{
  "name": "medfrail Medicaid work-rule library",
  "version": "2026-10-20e",
  "note": "Deterministic rules for the Medicaid work requirement (H.R.1 / P.L. 119-21, CMS-2454-IFC). Every line names its source. A person's state Medicaid agency makes every decision; this file only says what the rule and the state have published. Fields a state has not published read 'not published'. Built to be read by people's own AI assistants and by medfrail.com/keep.",
  "federal": {
    "who_it_applies_to": "Adults 19 to 64 who are not pregnant, not entitled to or enrolled in Medicare, and are in the Medicaid adult (expansion) group or a section 1115 demonstration that gives adults minimum essential coverage.",
    "start": "No later than January 1, 2027; a state may start earlier.",
    "ways_to_meet_it_each_month": [
      "80 hours of work (paid, in-kind, or unpaid work such as an internship)",
      "80 hours of community service: unpaid work in a structured program run by a public agency or nonprofit that tracks dates and hours and names a contact",
      "80 hours in a work program",
      "Enrollment in school at least half-time",
      "Any combination of work, community service and a work program totaling 80 hours",
      "Monthly income of at least $580 (80 hours at the federal minimum wage of $7.25)"
    ],
    "not_required_examples": [
      "Parents, guardians, caretaker relatives or family caregivers of a child 13 or younger",
      "Parents, guardians, caretaker relatives or family caregivers of a person of any age with a disability",
      "People who are medically frail: blind; disabled; a substance use disorder; a disabling mental disorder; a physical, intellectual or developmental disability that significantly impairs daily activities; or a serious or complex medical condition",
      "People in a drug or alcohol treatment program",
      "People meeting SNAP or TANF work rules",
      "American Indians and Alaska Natives",
      "Veterans with a total disability rating",
      "Former foster youth under 26",
      "People recently released from incarceration",
      "Pregnant or postpartum people, and anyone enrolled in Medicare (the rule does not apply)"
    ],
    "if_the_state_cannot_verify": "The state must give at least 30 days to show you meet the rule or are exempt. If coverage ends for this reason, you may reapply.",
    "renewals": "Expansion adults renew every six months.",
    "self_attestation_2027": "During calendar 2027 a state may choose to accept a person's own statement for some items (for example medical frailty, volunteer hours, student status). Each state decides.",
    "medical_frailty_guidance": "CMS's optional September 2026 model sorts frailty into three tiers: a diagnosis alone (Tier 1), a diagnosis plus other data such as pharmacy or equipment (Tier 2), and individualized review that may ask for documents (Tier 3).",
    "sources": [
      {
        "title": "CMS fact sheet, CMS-2454-IFC",
        "url": "https://www.cms.gov/newsroom/fact-sheets/medicaid-community-engagement-requirement-certain-individuals-interim-final-rule-comment-period-cms"
      },
      {
        "title": "Federal Register, CMS-2454-IFC (community service definition, section II.C.2)",
        "url": "https://www.federalregister.gov/documents/2026/06/03/2026-11094/medicaid-program-community-engagement-requirement-for-certain-individuals"
      },
      {
        "title": "SHVS summary of CMS's medical frailty tiers",
        "url": "https://shvs.org/resources/cms-releases-new-information-on-operationalizing-medicaid-work-reporting-requirements-medical-frailty-exclusion/"
      },
      {
        "title": "Colorado HCPF H.R.1 FAQ (exclusion list wording)",
        "url": "https://hcpf.colorado.gov/hr1-faqs"
      },
      {
        "title": "KFF, work requirement provisions (no premium tax credits after a work-rule denial)",
        "url": "https://www.kff.org/medicaid/a-closer-look-at-the-work-requirement-provisions-in-the-2025-federal-budget-reconciliation-law/"
      },
      {
        "title": "42 CFR part 431 subpart E, fair hearings",
        "url": "https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E"
      },
      {
        "title": "Justice in Aging, H.R.1 retroactive eligibility",
        "url": "https://justiceinaging.org/hr1-reduces-medicaid-retroactive-eligibility-starting-in-2027/"
      },
      {
        "title": "HRSA, find a health center",
        "url": "https://findahealthcenter.hrsa.gov/"
      }
    ],
    "if_coverage_ends": [
      "Losing or being denied Medicaid over the work rule also makes a person ineligible for Marketplace premium tax credits (KFF).",
      "Ask for a fair hearing; if requested before the date of action, coverage generally continues pending the decision (42 CFR 431 subpart E).",
      "Reapply when the rule is met or an exemption applies; the state checks the look-back month(s) before the application.",
      "From 2027, retroactive coverage for expansion adults is one month before the application month (H.R.1 section 71112).",
      "Community health centers serve people regardless of insurance, with sliding-scale fees (HRSA)."
    ]
  },
  "states": {
    "AK": {
      "name": "Alaska",
      "start_date": "2027-01-01 as currently set. Alaska has asked CMS for more time to implement (a good-faith exemption request); if approved the rules start later and DPA will announce the new date. Approval status not published as of 2026-10-20.",
      "self_attestation_2027": "Case-by-case. DPA uses available data first and says it will tell the member whether they can provide information themselves or whether documents are required. Explicitly accepts self-attestation of pregnancy/postpartum, and of caregiving or other exclusion status when records can't establish it. Rules for frailty, volunteer hours, income/hours and student status specifically: not published as of 2026-10-20.",
      "lookback_months": "not published as of 2026-10-20 (application or renewal). FAQ says WCER is reviewed again at the next renewal; members need not report WCER activities monthly.",
      "renewal_frequency": "Every 6 months for many expansion adults starting 2027-01-01; Alaska moves people to 6-month renewals using their existing renewal schedule where possible.",
      "frailty_method": "Ex parte first: DPA will use Medicaid claims, diagnoses, services, treatments, functional information and other administrative data, then request only the information needed. No condition list URL and no reference to the CMS 3-tier model published.",
      "member_page_url": "https://health.alaska.gov/en/education/medicaid-work-and-community-engagement-requirements/",
      "sources": [
        "https://health.alaska.gov/en/education/hr-1-ak-impacts/hr-1-medicaid-frequently-asked-questions/"
      ],
      "quotes": [
        {
          "quote": "The State of Alaska has asked the federal government for more time to implement the new work and community engagement rules.",
          "url": "https://health.alaska.gov/en/education/hr-1-ak-impacts/hr-1-medicaid-frequently-asked-questions/"
        },
        {
          "quote": "Sometimes. Whether self-attestation can be accepted depends on the information the Division of Public Assistance (DPA) needs to verify.",
          "url": "https://health.alaska.gov/en/education/hr-1-ak-impacts/hr-1-medicaid-frequently-asked-questions/"
        },
        {
          "quote": "The Division of Public Assistance (DPA) will first use reliable information already available, including Medicaid claims, diagnoses, services, treatments, functional information, and other administrative information.",
          "url": "https://health.alaska.gov/en/education/hr-1-ak-impacts/hr-1-medicaid-frequently-asked-questions/"
        }
      ],
      "unknowns": [
        "how many months it looks back (application and renewal)",
        "whether CMS approved the good-faith exemption and the resulting start date",
        "self-attestation rules for frailty/volunteer/income-hours/student specifically",
        "condition list or CMS tier adoption"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "AL": {
      "name": "Alabama",
      "not_expansion": "Alabama did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in Alabama (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    },
    "AR": {
      "name": "Arkansas",
      "start_date": "Soft launch 2026-07-01 with no penalties; enforcement 2027-01-01. From 2027-01-01, members who don't meet the requirement get 30 days to show compliance before benefits are suspended (per the 2026-02-23 DHS news release).",
      "self_attestation_2027": "not published as of 2026-10-20. DHS first checks existing data (wage records, SNAP data) and confirms hours automatically where it can; otherwise members report online, by phone or in person and must 'send proof' within 30 days.",
      "lookback_months": "Application: 1 month (the month before applying). Renewal: at least 1 month in every 6 months.",
      "renewal_frequency": "Effectively 6 months: current enrollees must show compliance at least one month every six months.",
      "frailty_method": "Called 'special medical needs'. The FAQ gives qualifying examples (cancer, end-stage kidney disease, HIV/AIDS, major heart disease, MS, Parkinson's) and conditions that generally do not qualify unless very severe (diabetes, asthma, hypertension, ADHD, obesity, anemia). Being on the medically frail benefit plan does not automatically qualify. SSDI recipients are identified automatically. No reference to the CMS 3-tier model.",
      "member_page_url": "https://humanservices.arkansas.gov/divisions-shared-services/medical-services/healthcare-programs/arhome/arhome-community-engagement-requirement/",
      "sources": [
        "https://humanservices.arkansas.gov/divisions-shared-services/medical-services/healthcare-programs/arhome/arhome-community-engagement-requirement/arhome-faq/",
        "https://humanservices.arkansas.gov/divisions-shared-services/medical-services/healthcare-programs/arhome/arhome-community-engagement-requirement/arhome-outreach-toolkit/"
      ],
      "quotes": [
        {
          "quote": "DHS launched a soft implementation of the requirement on July 1, 2026, but no penalties will be in effect until January 1, 2027.",
          "url": "https://humanservices.arkansas.gov/divisions-shared-services/medical-services/healthcare-programs/arhome/arhome-community-engagement-requirement/"
        },
        {
          "quote": "Current enrollees: You must show you met the requirement at least one month every six months, though DHS will first try to confirm your status using information we already have.",
          "url": "https://humanservices.arkansas.gov/divisions-shared-services/medical-services/healthcare-programs/arhome/arhome-community-engagement-requirement/arhome-faq/"
        },
        {
          "quote": "DHS will identify SSDI recipients automatically.",
          "url": "https://humanservices.arkansas.gov/divisions-shared-services/medical-services/healthcare-programs/arhome/arhome-community-engagement-requirement/arhome-faq/"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "whether any Arkansas state law limits self-attestation (not checked)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "AZ": {
      "name": "Arizona",
      "start_date": "2027-01-01 (KeepMyAHCCCS.com). The AHCCCS H.R.1 FAQ says states must begin implementing by 2026-12-31. No soft launch or no-disenrollment period published.",
      "self_attestation_2027": "not published as of 2026-10-20",
      "lookback_months": "Application: 1 month (the month before applying). Renewal: AHCCCS checks income and activities in the months since the last renewal; how many of those months must be met is not stated.",
      "renewal_frequency": "Every 6 months for most adult-group members starting 2027-01-01.",
      "frailty_method": "not published as of 2026-10-20. The FAQ lists medically frail (serious physical, mental health, or substance use conditions) as an exemption and says AHCCCS is still developing how to claim an exemption.",
      "member_page_url": "https://keepmyahcccs.com/",
      "sources": [
        "https://keepmyahcccs.com/partners/",
        "https://www.azahcccs.gov/AHCCCS/Initiatives/HR1/"
      ],
      "quotes": [
        {
          "quote": "If you are applying for AHCCCS for the first time, AHCCCS will look only at the month before you apply.",
          "url": "https://keepmyahcccs.com/"
        },
        {
          "quote": "If you are renewing your AHCCCS coverage, AHCCCS will see if you met the requirements by checking your income and activities in the months since your last renewal.",
          "url": "https://keepmyahcccs.com/"
        },
        {
          "quote": "Starting January 1, 2027, most individuals in the adult group will renew their AHCCCS coverage every 6 months.",
          "url": "https://keepmyahcccs.com/"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "how it checks medical frailty",
        "number of months that must be met at renewal",
        "how the separate state-law 'AHCCCS Works' 1115 amendment (ages 19-55, monthly reporting by the 10th, per older AHCCCS waiver documents and a DES Facebook post) interacts with the H.R.1 requirement"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "CA": {
      "name": "California",
      "start_date": "2027-01-01. No soft launch published. Equifax data for work-requirement verification starts January 2027; Truv phase 1 (work-requirement income/hours) starts January 2027.",
      "self_attestation_2027": "not published as of 2026-10-20 for the work requirement. ACWDL 26-18 (2026-09-21) covers income verification through reasonable compatibility of self-attested income with Equifax/Truv, and defers full work-requirement rules to a future ACWDL. In its student example the applicant 'submits verification' of full-time enrollment.",
