead author flags the specific population caught in between, those with “substantial health concerns that may not rise to the level of a documentable disability.” Too sick to hold predictable hours, not disabled enough for an automatic pass. For a health system, that is a named, findable cohort sitting inside your own EHR.

Those patients need the other door: a physician-signed frailty attestation filed against the federal “significantly impairs” standard, where the state accepts it (each state decides which clinicians’ documentation counts, and many look to the treating provider). Same retention goal, same revenue logic, different instrument — and it is the one your organization already has the clinical evidence to produce. A complete Medicaid retention program runs both. Guthrie has built one. We are planning the other.

Size the exemption-eligible cohort in your panel →
Sources: Marley Parish, “Medicaid will likely shed patients under new rules. This health system is working to keep them covered,” Spotlight PA / ABC27, August 31, 2026 · Shafer PR et al., JAMA Health Forum, 2026. medfrail is not affiliated with Guthrie, Spotlight PA, or the Pennsylvania Department of Human Services; their program is cited as public reporting, not as an endorsement.
What medfrail does

Physician-reviewed documentation, when review opens.

Three steps, all planned. Find who may qualify, prepare an AI draft from the record, and have a physician review it and sign or decline with the gap named. Review window agreed at contract. A log of each step.

01 / IDENTIFY

Find who qualifies. →

You would send a de-identified patient list by a method agreed at contract; there is no upload portal. The planned match compares diagnosis codes, medications and caregiving flags to the federal exemption criteria and returns a candidate list with the criterion to check for each. The estimator below is what exists today.

02 / DRAFT

An AI draft, from the record. →

A draft is prepared in plain language from what the record shows, citing the supporting diagnoses and encounters and following your state's fields. It is a draft only. Nothing leaves the physician's queue unreviewed.

03 / ATTEST

Physician reviews and signs. →

Our medical director would read every draft and either sign it or send it back with the specific gap. The review window is agreed at contract, not assumed. Your compliance team gets a log: draft, edits, signature, date.

How a case would move

An AI draft, a physician, a log of each step.

The AI prepares a draft and never signs. A physician reads it and either signs it or declines it with the reason in writing. This is the plan; review is not open yet.

  1. Receive a de-identified patient panel (CSV or XLSX today; an API is scoped, not built), after a BAA is signed.
  2. Match each patient to the federal exemption criteria using diagnosis codes, medications and caregiving flags. Planned.
  3. Draft an attestation in your state’s fields, with citations to the record.
  4. Review by our medical director, who signs it or declines it, inside a window agreed at contract.
  5. Return the signed document to your team for filing. Direct filing in a state portal is planned where a state offers it; it is not built.
  6. Log each step: draft, edits, signature, date. Today that log would be kept by the operator by hand.
Exemption ROI Report

Get your Exemption ROI Report.

Send an anonymized panel summary (counts by ICD-10 group, age band, and caregiving flag — no PHI). Within two business days we return a confidential report with:

  • Count of patients at risk of OBBBA disenrollment
  • Estimated share that likely qualify for exemption (by category)
  • Projected revenue protected per 1,000 retained patients
  • State-specific filing deadlines and required fields
  • Implementation path and timeline

No commitment. No PHI required (de-identified counts only). Reviewed by our medical director.

Request the report.

We follow up within one business day to confirm file format and security requirements.

 

Compliance · what exists today, what is planned — stated plainly
HIPAA
BAA before any PHI · none exchanged yet
SOC 2
Not started
NIST 800-53
Target, not audited
FHIR R4
Planned · CSV today

Questions we get from revenue-cycle and compliance teams.

Is a physician attestation required to claim a medical-frailty exemption?

No federal rule requires one. The federal work-requirement rule lists the exemptions, and each state decides how it checks them: its own records first, then the documentation it accepts, which in many states can come from the treating provider. A physician-signed attestation is one way to document it, and it is planned here, not open. The open question for a health system is whether the documentation exists when a state checks, from 2028, at redetermination.

Who is the physician of record, and why does their signature matter?

Our physician of record is our medical director, a physician licensed in all 50 states and DC. Each case is checked against the member’s state before review, and nothing is charged where review isn’t open. Having one physician decide every case means a single, consistent standard of review, and one physician an auditor can interview.

How do you handle PHI and where does data live?

Plainly: we do not accept PHI today. The ROI report runs on de-identified panel counts. Before any PHI is exchanged, a BAA is signed and the intake path is one the reviewing physician controls. We do not currently operate a HIPAA-audited cloud environment, a FHIR ingestion service, or a SOC 2 program; those are scoped and will be described as built, not before. If your security team needs a data-flow diagram of what exists now, we will draw the honest one.

Can this integrate with our EHR?

Not yet. Today the input is a CSV/XLSX of a de-identified panel. EHR integration (FHIR R4 against Epic, Cerner, Athena, Meditech) is scoped and is not built. We will not describe it as available until it is running against a live system.

What happens if the AI draft is something our physician of record won't sign?

The draft goes back with the gap named in writing. Your team either provides more documentation or removes that patient from the cohort. Nothing is submitted without a physician signature.

How fast can we start?

No turnaround is promised. A first batch of attestations would be scoped with you after the BAA, and the binding constraint is the physician review window, which we would agree in writing rather than promise. We would rather tell you a true date than a fast one.

Is this the same medfrail.com consumer product?

Same physician of record, different buyer. The consumer product at medfrail.com gives individual families a dated record that stays on their device, and a physician-review list; nothing is charged there today. This enterprise product is for health systems and Medicaid plans and is not priced yet. Any attestation we issue will be physician-signed.

January 2027 is four months away.

Your Medicaid panel's first redetermination cycle is closer than your budget process thinks. The systems that identify, file, and protect ahead of the curve will keep their patients. The systems that don't will write uncompensated care into next year's variance report.

Get your Exemption ROI Report →