      "lookback_months": "Application: 1 month (the month before applying; ACWDL 26-18 example uses December as the look-back month for a January application). Renewal: at least 1 month since the last renewal (DHCS implementation webinar, 2026-02-05).",
      "renewal_frequency": "Every 6 months for the MAGI New Adult Group (ACWDL 26-14 / DHCS webinar).",
      "frailty_method": "Ex parte using data (DHCS webinar 2026-02-05): all claims and encounters (PACES, CA-MMIS, Medi-Cal Rx), Short-Doyle Medi-Cal, and enrollment in programs such as HCBS waivers, CBAS, CCS, PACE, Enhanced Care Management and Community Supports where those align with frailty criteria. DHCS is evaluating ICD-10/CPT codes and MCP care-management data. No published condition list and no stated CMS 3-tier adoption.",
      "member_page_url": "https://www.dhcs.ca.gov/medi-cal/updates/medi-cal-changes/#work-rules",
      "sources": [
        "https://www.dhcs.ca.gov/tracking-federal-impact-medi-cal-eligibility/",
        "https://www.dhcs.ca.gov/file/acwdl-26-18-pdf/",
        "https://www.dhcs.ca.gov/medi-cal/updates/medi-cal-changes/"
      ],
      "quotes": [
        {
          "quote": "Starting January 1, 2027, some adults will need to work, volunteer, go to school, or be in training to get to keep their Medi-Cal.",
          "url": "https://www.dhcs.ca.gov/medi-cal/updates/medi-cal-changes/"
        },
        {
          "quote": "Since the income was e-verified, the applicant's WCER compliance for the look back month (December) is also met.",
          "url": "https://www.dhcs.ca.gov/file/acwdl-26-18-pdf/"
        },
        {
          "quote": "Comprehensive guidance specific to the Medi-Cal WCER for the New Adult group will be released in a future letter.",
          "url": "https://www.dhcs.ca.gov/file/acwdl-26-18-pdf/"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027 for the work requirement (pending a future WCER ACWDL)",
        "final medical frailty code list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "CO": {
      "name": "Colorado",
      "start_date": "January 2027: new applications filed on or after 2027-01-01, and current members with a renewal due in or after January 2027. No soft launch published.",
      "self_attestation_2027": "Yes, broadly. In 2027 applicants and members may self-attest to earnings, hours worked, or both. Self-attestation may also be used for certain information on medical frailty, student status, volunteer work and work-program participation. Exclusions and exceptions use existing system data plus self-attestation in a three-step process.",
      "lookback_months": "Application: 1 calendar month (the month before applying). Renewal: at least 1 calendar month since the last renewal deadline. Colorado chose one month to reduce administrative burden.",
      "renewal_frequency": "Every 6 months for members subject to work requirements.",
      "frailty_method": "Existing system data plus self-attestation in a three-step process. No claims-code list or CMS 3-tier adoption published on the pages checked.",
      "member_page_url": "https://www.healthfirstcolorado.gov/changes-are-coming-to-health-first-colorado-colorados-medicaid-program/work-requirements/",
      "sources": [
        "https://hcpf.colorado.gov/hr1-faqs",
        "https://hcpf.colorado.gov/hr1-medicaid-work-requirements"
      ],
      "quotes": [
        {
          "quote": "In 2027, they will be able to self-attest to their earnings, hours worked, or both.",
          "url": "https://hcpf.colorado.gov/hr1-faqs"
        },
        {
          "quote": "Current members will need to show at renewal that they met the requirement in at least one calendar month since their last renewal deadline.",
          "url": "https://hcpf.colorado.gov/hr1-faqs"
        },
        {
          "quote": "In 2027, for members and applicants subject to work requirements, the state will use existing system data and self-attestation to determine if an individual qualifies for an exclusion or exception based on a three-step process.",
          "url": "https://hcpf.colorado.gov/hr1-medicaid-work-requirements"
        }
      ],
      "unknowns": [
        "details of the three-step frailty process and any condition list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "CT": {
      "name": "Connecticut",
      "start_date": "2027-01-01 for HUSKY D adults. No soft launch published.",
      "self_attestation_2027": "not published as of 2026-10-20. The member page tells HUSKY members to report the change and provide documents to Access Health CT.",
      "lookback_months": "not published as of 2026-10-20",
      "renewal_frequency": "Every 6 months for HUSKY D (DSS knowledge-base article, last updated 2025-07-03).",
      "frailty_method": "not published as of 2026-10-20. 'Is medically frail' appears in the not-affected list, and a HUSKY D pre-screener is available.",
      "member_page_url": "https://portal.ct.gov/dss/all-programs/dss-benefits-and-hr1/hr1-for-members/hr1-work-rule-changes",
      "sources": [
        "https://portal.ct.gov/husky/huskydprescreener",
        "https://portal.ct.gov/dss/knowledge-base/articles/general-information/federal-updates-hr1"
      ],
      "quotes": [
        {
          "quote": "Starting on 1/1/2027, people on HUSKY D must follow new work rules.",
          "url": "https://portal.ct.gov/dss/all-programs/dss-benefits-and-hr1/hr1-for-members/hr1-work-rule-changes"
        },
        {
          "quote": "For HUSKY Health: Report the change and provide documents directly to Access Health CT.",
          "url": "https://portal.ct.gov/dss/all-programs/dss-benefits-and-hr1/hr1-for-members/hr1-work-rule-changes"
        },
        {
          "quote": "HUSKY D recipients will need to complete a renewal every 6 months instead of every 12 months",
          "url": "https://portal.ct.gov/dss/knowledge-base/articles/general-information/federal-updates-hr1"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "how many months it looks back",
        "how it checks medical frailty",
        "the not-affected list says 'Is a parent or caregiver relative' without the federal child-age-13 limit; how CT applies this is not explained"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "DC": {
      "name": "District of Columbia",
      "start_date": "2027-01-01 for applicants. For current enrollees, the first renewal cohort is March 2027 certification dates.",
      "self_attestation_2027": "not published as of 2026-10-20",
      "lookback_months": "Application: 1 month (the month prior to the month of application). Renewal: 1 month in the past certification period.",
      "renewal_frequency": "Every 6 months for most adults 19-64 without children, starting 2027-01-01.",
      "frailty_method": "not published as of 2026-10-20. The DHCF partner deck only restates CMS direction to use reliable available data such as Medicaid claims and encounter data.",
      "member_page_url": "https://dhcf.dc.gov/page/federal-changes-medicaid",
      "sources": [
        "https://dhcf.dc.gov/sites/default/files/dc/sites/dhcf/Biweekly%20DHCF%20Eligibility%20Meeting%20081226.pdf"
      ],
      "quotes": [
        {
          "quote": "First renewal cohort subject to Medicaid work requirements will be those with March 2027 certification dates.",
          "url": "https://dhcf.dc.gov/sites/default/files/dc/sites/dhcf/Biweekly%20DHCF%20Eligibility%20Meeting%20081226.pdf"
        },
        {
          "quote": "At application, an individual must have met one or a combination of the requirements below one month prior to their application.",
          "url": "https://dhcf.dc.gov/sites/default/files/dc/sites/dhcf/Biweekly%20DHCF%20Eligibility%20Meeting%20081226.pdf"
        },
        {
          "quote": "Most adults ages 19 to 64 without children must renew their Medicaid every 6 months instead of once a year.",
          "url": "https://dhcf.dc.gov/page/federal-changes-medicaid"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "how it checks medical frailty",
        "the member page says more work-requirement information 'is coming'"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "DE": {
      "name": "Delaware",
      "start_date": "2027-01-01. No soft launch published.",
      "self_attestation_2027": "not published as of 2026-10-20. At renewal the case manager checks existing information and may ask for pay stubs, school papers, or proof of volunteer or work-program hours.",
      "lookback_months": "Application: at least 1 month leading up to the application. Renewal: not published as of 2026-10-20.",
      "renewal_frequency": "Every 6 months for the Adult Expansion Group starting 2027-01-01.",
      "frailty_method": "not published as of 2026-10-20. Exemptions listed as 'serious health needs' (blindness or disability, SUD, mental health condition, serious medical condition, other physical or developmental disability).",
      "member_page_url": "https://dhss.delaware.gov/dmma/home/medicaid-engage/",
      "sources": [
        "https://dhss.delaware.gov/dmma/home/medicaid-engage/"
      ],
      "quotes": [
        {
          "quote": "If you are applying for Medicaid for the first time, you must be able to show that you met work requirements for at least one month leading up to your application.",
          "url": "https://dhss.delaware.gov/dmma/home/medicaid-engage/"
        },
        {
          "quote": "If we need more information, we will ask you for things like pay stubs, school papers, or proof of your volunteer or work program hours.",
          "url": "https://dhss.delaware.gov/dmma/home/medicaid-engage/"
        },
        {
          "quote": "You will need to renew your Medicaid coverage every six months instead of every 12 months.",
          "url": "https://dhss.delaware.gov/dmma/home/medicaid-engage/"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "lookback at renewal",
        "how it checks medical frailty",
        "separate partner page"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "FL": {
      "name": "Florida",
      "not_expansion": "Florida did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in Florida (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    },
    "GA": {
      "name": "Georgia",
      "start_date": "2027-01-01 for H.R.1 rules in Pathways. 'Current Pathways members will not be affected until renewal in 2027.' Pathways already had a work requirement before H.R.1.",
      "self_attestation_2027": "not published as of 2026-10-20. The page instead tells members and applicants to keep proof (pay stubs, school records, volunteer logs) because DFCS 'may ask for proof'.",
      "lookback_months": "Application: the 1 month before the application month (applicants may request 2 months of prior coverage but must show the prior month). Renewal: per the agency, compliance continues monthly during enrollment and is checked at annual renewal; no multi-month renewal lookback is stated.",
      "renewal_frequency": "The agency states an 'annual renewal'. The 6-month figure is not stated for Pathways.",
      "frailty_method": "DCH published Attachment A (conditions and diagnoses that satisfy frailty): https://dch.georgia.gov/document/document/medical-frailty-list-schedule-r1 . It also published Attachment B (conditions that may qualify with certain diagnoses or documentation; policy forthcoming): https://dch.georgia.gov/document/document/medical-frailty-list-schedule-b0 . CMS tiers are not mentioned.",
      "subject_note": "SUBJECT. Georgia did not expand Medicaid. Pathways to Coverage is the section 1115 adult-coverage demonstration (19-64, income at or below 100% FPL), and DCH applies the H.R.1 community engagement rules to it from 2027-01-01. Traditional (non-Pathways) Medicaid is not affected.",
      "member_page_url": "https://pathways.georgia.gov/hr-1-changes-pathways",
      "sources": [
        "https://pathways.georgia.gov/qualifying-activities"
      ],
      "quotes": [
        {
          "quote": "Current Pathways members will not be affected until renewal in 2027.",
          "url": "https://pathways.georgia.gov/hr-1-changes-pathways"
        },
        {
          "quote": "To meet the eligibility requirements, individuals must complete community engagement for at least one month immediately before the month of application, continuing monthly during Pathways enrollment, and at annual renewal.",
          "url": "https://pathways.georgia.gov/hr-1-changes-pathways"
        },
        {
          "quote": "Attachment A contains the list of health conditions and diagnoses that satisfy the criteria for medical frailty.",
          "url": "https://pathways.georgia.gov/hr-1-changes-pathways"
        }
      ],
      "unknowns": [
        "2027 self-attestation policy",
        "Whether monthly reporting continues in the same form",
        "How the Attachment B process works",
        "CMS tier adoption"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "HI": {
      "name": "Hawaii",
      "start_date": "2027-01-01. For current members the requirements apply starting with their 2027 renewal.",
      "self_attestation_2027": "not published as of 2026-10-20. The member page advises saving pay stubs, proof of income, and official proof of school enrollment.",
      "lookback_months": "Application: not published as of 2026-10-20. Renewal: 1 month out of the 6 months before renewal. Seasonal workers may average income over 6 months.",
      "renewal_frequency": "Every 6 months for adults 19-64 who are not blind, disabled or pregnant.",
      "frailty_method": "not published as of 2026-10-20",
      "member_page_url": "https://medquest.hawaii.gov/hr1",
      "sources": [
        "https://medquest.hawaii.gov/en/members-applicants/already-covered/Stay_Well_Stay_Covered_Toolkit",
        "https://medquest.hawaii.gov/api/media/file/H.R.1%20WR%20One-Pager_Flyer%2020260728_V6_FINAL.pdf",
        "https://medquest.hawaii.gov/en/resources/community-partners"
      ],
      "quotes": [
        {
          "quote": "These requirements need to be met in one of the six months before your Med-QUEST renewal. These requirements do not apply until your 2027 renewal.",
          "url": "https://medquest.hawaii.gov/en/members-applicants/already-covered/Stay_Well_Stay_Covered_Toolkit"
        },
        {
          "quote": "Seasonal workers may use their average monthly income over six months to meet the requirement.",
          "url": "https://medquest.hawaii.gov/api/media/file/H.R.1%20WR%20One-Pager_Flyer%2020260728_V6_FINAL.pdf"
        }
      ],
      "unknowns": [
        "lookback at application",
        "whether your own word counts in 2027",
        "how it checks medical frailty"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "IA": {
      "name": "Iowa",
      "start_date": "Early start: 2026-12-01 for people who apply on or after that date. Current IHAWP members: renewal dates in February 2027 or later. An Oct 2026 town-hall deck says it applies to 'applications received January 1, 2027, and later', which conflicts with the Dec 1 date on the live page. No soft launch is published.",
      "self_attestation_2027": "Not published as of 2026-10-20. Iowa HHS says 'The state may require medical documentation for the medically frail exclusion.' Its reporting-process sheet asks members to keep and submit pay stubs, volunteer logs and school forms.",
      "lookback_months": "Application: 1 month, the month just before the application month. Renewal: any 2 months since the last determination or renewal.",
      "renewal_frequency": "6 months (Iowa HHS member town-hall presentation, 10.2026).",
      "frailty_method": "Not published beyond 'Iowa HHS will check records'. The state may require medical documentation. No condition list.",
      "member_page_url": "https://hhs.iowa.gov/medicaid/plans-programs/iowa-health-wellness-plan/ihawp-community-engagement-requirements",
      "sources": [
        "https://hhs.iowa.gov/media/19571/download?inline",
        "https://hhs.iowa.gov/media/19532/download"
      ],
      "quotes": [
        {
          "quote": "These requirements take effect December 1, 2026, for individuals who apply on or after that date.",
          "url": "https://hhs.iowa.gov/medicaid/plans-programs/iowa-health-wellness-plan/ihawp-community-engagement-requirements"
        },
        {
          "quote": "Members must meet the requirement for any two months during the review period since their last eligibility determination or renewal.",
          "url": "https://hhs.iowa.gov/medicaid/plans-programs/iowa-health-wellness-plan/ihawp-community-engagement-requirements"
        },
        {
          "quote": "6-month renewals: Members enrolled in IHAWP will receive a 6-month renewal period.",
          "url": "https://hhs.iowa.gov/media/19532/download"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "frailty method (claims, condition list, CMS tiers)",
        "conflict between the Dec 1, 2026 applicant start and the town-hall deck's Jan 1, 2027"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "ID": {
      "name": "Idaho",
      "start_date": "DHW begins reviewing work requirements for participants whose coverage periods end on or after 2027-01-01. No soft launch published.",
      "self_attestation_2027": "not published as of 2026-10-20. Members are told to track hours and gather medical or legal documents to prove an exclusion or exemption. Whether Idaho state law (secondary source cites House Bill 913) restricts self-attestation: not established.",
      "lookback_months": "Application: 3 months (state choice; Idaho Capital Sun says it comes from state lawmakers). Renewal: at least 3 months of compliance within the current 6-month certification period.",
      "renewal_frequency": "Every 6 months (semi-annual re-evaluation).",
      "frailty_method": "Agency: not published as of 2026-10-20. The exclusion list includes disability affecting daily activities, serious or complex conditions needing regular care, SUD, disabling mental health conditions, and blindness. Not from the agency, per Idaho Capital Sun, 2026-09-01: the state is working with a contractor to pull medical claims data automatically to verify medical frailty.",
      "member_page_url": "https://healthandwelfare.idaho.gov/services-programs/medicaid-health/medicaid-expansion",
      "sources": [
        "https://healthandwelfare.idaho.gov/news/idaho-department-health-and-welfare-announces-work-requirements-medicaid-expansion-recipients"
      ],
      "quotes": [
        {
          "quote": "New and existing applicants must demonstrate three months of qualifying activity (work, volunteering, or education) or must meet an exclusion or qualify for an exemption",
          "url": "https://healthandwelfare.idaho.gov/services-programs/medicaid-health/medicaid-expansion"
        },
        {
          "quote": "Participants must stay enrolled and either meet an excluding circumstance, qualify for an exemption, or demonstrate at least three months of qualifying-activity compliance during their current six-month certification period",
          "url": "https://healthandwelfare.idaho.gov/services-programs/medicaid-health/medicaid-expansion"
        },
        {
          "quote": "DHW will begin reviewing work requirements for participants whose coverage periods end on or after January 1, 2027.",
          "url": "https://healthandwelfare.idaho.gov/services-programs/medicaid-health/medicaid-expansion"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "how it checks medical frailty on an agency page",
        "exact state-law provisions (bill number from a secondary source only)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "IL": {
      "name": "Illinois",
      "start_date": "Applications submitted after 5:00 p.m. on 2026-12-31. For existing ACA Adults, redeterminations due March 2027 onward, on a rolling basis.",
      "self_attestation_2027": "Exemptions: yes. In 2027 HFS will accept self-attestation of exemptions it cannot verify through its data. Self-attestation of hours, income, volunteer work or student status: not published as of 2026-10-20.",
      "lookback_months": "Must meet or be exempt for 1 month during the eligibility period (the 6-month review period at renewal). Which month counts at application is not stated explicitly.",
      "renewal_frequency": "Every 6 months after the first 2027 redetermination.",
      "frailty_method": "Data match: application information, HFS claims records, and SNAP/TANF eligibility information, then self-attestation in 2027 if data can't verify. No condition list or CMS 3-tier adoption published.",
      "member_page_url": "https://hfs.illinois.gov/medicalclients/medicaidguide/changes.html",
      "sources": [
        "https://www.dhs.state.il.us/page.aspx?item=180030",
        "https://hfs.illinois.gov/info/fedresctr/faqshowwillfedchimpactmedicaid.html"
      ],
      "quotes": [
        {
          "quote": "In 2027, the state will accept “self-attestation” from customers of exemptions to work requirements if we are unable to verify the exemptions through our data sources.",
          "url": "https://hfs.illinois.gov/medicalclients/medicaidguide/changes.html"
        },
        {
          "quote": "HFS uses available data sources - such as application information, HFS claims records, and SNAP and TANF eligibility information - to verify mandatory exemptions and exclusions for the Medicaid work requirement.",
          "url": "https://www.dhs.state.il.us/page.aspx?item=180030"
        },
        {
          "quote": "In Illinois, you will only need to meet or be exempt from the work requirement for one month during your \"eligibility period\"-which means the time from when your Medicaid starts to when it is set to end or be renewed.",
          "url": "https://www.dhs.state.il.us/page.aspx?item=180030"
        }
      ],
      "unknowns": [
        "exact look-back month at application",
        "self-attestation for hours/income/volunteer/student"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "IN": {
      "name": "Indiana",
      "start_date": "2027-01-01 for new applicants and for redeterminations started on or after that date. A January 2027 applicant must meet the requirement in Oct, Nov and Dec 2026. No soft launch or no-disenrollment period is published. FSSA says over 58,000 HIP members are not currently in compliance (announcement dated 10/05/2026).",
      "self_attestation_2027": "Not published by FSSA. A news report, not the agency (Indiana Capital Chronicle, 2026-08-12), says state Senate Enrolled Act 1 (2026) bars self-attestation in the first year. FSSA's own FAQ says community service needs either its form or 'official documentation from the community agency'.",
      "lookback_months": "Application: 3 months, the three months before the application month. Renewal: 3 months before the renewal month, and the same 3 months before each quarterly work-requirement review.",
      "renewal_frequency": "Every 6 months, plus quarterly (every 3 months) compliance checks.",
      "frailty_method": "The state decides; clinicians may only recommend. FSSA says it is 'still working with' CMS on frailty criteria. No condition list and no claims method published.",
      "member_page_url": "https://www.in.gov/fssa/hip/hip-work-requirements/info-for-hip-members",
      "sources": [
        "https://www.in.gov/fssa/hip/hip-work-requirements/hwr-partner-toolkit",
        "https://www.in.gov/fssa/hip/hip-work-requirements/index"
      ],
      "quotes": [
        {
          "quote": "For existing HIP members, the lookback period will be three months before the renewal month or three months before the quarterly work requirements review.",
          "url": "https://www.in.gov/fssa/hip/hip-work-requirements/hwr-partner-toolkit"
        },
        {
          "quote": "You renew HIP every six months, and the state checks your hours every three months.",
          "url": "https://www.in.gov/fssa/hip/hip-work-requirements/info-for-hip-members"
        },
        {
          "quote": "Medically frail will be determined by the State. Physicians, and other clinicians, may provide recommendations on the medical history of their patients.",
          "url": "https://www.in.gov/fssa/hip/hip-work-requirements/info-for-hip-members"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027 on the agency's own pages (the state-law bar comes from a secondary source only)",
        "frailty condition list or claims method",
        "use of the CMS 3-tier frailty model"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "KS": {
      "name": "Kansas",
      "not_expansion": "Kansas did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in Kansas (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    },
    "KY": {
      "name": "Kentucky",
      "start_date": "2027-01-01 (Medicaid Work or Community Engagement, 'MACE'). No soft launch is published. Enrollees get a 30-day noncompliance window with coverage continued.",
      "self_attestation_2027": "Yes, broadly, for 2027 only, when Medicaid cannot confirm from available data. It covers work and community-engagement activities and all exemptions, including medical frailty. Forms MACE-100 (activities), MACE-200 (medical condition) and MACE-300 (hardship) can be self-signed in 2027. From 2028, frailty self-attestation is allowed one time.",
      "lookback_months": "Application: 1 month, the month before applying. Renewal: 3 of the 6 months before renewal.",
      "renewal_frequency": "6 months. The FAQ refers to 'the six-month period between renewals'. Medically frail status must be reverified every 12 months.",
      "frailty_method": "12 months of claims reviewed 'when available'. A list of conditions by diagnosis code is promised on the MACE webpage (not yet seen). Fallback is MACE-200, or a signed letter from a licensed provider on letterhead.",
      "member_page_url": "https://khbe.ky.gov/Enrollment/Pages/MedicaidWorkCE.aspx",
      "sources": [
        "https://khbe.ky.gov/Enrollment/MACEHR1/Medicaid_Work_or_Community_Engagement_FAQ.pdf"
      ],
      "quotes": [
        {
          "quote": "For 2027 only, you may fill out this form entirely yourself. You may sign the form yourself as self-attestation.",
          "url": "https://khbe.ky.gov/Enrollment/Pages/MedicaidWorkCE.aspx"
        },
        {
          "quote": "If you are a current Medicaid member, you must show you met the work or community engagement requirement for at least three of the six months before you renew your coverage.",
          "url": "https://khbe.ky.gov/Enrollment/Pages/MedicaidWorkCE.aspx"
        },
        {
          "quote": "When available, health care claims for the past 12 months will be reviewed to see if an enrolled member has a condition that may make them medically frail.",
          "url": "https://khbe.ky.gov/Enrollment/MACEHR1/Medicaid_Work_or_Community_Engagement_FAQ.pdf"
        }
      ],
      "unknowns": [
        "the diagnosis-code list itself (promised, not yet seen)",
        "use of the CMS 3-tier frailty model"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "LA": {
      "name": "Louisiana",
      "start_date": "2027-01-01 for members up for renewal and for new applicants. January 2027 renewals were mailed a notice in May 2026 and a renewal packet in November 2026. No soft launch is published. Members have 45 days to respond.",
      "self_attestation_2027": "For 2027 renewals, members can self-attest to two exemptions: caretaker relative/family caregiver, and medically frail. From 2028 a medical provider may be required to complete the form. Self-attestation of work, volunteer, income/hours or student status: not published. Pay stubs can replace the employer verification form.",
      "lookback_months": "Application: not published as of 2026-10-20. Renewal: at least one full month in the months before the renewal period. Not from the agency, per AmeriHealth Caritas LA, an MCO: one month in the last six months before renewal begins.",
      "renewal_frequency": "Not published on the LDH work-requirement page as of 2026-10-20. An LDH Medicaid Facebook post (search snippet only) mentions that 6-month renewals begin.",
      "frailty_method": "Not published beyond using 'reliable information the state already has, like employment and Social Security records'. No condition list. 2027 renewals rely on the member's self-attested frailty section.",
      "member_page_url": "https://ldh.la.gov/medicaid/work-requirements",
      "sources": [
        "https://ldh.la.gov/renew-medicaid"
      ],
      "quotes": [
        {
          "quote": "For 2027 renewals, members can self-attest that they meet these exemptions. Starting in 2028, a medical provider may be required to complete the form.",
          "url": "https://ldh.la.gov/medicaid/work-requirements"
        },
        {
          "quote": "Work/community engagement requirements will begin with members up for renewal and new applicants beginning January 1, 2027.",
          "url": "https://ldh.la.gov/medicaid/work-requirements"
        },
        {
          "quote": "Medicaid checks work/community engagement requirements in the months before renewal, so members need to ensure they are participating in approved activities for at least one full month before their renewal period.",
          "url": "https://ldh.la.gov/medicaid/work-requirements"
        }
      ],
      "unknowns": [
        "lookback at application",
        "renewal_frequency on an agency web page",
        "self-attestation for activities, income or student status",
        "frailty claims method or condition list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "MA": {
      "name": "Massachusetts",
      "start_date": "2027-01-01. Enrollees are not affected until their first renewal of 2027, or earlier if a change affects their coverage. No soft launch is published.",
      "self_attestation_2027": "Not published as of 2026-10-20 on member pages. The member page says some frailty conditions 'may need to show' significant impairment. Context: Massachusetts is a plaintiff in a multistate suit against the IFR (Case 1:26-cv-12962, filed 2026-06-29, posted on mass.gov). The complaint says MassHealth told CMS it favored accepting self-reported frailty information. That is a litigation position, not published 2027 policy.",
      "lookback_months": "Application: 1 month, the month before applying. Renewal: 1 month between the last renewal and the next.",
      "renewal_frequency": "6 months.",
      "frailty_method": "MassHealth 'will use available data' to confirm exemptions. Listed condition categories: ADL-limiting disability, alcohol or drug addiction, serious mental illness, serious or complex condition needing frequent care, and SSA blindness or disability. No condition list or claims method published.",
      "member_page_url": "https://www.mass.gov/info-details/new-work-and-education-requirements-for-masshealth-members",
      "sources": [
        "https://www.mass.gov/info-details/masshealth-federal-updates-and-impact",
        "https://www.mass.gov/decision-tree/find-out-if-you-need-to-meet-new-work-and-education-requirements-for-masshealth-members"
      ],
      "quotes": [
        {
          "quote": "Impacted members are required to meet work and education requirements for one month between their last renewal and their next renewal.",
          "url": "https://www.mass.gov/info-details/new-work-and-education-requirements-for-masshealth-members"
        },
        {
          "quote": "MassHealth will use available data to confirm if you are excused from or already meeting these requirements.",
          "url": "https://www.mass.gov/info-details/new-work-and-education-requirements-for-masshealth-members"
        },
        {
          "quote": "January 1, 2027: Some MassHealth members will have to comply with work requirements and eligibility checks every six months to receive coverage.",
          "url": "https://www.mass.gov/info-details/masshealth-federal-updates-and-impact"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "frailty claims method or condition list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "MD": {
      "name": "Maryland",
      "start_date": "January 2027. Notices went to affected members in September 2026. No soft launch is published.",
      "self_attestation_2027": "Not published as of 2026-10-20. Maryland Health Connection says it will check existing data and send a letter if more proof is needed.",
      "lookback_months": "Application: 1 month, the month before applying. Renewal: at least one month. MDH says 'at least one recent month'; Maryland Health Connection says the month is in 2027 renewals. Short-term hardships count 'since your last renewal'.",
      "renewal_frequency": "6 months ('two times a year').",
      "frailty_method": "Not published. The exemption is listed as a 'health condition that limits your work' (blindness or physical disability, mental health condition, substance use disorder, complex medical condition). Verification is described only generally as 'data we already have'.",
      "member_page_url": "https://www.marylandhealthconnection.gov/checkin/",
      "sources": [
        "https://health.maryland.gov/mmcp/Pages/workrequirements.aspx",
        "https://health.maryland.gov/mmcp/Pages/workrequirements-providers.aspx"
      ],
      "quotes": [
        {
          "quote": "New applicants must complete work requirements or other activities in the month prior to the application. Existing members must complete work requirements or other activities in at least one recent month.",
          "url": "https://health.maryland.gov/mmcp/Pages/workrequirements.aspx"
        },
        {
          "quote": "Starting Jan. 1, 2027, Maryland Health Connection will check if you meet the work rules using data we already have.",
          "url": "https://www.marylandhealthconnection.gov/checkin/"
        },
        {
          "quote": "Renew your Medicaid coverage two times a year (every 6 months) instead of once a year.",
          "url": "https://www.marylandhealthconnection.gov/checkin/"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "frailty method or condition list",
        "exact renewal lookback window definition"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "ME": {
      "name": "Maine",
      "start_date": "2027-01-01. Current MaineCare Expansion adults see the rule at their 2027 renewal, starting March 2027. No soft launch is published.",
      "self_attestation_2027": "Not published as of 2026-10-20. The member page only says members should 'Tell OFI' if an exemption applies.",
      "lookback_months": "Application: 1 month, the calendar month before the application. Renewal: at least 1 calendar month since the last renewal.",
      "renewal_frequency": "6 months for Expansion adults.",
      "frailty_method": "Not published. The exemption is described as a 'work-limiting health condition'. On Aug 21, 2026 OMS announced an upcoming pathway for providers to share data to support eligibility determinations; no details seen.",
      "member_page_url": "https://www.maine.gov/dhhs/ofi/health-care-assistance/work",
      "sources": [
        "https://www.maine.gov/dhhs/ofi/federalchanges",
        "https://www.maine.gov/dhhs/oms/providers/provider-bulletins/2027-mainecare-eligibility-changes-information-resources-and-partner-briefing-2026-08-21"
      ],
      "quotes": [
        {
          "quote": "MaineCare Expansion adults will need to meet these new requirements in at least one calendar month since their last MaineCare renewal to maintain their eligibility for MaineCare coverage.",
          "url": "https://www.maine.gov/dhhs/ofi/health-care-assistance/work"
        },
        {
          "quote": "Current MaineCare Expansion Adults will see the rule change at their 2027 MaineCare Renewal date beginning in March 2027.",
          "url": "https://www.maine.gov/dhhs/ofi/federalchanges"
        },
        {
          "quote": "It will now be every 6 months instead of every 12 months.",
          "url": "https://www.maine.gov/dhhs/ofi/federalchanges"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "frailty method (claims, list, provider data pathway details)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "MI": {
      "name": "Michigan",
      "start_date": "2027-01-01 for applications. Current Healthy Michigan Plan (HMP) enrollees: renewal dates on or after 2027-03-01. No soft launch is published.",
      "self_attestation_2027": "Medical frailty: yes. In 2027 MDHHS will not require documentation for self-attested conditions; documentation is required from 2028. Activities and other exemptions: the 2027 application asks questions about them, but whether answers are accepted without proof is not explicitly published.",
      "lookback_months": "Application: 1 month, either the month before or the month of application. Renewal: at least 1 month since the last renewal, or since coverage started if it is the first renewal.",
      "renewal_frequency": "Not stated on the MDHHS work-requirement page as of 2026-10-20. Secondary sources (community mental health presentations, e.g. cmhcm.org, norcocmh.org) say six-month renewals take effect March 1, 2027.",
      "frailty_method": "Claims, encounter and program-enrollment data checked against a Category 1/Category 2 code list. Category 2 conditions need added severity indicators. Automatic exemption for 30+ days in a hospital, hospice, nursing facility or psychiatric facility, or for PACE, MI Choice or Habilitation Supports Waiver enrollment. The exemption lasts 12 months. This closely resembles a tiered model. Code list: https://www.michigan.gov/healthymiplan/-/media/Project/Websites/mdhhs/Assistance-Programs/Medicaid-BPHASA/Medicaid-Changes/HMP-MF-Codes-List.pdf",
      "member_page_url": "https://www.michigan.gov/healthymiplan/new-medicaid-work-requirements",
      "sources": [
        "https://www.michigan.gov/healthymiplan/medical-frailty"
      ],
      "quotes": [
        {
          "quote": "In 2027, MDHHS will not require documentation for self‑attested conditions.",
          "url": "https://www.michigan.gov/healthymiplan/medical-frailty"
        },
        {
          "quote": "Work requirements will apply to HMP enrollees with renewal dates on or after March 1, 2027.",
          "url": "https://www.michigan.gov/healthymiplan/new-medicaid-work-requirements"
        },
        {
          "quote": "When renewing HMP coverage, you must meet work requirements during at least one month since your last renewal.",
          "url": "https://www.michigan.gov/healthymiplan/new-medicaid-work-requirements"
        }
      ],
      "unknowns": [
        "renewal_frequency on an agency page",
        "self-attestation for activities, income or student status",
        "main work-requirement page last updated 2026-06-23 and may be stale"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "MN": {
      "name": "Minnesota",
      "start_date": "2027-01-01. In Minnesota it applies to adults 21-64 without dependent children under 19 in the home, not pregnant, and not on MA based on disability. No soft launch is published.",
      "self_attestation_2027": "Not published as formal policy as of 2026-10-20. DHS ran a pre-renewal 'Renewal Lookup Tool' (mnrenewallookup.com) where enrollees report expected exemptions or activities to 'help us prepare' their 2027 renewal. DHS does not say whether those reports count as accepted self-attestation.",
      "lookback_months": "Application: not published as of 2026-10-20. Renewal: a month since the last Medical Assistance (MA) renewal.",
      "renewal_frequency": "6 months for the same adult group.",
      "frailty_method": "Not published. Definition only: 'living with a serious, complex, or chronic medical condition, or getting regular therapy or treatment.'",
      "member_page_url": "https://mn.gov/dhs/federalchanges/work-requirements/",
      "sources": [
        "https://mn.gov/dhs/federalchanges/six-month-renewal/",
        "https://mnrenewallookup.com/"
      ],
      "quotes": [
        {
          "quote": "They will need to meet the new requirements by either meeting an exemption or having completed a qualifying activity in a month since their last Medical Assistance renewal.",
          "url": "https://mn.gov/dhs/federalchanges/work-requirements/"
        },
        {
          "quote": "This change generally applies to adults ages 21 to 64 who do not have dependent children, are not pregnant, are not eligible for Medicare and do not qualify for Medical Assistance based on a disability.",
          "url": "https://mn.gov/dhs/federalchanges/work-requirements/"
        },
        {
          "quote": "Starting in 2027, some adults who get Medical Assistance will have a renewal every six months instead of once per year.",
          "url": "https://mn.gov/dhs/federalchanges/six-month-renewal/"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027 policy",
        "lookback at application",
        "frailty method or condition list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "MO": {
      "name": "Missouri",
      "start_date": "2027-01-01 for the Adult Expansion Group (AEG). Coverage does not end automatically; FSD must send a written notice first. Enrollees get a 35-day noncompliance window with coverage continued. Missouri is not using the optional short-term hardship exceptions.",
      "self_attestation_2027": "Not published on DSS pages as of 2026-10-20. DSS says FSD checks available data first, then asks for documents such as pay stubs or a signed volunteer record. Secondary (Missouri Health Matters blog) says Missouri will allow self-attestation in 2027 when records can't confirm compliance; not confirmed on any agency page.",
      "lookback_months": "Application: 1 month, the month right before applying. Renewal: at least 1 month since the last renewal ('a single month within your 6-month renewal period').",
      "renewal_frequency": "6 months for AEG.",
      "frailty_method": "Not published beyond: FSD first uses information already available, and a diagnosis alone is not enough because FSD must confirm the condition 'greatly limits' ability to comply. No condition list.",
      "member_page_url": "https://dss.mo.gov/community-engagement-requirements-frequently-asked-questions",
      "sources": [
        "https://dss.mo.gov/aeg-notice",
        "https://dss.mo.gov/hr1-implementation",
        "https://mydss.mo.gov/hr1/community-engagement-screener"
      ],
      "quotes": [
        {
          "quote": "If you already have MO HealthNet, you must meet the requirements in at least one month since your last renewal.",
          "url": "https://dss.mo.gov/community-engagement-requirements-frequently-asked-questions"
        },
        {
          "quote": "A diagnosis by itself does not automatically mean you do not have to meet the requirements.",
          "url": "https://dss.mo.gov/community-engagement-requirements-frequently-asked-questions"
        },
        {
          "quote": "Instead of renewing once a year, AEG members will renew every six months.",
          "url": "https://dss.mo.gov/community-engagement-requirements-frequently-asked-questions"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027 on agency pages (only a secondary source says yes)",
        "frailty claims method or condition list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "MS": {
      "name": "Mississippi",
      "not_expansion": "Mississippi did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in Mississippi (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    },
    "MT": {
      "name": "Montana",
      "start_date": "Early start: 2026-07-01 for new Expansion applications. Existing clients: redeterminations dated 2026-08-31 onward. No denials or disenrollments for noncompliance Jul-Sep 2026; enforcement began October 2026.",
      "self_attestation_2027": "Limited. New applicants may self-declare medical frailty on the Appendix B Self-Declaration form, mailed with the noncompliance notice. Existing clients must use a provider attestation for frailty. Activities and other exclusions need the documentation in DPHHS's verification matrix after ex parte checks fail. Presumptive-eligibility screening uses self-declaration only, with verification at full application. No broad 2027 self-attestation is published.",
      "lookback_months": "Application: 1 month, the month before applying. Renewal: 3 months, not necessarily consecutive, within the redetermination review period.",
      "renewal_frequency": "6 months beginning January 2027; American Indian/Alaska Native members stay at 12 months.",
      "frailty_method": "Claims-based from 2026-10-01: the CHIMES eligibility system scans 12 months of Medicaid claims for ICD-10 codes on DPHHS's Medically Frail Condition List. The list has two tiers (Tier 1 aligned to the CMS categories, Tier 2 frailty indicators), and a code in either tier exempts. Fallbacks: provider attestation (existing clients), self-declaration (new applicants), and an exception-request form for unlisted conditions. List: https://dphhs.mt.gov/assets/medicaidchanges/DPHHSMedicallyFrailCodeList_092926.pdf",
      "member_page_url": "https://dphhs.mt.gov/medicaidchanges/",
      "sources": [
        "https://dphhs.mt.gov/medicaidchanges/faqs",
        "https://dphhs.mt.gov/medicaidchanges/MedicallyFrail",
        "https://dphhs.mt.gov/medicaidchanges/VerificationMatrix"
      ],
      "quotes": [
        {
          "quote": "From July through September 2026, DPHHS will review community engagement for applications and redeterminations, but people will not be denied coverage or disenrolled for not meeting the requirement during this time.",
          "url": "https://dphhs.mt.gov/medicaidchanges/faqs"
        },
        {
          "quote": "Starting October 1, 2026, DPHHS will begin using Medicaid claims data to automatically identify individuals who qualify for this exclusion.",
          "url": "https://dphhs.mt.gov/medicaidchanges/MedicallyFrail"
        },
        {
          "quote": "New Applicants may submit a self-declaration of their medically frail status using the Self-Declaration form in Appendix B, mailed with their notice of non-compliance.",
          "url": "https://dphhs.mt.gov/medicaidchanges/MedicallyFrail"
        }
      ],
      "unknowns": [
        "whether any self-attestation for activities, income or student status will be accepted in calendar 2027",
        "whether the Tier 1/Tier 2 list is formally the CMS Sept 8 optional 3-tier model"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "NC": {
      "name": "North Carolina",
      "start_date": "2027-01-01.",
      "self_attestation_2027": "Not published as of 2026-10-20. Agency messaging is documentation-oriented: 'You may have to provide documents to support your answer', 'You must show proof of the time you worked and the money you made', and members are told to submit proof of exclusions to local DSS. Not from the agency, per KFF, March 2026: NC did not plan to use self-attestation for frailty.",
      "lookback_months": "Application: 3 (must meet the requirement 3 months in a row, in the 3 months before applying). Renewal: 3 of the 6 months before recertification (any 3).",
      "renewal_frequency": "6 months from 2027-01-01 (American Indian and Alaska Native members renew annually).",
      "frailty_method": "Not published in detail. The agency lists the statutory categories and says it 'is still working out what kinds of situations will qualify' for serious/complex conditions. Members are told to keep proof and tell local DSS. Not from the agency, per KFF, March 2026: claims, MCO data, data matches, provider confirmation.",
      "member_page_url": "https://medicaid.ncdhhs.gov/beneficiaries/impact-hr-1-and-federal-changes-medicaid/work-and-community-engagement-requirement",
      "sources": [
        "https://medicaid.ncdhhs.gov/beneficiaries/medicaid-is-changing"
      ],
      "quotes": [
        {
          "quote": "You need to meet the requirement for only 3 of the 6 months before your recertification.",
          "url": "https://medicaid.ncdhhs.gov/beneficiaries/impact-hr-1-and-federal-changes-medicaid/work-and-community-engagement-requirement"
        },
        {
          "quote": "You must meet the work and community engagement requirement for 3 months in a row, in the 3 months before you apply.",
          "url": "https://medicaid.ncdhhs.gov/beneficiaries/impact-hr-1-and-federal-changes-medicaid/work-and-community-engagement-requirement"
        },
        {
          "quote": "NC Medicaid is still working out what kinds of situations will qualify.",
          "url": "https://medicaid.ncdhhs.gov/beneficiaries/impact-hr-1-and-federal-changes-medicaid/work-and-community-engagement-requirement"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "Frailty identification method and condition list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "ND": {
      "name": "North Dakota",
      "start_date": "2027-01-01 for new applicants. Existing Medicaid Expansion members start with reviews due 2027-02-28.",
      "self_attestation_2027": "Not published as of 2026-10-20. The agency describes data checks first, then a notice requesting proof (pay stubs, employer letter, transcript, letter from volunteer organization, letter from work program).",
      "lookback_months": "Application: 1 (month before application). Renewal: at least 1 month in the last review period.",
      "renewal_frequency": "Not stated explicitly on the work-requirement page. The agency mentions 'more frequent reviews' with details at hhs.nd.gov/stayenrolled, and its example uses a Jan-June (6-month) review period.",
      "frailty_method": "Not published. The agency defines 'special health need' (SSA blind/disabled, SUD in recovery under 5 years, disabling mental health condition, ADL-limiting disability, serious/complex condition e.g. cancer or heart disease). No method or list URL.",
      "member_page_url": "https://www.hhs.nd.gov/human-services/medicaid/StayCoveredND",
      "sources": [
        "https://www.hhs.nd.gov/stayenrolled",
        "https://www.hhs.nd.gov/news/hhs-preparing-implement-federal-work-requirements-and-other-changes-medicaid-program"
      ],
      "quotes": [
        {
          "quote": "Work requirements will begin for Medicaid Expansion members who have a review due on Feb. 28, 2027, and new applicants starting Jan. 1, 2027.",
          "url": "https://www.hhs.nd.gov/human-services/medicaid/StayCoveredND"
        },
        {
          "quote": "For new 2027 applications: North Dakota Medicaid will check if qualifying activities were completed in the month before someone applies.",
          "url": "https://www.hhs.nd.gov/human-services/medicaid/StayCoveredND"
        },
        {
          "quote": "For 2027 renewals: North Dakota Medicaid will check that members met work requirements for at least one month in their last review period.",
          "url": "https://www.hhs.nd.gov/human-services/medicaid/StayCoveredND"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "how it checks medical frailty",
        "Explicit renewal frequency statement (stayenrolled page not checked)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "NE": {
      "name": "Nebraska",
      "start_date": "2026-05-01 (early implementer, first state). New applicants checked from 2026-05-01; existing members checked at renewal, starting with coverage periods ending on/after 2026-07-31. Soft launch: members with May or June 2026 renewal dates not checked until their 2027 renewal. County-based temporary hardship exemptions active in 14 counties, with automatic reprocessing of terminations.",
      "self_attestation_2027": "Agency uses an Individual Declaration Form (IDF), signed under penalty of perjury, for volunteering, education/apprenticeship, work programs, caring for a person with a disability, previous incarceration, medical exemptions (medically frail / SUD treatment) and VA disability ratings. New applicants may self-declare medical frailty or SUD treatment with no additional documentation 'at this time'. Medical hardships (hospital/nursing home, travel for care) also by declaration. Income/wages verified from state data first, and documents may be requested. Agency says it will 'move from self-declaration to more automated verification' over time. No state law barring self-attestation found.",
      "lookback_months": "Application: 1 (calendar month before applying for activities/income/hardship; month of application or month before for exemptions). Renewal: any 1 month since last renewal (agency: 'the work requirement review period is 12 months' under current 12-month renewals).",
      "renewal_frequency": "Agency pages still describe checking 'at each regularly scheduled renewal' with a 12-month review period. Nebraska's own pages say nothing about a move to 6-month renewals as of 2026-10-20.",
      "frailty_method": "Claims-first ex parte review about 90 days before the end of the eligibility period, using DHHS-curated ICD-10/CPT/HCPCS code logic. Self-declaration (condition description plus provider name/contact) is used when no claims exist and is the default path for new applicants. A published conditions index exists (DHHS: 'not a one-to-one diagnosis list'). Process doc updated 2026-09-14. Not stated whether NE uses the CMS 3-tier model.",
      "member_page_url": "https://dhhs.ne.gov/Pages/WorkRequirements.aspx",
      "sources": [
        "https://dhhs.ne.gov/Documents/MLTC-WR-Requirements-FAQ.pdf",
        "https://dhhs.ne.gov/Documents/NE%20MWR%20-%20Medically%20Frail%20and%20SUD%20Treatment%20Program%20Exemptions.pdf",
        "https://dhhs.ne.gov/Documents/Nebraska%20Medicaid%20Work%20Requirements%20-%20Medically%20Frail%20and%20SUD%20Conditions.pdf",
        "https://dhhs.ne.gov/Pages/DHHS-Preparing-Community-Partners-for-Medicaid-Work-Requirements.aspx"
      ],
      "quotes": [
        {
          "quote": "Members with renewal dates in May or June 2026 will not have to show they've met work requirements until their renewal in 2027.",
          "url": "https://dhhs.ne.gov/Pages/WorkRequirements.aspx"
        },
        {
          "quote": "If you're already on Medicaid, the work requirement review period is 12 months.",
          "url": "https://dhhs.ne.gov/Pages/WorkRequirements.aspx"
        },
        {
          "quote": "Individuals may self-declare that they are medically frail or enrolled in an SUD treatment program.",
          "url": "https://dhhs.ne.gov/Documents/NE%20MWR%20-%20Medically%20Frail%20and%20SUD%20Treatment%20Program%20Exemptions.pdf"
        }
      ],
      "unknowns": [
        "Date of the switch to 6-month renewals for expansion adults (not stated on NE pages)",
        "Whether self-declaration of activities continues through all of 2027 (no explicit 2027/2028 statement)",
        "Whether NE adopts the CMS Sept 2026 3-tier frailty model",
        "The FAQ PDF is v3.0 dated 2026-04-29 and predates the CMS IFC; the main page carries newer hardship content"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "NH": {
      "name": "New Hampshire",
      "start_date": "2027-01-01 for new applicants (December 2026 activity must be shown). Existing Granite Advantage members start at their first redetermination in 2027.",
      "self_attestation_2027": "Medical frailty: the agency says the '2027 federal framework permits NH to consider additional documentation or a statement/other information provided under penalty of perjury' when state data are insufficient. Agency pages publish no self-attestation policy for volunteer hours, income/hours or student status. Not found whether a state law bars attestation. NH has its own older state-law Granite Advantage work requirement, and its current status relative to the federal rule is not established here.",
      "lookback_months": "Application: 1 (calendar month immediately before the application month). Renewal: First CE review for existing members: 12-month lookback; subsequent lookbacks: 6 months (meet in at least 1 month).",
      "renewal_frequency": "6 months for Granite Advantage only, starting after each member's already-scheduled 2027 renewal (the existing 12-month period is retained). Medical frailty is reverified at least every 12 months.",
      "frailty_method": "Data-first, claims/encounter-based ex parte, using 'detailed clinical identification logic' that maps diagnoses to the frailty categories. A plain-language condition list is being developed for CMS review (not yet public). A member/applicant self-screener is due end of October 2026. A provider certification Form 330 pathway is planned (2028 workflow still being finalized). 3-tier model not named.",
      "member_page_url": "https://www.dhhs.nh.gov/programs-services/stay-covered-new-hampshire/medicaid-work-requirements-what-you-need-know",
      "sources": [
        "https://www.dhhs.nh.gov/programs-services/stay-covered-new-hampshire/stay-covered-nh-information-providers-and-community",
        "https://www.dhhs.nh.gov/sites/g/files/ehbemt476/files/media/media_document/mco-medicaid-matters-presentation-10062026.pdf"
      ],
      "quotes": [
        {
          "quote": "For new applicants, the changes are effective immediately on January 1, 2027, which means the work requirement must be demonstrated in December of 2026.",
          "url": "https://www.dhhs.nh.gov/programs-services/stay-covered-new-hampshire/medicaid-work-requirements-what-you-need-know"
        },
        {
          "quote": "When an existing member first becomes subject to CE after the current continuous-coverage period, the initial compliance lookback is 12 months; subsequent lookbacks are 6 months.",
          "url": "https://www.dhhs.nh.gov/sites/g/files/ehbemt476/files/media/media_document/mco-medicaid-matters-presentation-10062026.pdf"
        },
        {
          "quote": "Where State data are insufficient, the 2027 federal framework permits NH to consider additional documentation or a statement/other information provided under penalty of perjury.",
          "url": "https://www.dhhs.nh.gov/sites/g/files/ehbemt476/files/media/media_document/mco-medicaid-matters-presentation-10062026.pdf"
        }
      ],
      "unknowns": [
        "Self-attestation for volunteer/income/hours/student in 2027",
        "Public frailty condition list (in development)",
        "Interaction with NH's state-law Granite Advantage work requirement",
        "Member page says details 'may change based on upcoming guidance from the federal government'"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "NJ": {
      "name": "New Jersey",
      "start_date": "2027-01-01. Applies to new applicants on/after 2027-01-01 and to current members at their first renewal on/after that date. First renewals affected are those in March 2027.",
      "self_attestation_2027": "Yes, explicitly for 2027. Volunteering/community service: name of organization, hours and description. Job training program: name and hours. Exclusions NJ cannot verify (e.g., caring for a person with a disability): self-attested. Medical frailty: self-answered 'medical frailty screener'. Documents may be required starting 2028-01-01. Income/work is checked from wage records first, and documents (pay stubs etc.) are requested if it cannot be confirmed. No statement found on self-attesting student status.",
      "lookback_months": "Application: 1 (month before application, or month of application for activities; exceptions: month before). Renewal: at least 1 month since last renewal (FAQ: 'at least one month in the 6 months before your next renewal').",
      "renewal_frequency": "6 months for Plan ABP adults 19-64 from 2027-01-01 (American Indian and Alaska Native members keep 12 months).",
      "frailty_method": "Two routes: an automatic claims check at renewal, and a self-answered medical frailty screener in the application/renewal/RFI. Condition list 'still finalizing', with the link to be posted. SUD is excluded after 5+ years in recovery. 3-tier model not mentioned.",
      "member_page_url": "https://www.nj.gov/humanservices/dmahs/obbba/work-requirements/",
      "sources": [
        "https://www.nj.gov/humanservices/dmahs/obbba/medicaid-federal-changes.shtml",
        "https://njfcchecker.nj.gov/",
        "https://njfamilycare.dhs.state.nj.us/docs/NJFC-HR1-WR-ENGLISH.pdf"
      ],
      "quotes": [
        {
          "quote": "This is called “self-attestation,” which is a legal statement, so your answer must be true. Starting January 1, 2028, you may need to send documents as proof.",
          "url": "https://www.nj.gov/humanservices/dmahs/obbba/work-requirements/"
        },
        {
          "quote": "In 2027, you can confirm participation in volunteering or community service yourself by providing the name of the organization, the number of hours you volunteered, and a short description of what you do.",
          "url": "https://www.nj.gov/humanservices/dmahs/obbba/work-requirements/"
        },
        {
          "quote": "The first people affected are people who apply on or after January 1, 2027, and current members whose next renewal month is March 2027.",
          "url": "https://www.nj.gov/humanservices/dmahs/obbba/work-requirements/"
        }
      ],
      "unknowns": [
        "Final medical frailty condition list",
        "Whether student status may be self-attested",
        "County unemployment/disaster lookup link (to be posted)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "NM": {
      "name": "New Mexico",
      "start_date": "2027-01-01. The first renewal letters go in January 2027 to members with a March 2027 renewal date.",
      "self_attestation_2027": "Not published as of 2026-10-20. The agency says members 'may need to show proof of your hours or proof of an exemption' and 'If you think you qualify for an exemption, report it at renewal.' Not from the agency: the KFF March 2026 survey lists NM as planning to use self-attestation (if allowed) for frailty.",
      "lookback_months": "Application: 1 (month before applying). Renewal: any 1 month since last renewal.",
      "renewal_frequency": "6 months for many adults 19-64 (American Indian and Alaska Native members keep 12 months).",
      "frailty_method": "Not published by the agency. Not from the agency, per KFF, March 2026: NM planned to use claims, MCO utilization, MCO case-management data, provider confirmation, self-attestation and a health assessment screener.",
      "member_page_url": "https://www.hca.nm.gov/medicaidchanges/",
      "sources": [
        "https://www.hca.nm.gov/hr1resources/",
        "https://keepyourbenefitsnm.com/",
        "https://www.hca.nm.gov/wp-content/uploads/HCA_HR1_MED_WorkActivityRules_OnePager_12_forWeb.pdf"
      ],
      "quotes": [
        {
          "quote": "If you are an adult applying for Medicaid for the first time, you may need to complete 80 work or activity hours during the month before you apply.",
          "url": "https://www.hca.nm.gov/medicaidchanges/"
        },
        {
          "quote": "At your renewal, you may be asked to provide proof that you completed 80 hours of work or activities in any month since your last renewal.",
          "url": "https://www.hca.nm.gov/medicaidchanges/"
        },
        {
          "quote": "In January, New Mexico Medicaid will mail letters to members with a March 2027 renewal date.",
          "url": "https://www.hca.nm.gov/medicaidchanges/"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027 (not published by agency)",
        "how it checks medical frailty (not published by agency; KFF March 2026 only)",
        "Frailty condition list URL"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "NV": {
      "name": "Nevada",
      "start_date": "2027-01-01. Existing members are checked at their 2027 renewal date. No early start.",
      "self_attestation_2027": "Agency page says only: 'The law allows self-identification of certain exemptions. CMS is expected to release more guidance.' It is building a screening tool so members can explain health needs 'even without formal medical records'. Not from the agency, per Nevada Current, 2026-07-22, citing NVHA: members can self-attest compliance in 2027, with documentation required starting 2028. The agency itself publishes no per-category list.",
      "lookback_months": "Application: 1 (month before application, per agency exceptions text). Renewal: at least 1 month of the review period / since last renewal.",
      "renewal_frequency": "6 months, for renewals starting 2027-01-01 (agency).",
      "frailty_method": "A vendor reviews 'all reliable data sources' to verify exemptions, plus a screening tool now being built. Not from the agency: NVHA defines medically frail as one of five condition categories AND impaired ability to work (Nevada Current, 2026-07-22). No condition list URL published. 3-tier model not mentioned.",
      "member_page_url": "https://www.nevadamedicaid.nv.gov/WorkRequirements",
      "sources": [
        "https://www.nevadamedicaid.nv.gov/WorkRequirements/DoesThisApplytoMe/",
        "https://www.nevadamedicaid.nv.gov/WorkRequirements/verifying-compliance/",
        "https://www.dss.nv.gov/programs/Medicaid/medicaid-eligibility-rules-are-changing/",
        "https://nv.benefitstools.org/",
        "https://www.nevadamedicaid.nv.gov/WorkRequirements/new-requirements/"
      ],
      "quotes": [
        {
          "quote": "The law allows self-identification of certain exemptions. CMS is expected to release more guidance on how this will work in practice",
          "url": "https://www.nevadamedicaid.nv.gov/WorkRequirements/verifying-compliance/"
        },
        {
          "quote": "If any of the following applied to you during the month before your Medicaid application, or during at least one month since your last Medicaid renewal, you may not need to meet work requirements",
          "url": "https://www.nevadamedicaid.nv.gov/WorkRequirements/DoesThisApplytoMe/"
        },
        {
          "quote": "New law requires renewal every 6 months",
          "url": "https://www.nevadamedicaid.nv.gov/WorkRequirements/new-requirements/"
        }
      ],
      "unknowns": [
        "Per-category self-attestation list (agency verifying-compliance page dated 2026-05-13 predates the IFC)",
        "Frailty condition list / code set",
        "Use of the CMS 3-tier model",
        "Application look-back stated for exceptions only; for activities it is implied but not stated explicitly"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "NY": {
      "name": "New York",
      "start_date": "2027-01-01. Requirements are reviewed at application or renewal. Members renewing before 2027-03-01 get one more 12-month period.",
      "self_attestation_2027": "Partially published. Pregnancy/postpartum needs no medical documentation. Hospital/nursing stay and medical-travel temporary exceptions are reported on the application. Otherwise: 'NY State of Health might ask you for documents or to verify the information yourself. Details on required documentation will be available closer to January 1, 2027.' No specific 2027 attestation list for volunteer, hours or student.",
      "lookback_months": "Application: not published by agency as of 2026-10-20 (KFF's March 2026 survey, not the agency: 1 month). Renewal: not published by agency as of 2026-10-20 (KFF's March 2026 survey, not the agency: 1 month).",
      "renewal_frequency": "6 months for most adults 19-64 who apply after 2027-01-01 or renew after 2027-03-01 (American Indian and Alaska Native members stay annual).",
      "frailty_method": "Not yet published: the agency says it 'plans to provide details on which conditions qualify soon' and is 'still determining the best way to assess' impairment. Not from the agency, per KFF, March 2026: planned claims, MCO data, data matches, self-attestation and a screener.",
      "member_page_url": "https://info.nystateofhealth.ny.gov/stay-covered",
      "sources": [
        "https://omh.ny.gov/omhweb/hr-1-changes/index.html",
        "https://info.nystateofhealth.ny.gov/sites/default/files/Example%20Notice%20of%20Work%20Requirements%20for%20Medicaid.pdf",
        "https://info.nystateofhealth.ny.gov/HR1-Tool-Kit"
      ],
      "quotes": [
        {
          "quote": "New York State will not require you to provide medical documentation to prove you are pregnant or postpartum.",
          "url": "https://info.nystateofhealth.ny.gov/stay-covered"
        },
        {
          "quote": "If the state doesn’t have the information it needs, NY State of Health might ask you for documents or to verify the information yourself. Details on required documentation will be available closer to January 1, 2027.",
          "url": "https://info.nystateofhealth.ny.gov/stay-covered"
        },
        {
          "quote": "If you apply for Medicaid after January 1, 2027, or renew after March 1, 2027, you will renew every 6 months if you still qualify.",
          "url": "https://info.nystateofhealth.ny.gov/stay-covered"
        },
        {
          "quote": "For seasonal workers, New York State will assess compliance with work requirements by averaging consumers’ income over the 12 months preceding the month of application.",
          "url": "https://info.nystateofhealth.ny.gov/HR1-Tool-Kit"
        }
      ],
      "unknowns": [
        "how many months it looks back (the agency has not said; KFF's March 2026 survey says one month at application and at renewal)",
        "Self-attestation scope for activities/student",
        "Frailty condition list and method"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20",
      "subject_note": "Seasonal workers: New York averages income over the 12 months before the month of application; an average of at least $580 a month meets the rule (the federal rule says six months)."
    },
    "OH": {
      "name": "Ohio",
      "start_date": "Requirement effective 2027-01-01, but renewals under it begin in April 2027 (agency Q&A: a January 2027 redetermination is evaluated under current rules). The provider page notes changes are 'not currently in effect'.",
      "self_attestation_2027": "Limited. Medically frail self-attestation is accepted only at Presumptive Eligibility (Qualified Entities), and documentation is required at full application. Otherwise the agency lists documents for each exemption and activity (doctor's statement, letters from organizations, pay stubs). A pregnancy 'Verbal or Written Statement' is accepted. No 2027 self-attestation for volunteer/hours/student published.",
      "lookback_months": "Application: 1 (month before application). Renewal: at least 1 month since last application/renewal (lookback = time since last renewal).",
      "renewal_frequency": "6 months beginning 2027-01-01 per agency (WCER renewals start April 2027).",
      "frailty_method": "Claims-based ex parte at renewal: one claim with a qualifying ICD-10 diagnosis (primary or secondary) is enough. A published Medically Frail ICD-10 code list (dated 2025-10-29). Provider documentation for new applicants or when claims lag. 3-tier model not mentioned.",
      "member_page_url": "https://medicaid.ohio.gov/resources-for-providers/special-programs-and-initiatives/group-viii",
      "sources": [
        "https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Families%2C%20Individuals/Programs/Community/Group_VIII_Informational_Webinar_Q_A.pdf",
        "https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Providers/group-viii/HR1_Required_Outreach_Language_v4_1.pdf",
        "https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Providers/group-viii/Copy_of_Medically_Frail_ICD-10_Codes_-_10.29.2025.pdf",
        "https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Families%2C%20Individuals/Programs/Community/Group_VIII_Partner_Packet_08132026.pdf"
      ],
      "quotes": [
        {
          "quote": "ODM will not begin renewals under this requirement until April 2027. Therefore, a January 2027 redetermination will be evaluated based on current eligibility rules.",
          "url": "https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Families%2C%20Individuals/Programs/Community/Group_VIII_Informational_Webinar_Q_A.pdf"
        },
        {
          "quote": "If the individual has one claim with a diagnosis code indicating frailty, this will be sufficient to verify their exemption.",
          "url": "https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Families%2C%20Individuals/Programs/Community/Group_VIII_Informational_Webinar_Q_A.pdf"
        },
        {
          "quote": "If you are applying for Medicaid: Show you met the requirement during the month before you applied.",
          "url": "https://dam.assets.ohio.gov/image/upload/medicaid.ohio.gov/Providers/group-viii/HR1_Required_Outreach_Language_v4_1.pdf"
        }
      ],
      "unknowns": [
        "A dedicated member-facing page (only a provider-section page found)",
        "Whether ODM will allow 2027 self-attestation of activities (none published)",
        "Whether the ICD-10 list was updated after the IFC (list dated 2025-10-29)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "OK": {
      "name": "Oklahoma",
      "start_date": "2027-01-01.",
      "self_attestation_2027": "Not published as of 2026-10-20. Screener note: 'These circumstances may need to be verified and documented. More information on what will need to be provided is coming soon from OHCA.' Not from the agency, per KFF, March 2026: OK planned to accept self-attestation for frailty if allowed.",
      "lookback_months": "Application: 1 (month before). Renewal: first 2027 renewal: month before; later renewals: any 1 of the previous 6 months.",
      "renewal_frequency": "6 months (agency: 'we will check every six months when you renew').",
      "frailty_method": "Not published by agency. Not from the agency, per KFF, March 2026: claims, MCO data, case management, data matches, provider confirmation, self-attestation, health assessment screener.",
      "member_page_url": "https://oklahoma.gov/ohca/individuals/mysoonercare/work-requirements.html",
      "sources": [
        "https://oklahoma.gov/ohca/individuals/mysoonercare/work-requirements/stakeholder-toolkit.html",
        "https://oklahoma.gov/content/dam/ok/en/okhca/docs/individuals/mysoonercare-portal/work-requirements/Work%20Requirements%20Flyer.pdf"
      ],
      "quotes": [
        {
          "quote": "If you are applying for SoonerCare or renewing for the first time in 2027, you must meet the work requirements or have an exemption for the month before.",
          "url": "https://oklahoma.gov/ohca/individuals/mysoonercare/work-requirements.html"
        },
        {
          "quote": "When you renew after that, you must meet the work requirements or have an exemption in one of the previous six months from your renewal date.",
          "url": "https://oklahoma.gov/ohca/individuals/mysoonercare/work-requirements.html"
        },
        {
          "quote": "OHCA must check to see if you meet work requirements or are exempt when you apply for SoonerCare. After that, we will check every six months when you renew.",
          "url": "https://oklahoma.gov/ohca/individuals/mysoonercare/work-requirements.html"
        }
      ],
      "unknowns": [
        "whether your own word counts in 2027",
        "how it checks medical frailty / condition list"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "OR": {
      "name": "Oregon",
      "start_date": "2027 (agency: 'Starting in 2027 ... when they apply for or renew OHP'). Applied at each member's application/renewal, and Oregon's 6-month renewals do not start until late 2027, so most existing members are effectively first checked at their next renewal.",
      "self_attestation_2027": "Broadest of this set: 'In 2027, you can tell us you have an exemption. You don't need to give proof.' That covers frailty / serious health conditions with no provider statement in 2027, caregiving, inpatient stays, medical travel, SUD treatment and pregnancy. Activities (income, school, 80 hours) list proof documents. Self-attestation of activities in 2027 is not explicitly stated, but volunteer hours must be with an organization that 'can confirm them if asked'. Proof is required for more exemptions in 2028.",
      "lookback_months": "Application: 1 (month before application month; sometimes the application month). Renewal: at least 1 month during the 6 months before renewal date.",
      "renewal_frequency": "6 months for applicable adults 19-64, but starting late 2027 (most OHP members now renew every 2 years).",
      "frailty_method": "Self-report in 2027 plus medical records ('If you are regularly receiving care, your medical records may be enough for us to verify an exemption'). Published illustrative condition examples (exemptions explainer). 2028: possibly a provider statement. Not from the agency, per KFF, March 2026: federal definition; claims, MCO data, data matches, provider confirmation, self-attestation.",
      "member_page_url": "https://www.oregon.gov/oha/hsd/ohp/pages/federal-changes.aspx",
      "sources": [
        "https://www.oregon.gov/oha/HSD/OHP/Documents/Work-Activity-Exemptions.pdf",
        "https://www.oregon.gov/oha/HSD/OHP/Tools/Work-Activity-Requirements-EN.pdf",
        "https://www.oregon.gov/oha/HSD/OHP/pages/toolkit.aspx"
      ],
      "quotes": [
        {
          "quote": "In 2027, you can tell us you have an exemption. You don't need to give proof.",
          "url": "https://www.oregon.gov/oha/hsd/ohp/pages/federal-changes.aspx"
        },
        {
          "quote": "If you're renewing: In at least one month during the six months before your renewal date.",
          "url": "https://www.oregon.gov/oha/hsd/ohp/pages/federal-changes.aspx"
        },
        {
          "quote": "OHP and Medicare Savings Program members will need to renew more frequently starting in late 2027.",
          "url": "https://www.oregon.gov/oha/hsd/ohp/pages/federal-changes.aspx"
        }
      ],
      "unknowns": [
        "Whether activity hours/income/student status may be self-attested in 2027 (page lists proof documents)",
        "Exact first enforcement month for existing members",
        "Frailty code list (only examples published)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "PA": {
      "name": "Pennsylvania",
      "start_date": "2027-01-01 for applicants. Current recipients are checked starting at their next renewal in 2027; 'Medicaid coverage will not automatically change on January 1.' Outreach began Aug-Sep 2026. No separate soft-launch or no-disenrollment period is published.",
      "self_attestation_2027": "Yes for most activities and exemptions in 2027, but paid work must always be verified (for example a pay stub). Self-attestation ends in 2028. No state-law bar was found in agency sources.",
      "lookback_months": "Application: the 1 month before the month of application. Renewal: at least 1 month since the last renewal.",
      "renewal_frequency": "6 months. Current recipients switch after completing their next renewal in or after Feb 2027. New 2027 applicants renew 6 months after benefits start.",
      "frailty_method": "DRAFT strategy, not approved by CMS (May 2026 deck). DHS will review claims against a list of eligible conditions. That list is preliminary, built from the CMS Chronic Condition Warehouse and other sources and refined by clinical review. DHS will also use the P3N health information exchange (admission/discharge notices, aimed at new applicants), MCO health risk assessments and case-management data, and information the applicant provides when records miss a condition. Deck: https://www.pa.gov/content/dam/copapwp-pagov/en/dhs/documents/medicaid/hr1-related/2026-05-may-pa-medical-frailty-overview-presentation.pdf . No public condition list and no CMS-tier mapping are published.",
      "member_page_url": "https://www.pa.gov/agencies/dhs/resources/medicaid/medicaid-changes",
      "sources": [
        "https://www.pa.gov/agencies/dhs/resources/medicaid/faq-medicaid-changes",
        "https://www.pa.gov/agencies/dhs/resources/medicaid/medicaid-toolkit"
      ],
      "quotes": [
        {
          "quote": "Paid work must always be verified, so you need to provide information to PA DHS showing that you received payment, such as a pay stub.",
          "url": "https://www.pa.gov/agencies/dhs/resources/medicaid/faq-medicaid-changes"
        },
        {
          "quote": "In 2027, most other work activities and exemptions can be verified by answering questions (self-attestation) on your application or renewal.",
          "url": "https://www.pa.gov/agencies/dhs/resources/medicaid/faq-medicaid-changes"
        },
        {
          "quote": "For a renewal, if you do not meet an exemption, you will need to provide information to show that you are meeting the work requirement in at least one month since your last renewal.",
          "url": "https://www.pa.gov/agencies/dhs/resources/medicaid/faq-medicaid-changes"
        }
      ],
      "unknowns": [
        "Final (CMS-approved) frailty method and condition list",
        "Whether PA adopts the CMS Sept 2026 3-tier model",
        "Which specific exemptions, if any, are excluded from 2027 self-attestation besides paid work"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "RI": {
      "name": "Rhode Island",
      "start_date": "2027-01-01 for expansion adults. The member page says 'You do not need to report anything right now.' No soft launch is published.",
      "self_attestation_2027": "Medical frailty: yes. Claims are checked first; if claims data are insufficient, the member can self-attest, with no extra documentation from the member or the provider in 2027 (this may change in 2028). Income: auto-renews if data is on file, otherwise the state may ask for a pay stub. Self-attestation for volunteer hours, work hours or student status is not explicitly published.",
      "lookback_months": "Application: the month before the application. Renewal: the first 2027 renewal looks back to the last renewal (up to 12 months), then the previous 6 months at each 6-month renewal. One compliant or exempt month is enough.",
      "renewal_frequency": "6 months for expansion adults starting in 2027 (passive auto-renewal when data confirm eligibility).",
      "frailty_method": "Claims-based automatic exemption for SUD treatment and special medical or behavioral health needs. The state built a list of conditions and claims information mapped to the federal frailty categories, including severity and functional impact. Self-attestation is the fallback. The SUD rule: less than 5 years in recovery may qualify if the condition significantly impacts ability; 5 or more years in stable recovery does not qualify on SUD alone. The list URL is not published. CMS tiers are not mentioned.",
      "member_page_url": "https://staycovered.ri.gov/updates-news/medicaid-updates/work-requirements",
      "sources": [
        "https://staycovered.ri.gov/updates-news/medicaid-updates/provider-community-partner-faqs",
        "https://staycovered.ri.gov/updates-news/medicaid-updates/work-requirements/medicaid-work-requirements-screener"
      ],
      "quotes": [
        {
          "quote": "If claims data are insufficient, individuals can self-attest to their condition and its impact.",
          "url": "https://staycovered.ri.gov/updates-news/medicaid-updates/provider-community-partner-faqs"
        },
        {
          "quote": "For a member’s first renewal in 2027, the State will look back to the member’s last renewal, up to 12 months prior. After that, the State will review the previous six months at each six-month renewal.",
          "url": "https://staycovered.ri.gov/updates-news/medicaid-updates/provider-community-partner-faqs"
        },
        {
          "quote": "For new applicants, the State will look back to the month before the application to see if the individual has met Medicaid work requirements.",
          "url": "https://staycovered.ri.gov/updates-news/medicaid-updates/provider-community-partner-faqs"
        }
      ],
      "unknowns": [
        "Self-attestation for volunteer, work-hours and student status",
        "Public URL of the RI frailty condition list",
        "CMS 3-tier adoption",
        "The member work-requirements page itself (Cloudflare blocked my direct fetch; the quotes come from the partner FAQ on the same site)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "SC": {
      "name": "South Carolina",
      "not_expansion": "South Carolina did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in South Carolina (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    },
    "SD": {
      "name": "South Dakota",
      "start_date": "2027-01-01 for new applicants. Current recipients are checked at their first regularly scheduled renewal in 2027; the first group is those with certification periods ending 2027-03-31. No soft launch is published.",
      "self_attestation_2027": "Not stated as a 2027 self-attestation policy. The fact sheet says that if DSS cannot verify activities electronically it will request paper documentation or a signed statement from the member. Frailty: providers may be asked to verify diagnoses on form DSS-EA-402. Otherwise not published as of 2026-10-20.",
      "lookback_months": "Application: the 1 month before applying. Renewal: at least 1 month since the last renewal. Incarceration exclusion: the 3 months before the review period.",
      "renewal_frequency": "6 months for Medicaid Expansion, effective 2027-01-01 (American Indian and Alaska Native members exempt, 12 months).",
      "frailty_method": "Electronic data first (for example medical claims). If needed, providers verify diagnoses on the DSS-EA-402 Medical Screener Form; providers do not determine ability to work. Frailty includes active SUD (treatment within the last 5 years), impact on at least one ADL, and similar criteria. A provider webinar on physician attestation forms for medically frail recipients is set for 2026-11-04. CMS tiers are not mentioned.",
      "member_page_url": "https://dss.sd.gov/medicaid/HR1.aspx",
      "sources": [
        "https://dss.sd.gov/formsandpubs/docs/MEDELGBLTY/EA400.pdf",
        "https://dss.sd.gov/docs/medicaid/providers/billingmanuals/General/Recipient_Eligibility.pdf"
      ],
      "quotes": [
        {
          "quote": "For a new applicant, that’s the one (1) month before you apply. For an ongoing recipient, it’s at least one (1) month since your last renewal.",
          "url": "https://dss.sd.gov/formsandpubs/docs/MEDELGBLTY/EA400.pdf"
        },
        {
          "quote": "If we can’t verify your activities electronically, we will request paper documentation or a signed statement from you.",
          "url": "https://dss.sd.gov/formsandpubs/docs/MEDELGBLTY/EA400.pdf"
        },
        {
          "quote": "However, providers may be asked to verify an individual’s medical diagnoses by completing the DSS-EA-402 Medical Screener Form",
          "url": "https://dss.sd.gov/docs/medicaid/providers/billingmanuals/General/Recipient_Eligibility.pdf"
        }
      ],
      "unknowns": [
        "An explicit 2027 self-attestation policy by category",
        "Frailty diagnosis list",
        "CMS tier adoption (pending the 11/4 webinar)"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "TN": {
      "name": "Tennessee",
      "not_expansion": "Tennessee did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in Tennessee (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    },
    "TX": {
      "name": "Texas",
      "not_expansion": "Texas did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in Texas (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    },
    "UT": {
      "name": "Utah",
      "start_date": "2027-01-01. Applies to Adult Expansion and Targeted Adult Medicaid (TAM). The agency says 'You do not need to do anything right now.' No soft launch is published.",
      "self_attestation_2027": "not published as of 2026-10-20. Agency pages say only 'You may need to provide proof of these activities every 6 months' and that DWS checks records first. Not from the agency: KFF (March 2026) lists Utah as planning self-attestation for frailty if allowed. No state-law bar was found in agency sources (not exhaustively checked).",
      "lookback_months": "Application: the month before applying. Renewal: from the last renewal or approval until now (at least 1 month). Incarceration: the 3 months before the last approval or renewal.",
      "renewal_frequency": "6 months for Adult Expansion and TAM (American Indian and Alaska Native members with verified status stay at 12 months).",
      "frailty_method": "not published as of 2026-10-20 on agency pages. The partner FAQ says frailty 'need[s] more definition'. Not from the agency, per KFF, March 2026: planned sources are claims, treating-provider confirmation, self-attestation and a health assessment screener.",
      "member_page_url": "https://medicaid.utah.gov/community-engagement-requirement/",
      "sources": [
        "https://obbba.medicaid.utah.gov/",
        "https://medicaid-documents.dhhs.utah.gov/Documents/pdfs/OBBBA%20FAQ%20for%20partners_1.2026.pdf",
        "https://obbba.medicaid.utah.gov/wp-content/themes/twentytwelve/page-templates/pdf/FINAL_H.R.1-CE-requirement-toolkit.pdf"
      ],
      "quotes": [
        {
          "quote": "You may need to provide proof of these activities every 6 months during your review.",
          "url": "https://medicaid.utah.gov/community-engagement-requirement/"
        },
        {
          "quote": "If you do not meet an exclusion listed above, you must fulfill the community engagement requirement in at least one month since your last approval or renewal.",
          "url": "https://medicaid.utah.gov/community-engagement-requirement/"
        },
        {
          "quote": "DWS will check your records first. If they already see that you work, go to school, or have other benefits, you may not need to send in any paperwork.",
          "url": "https://obbba.medicaid.utah.gov/wp-content/themes/twentytwelve/page-templates/pdf/FINAL_H.R.1-CE-requirement-toolkit.pdf"
        }
      ],
      "unknowns": [
        "2027 self-attestation policy",
        "Frailty identification method and condition list",
        "CMS tier adoption",
        "Whether any Utah statute constrains attestation"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "VA": {
      "name": "Virginia",
      "start_date": "Applicants applying on or after 2027-01-01. Current members are checked at renewals scheduled for 2027-03-31 or later. Member letters went out by end of Sep 2026.",
      "self_attestation_2027": "Yes, 'in most cases' the application or renewal answers are enough for an exemption or for meeting the requirement. Medical, mental health and disability exemption: no documentation or doctor sign-off required in 2027. Additional requirements apply in 2028. No state-law bar was found in agency sources.",
      "lookback_months": "Application: the month immediately before applying. Renewal: at least 1 month since the most recent renewal or enrollment.",
      "renewal_frequency": "6 months (phased in from Jan 2027; example: a renewal in March 2027 leads to the next one in September 2027).",
      "frailty_method": "The state 'will try to use information we already have' plus answers on the application or renewal. It says 'We will be providing more guidance on this exemption.' No claims method, list or CMS tiers are published.",
      "member_page_url": "https://www.dmas.virginia.gov/news-updates/new-federal-requirements/federal-work-requirements/",
      "sources": [
        "https://www.dmas.virginia.gov/media/cyvdt2wd/hr1-work-requirement-faqs-09-15-26.pdf",
        "https://coverva.dmas.virginia.gov/learn/coverage-for-adults/adults-19-64-years-old/"
      ],
      "quotes": [
        {
          "quote": "The work requirement will apply to renewals scheduled for March 31, 2027 or later.",
          "url": "https://www.dmas.virginia.gov/news-updates/new-federal-requirements/federal-work-requirements/"
        },
        {
          "quote": "In 2027, in most cases, the information you put on your application or renewal will be all you need to show you qualify for an exemption or have met the work requirement.",
          "url": "https://www.dmas.virginia.gov/news-updates/new-federal-requirements/federal-work-requirements/"
        },
        {
          "quote": "No. For 2027, you are not required to provide any documentation of your medical condition or disability.",
          "url": "https://www.dmas.virginia.gov/media/cyvdt2wd/hr1-work-requirement-faqs-09-15-26.pdf"
        }
      ],
      "unknowns": [
        "Frailty data method and condition list",
        "CMS tier adoption"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "VT": {
      "name": "Vermont",
      "start_date": "Applicants: 2027-01-01. Current members: 2027-03-01 (renewals).",
      "self_attestation_2027": "Yes. Hours (work, community service, education, work program) and exclusions (including health-condition exclusions) can be met by 'auditable self-attestation' in 2027; documentation may be required in 2028. Income of $580 or more uses the Acceptable Verification Documents list (not stated as self-attestable). No state-law bar was found.",
      "lookback_months": "Application: 1 month (the calendar month before). First renewal in 2027: 12-month lookback. Later 6-month renewals: 6-month lookback. Only one compliant month is needed.",
      "renewal_frequency": "6 months after the first 2027 renewal.",
      "frailty_method": "Agency lists the federal categories (blind or disabled, SUD, disabling mental disorder, serious or complex condition, ADL-impairing disability) plus 'significantly impairs' ability. In 2027 these are met by auditable self-attestation, and the state checks 'using information we already have' at the first renewal. No claims method, condition list or CMS tiers are published.",
      "member_page_url": "https://dvha.vermont.gov/medicaid-changes/how-to-meet-medicaid-work-requirements",
      "sources": [
        "https://dvha.vermont.gov/medicaid-changes",
        "https://dvha.vermont.gov/medicaid-work-requirements-screening-tool"
      ],
      "quotes": [
        {
          "quote": "In 2027, you will need to provide auditable self-attestation. In 2028, you may need to provide documentation of hours.",
          "url": "https://dvha.vermont.gov/medicaid-changes/how-to-meet-medicaid-work-requirements"
        },
        {
          "quote": "If you are a new applicant, you must have met the requirement in the calendar month prior to the month you are applying.  This is called a one-month lookback period.",
          "url": "https://dvha.vermont.gov/medicaid-changes/how-to-meet-medicaid-work-requirements"
        },
        {
          "quote": "The first renewal has a 12-month lookback period.  After that, you will have to renew your Medicaid every 6 months, with a 6-month lookback period.",
          "url": "https://dvha.vermont.gov/medicaid-changes/how-to-meet-medicaid-work-requirements"
        }
      ],
      "unknowns": [
        "Data or claims frailty method and condition list",
        "CMS tier adoption",
        "Whether income can be self-attested"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "WA": {
      "name": "Washington",
      "start_date": "2027-01-01 (Apple Health for Adults). No soft launch is published.",
      "self_attestation_2027": "Medical frailty: yes, accepted without additional proof through 2027; verification starts January 2028. Self-attestation for work hours, volunteering, income or student status is not explicitly published on the member page. Two short-term hardships (out-of-community medical travel, inpatient stays) must be requested by the member.",
      "lookback_months": "Application: the month before the application month (current-month exclusions: the application month or the month before). Renewal: any one month during the certification period.",
      "renewal_frequency": "6 months from 2027-01-01 (American Indian and Alaska Native members: 12 months).",
      "frailty_method": "Published diagnosis and condition code list: https://www.hca.wa.gov/assets/billers-and-providers/medically-frail-code-list.xlsx . Residents of Rainier School, Fircrest, Lakeland Village and Yakima Valley School are frail. Self-attestation through 2027; from 2028, data sources first, then proof. CMS tiers are not mentioned.",
      "member_page_url": "https://www.hca.wa.gov/free-or-low-cost-health-care/i-need-medical-dental-or-vision-care/apple-health-medicaid-work-requirements",
      "sources": [
        "https://www.hca.wa.gov/assets/free-or-low-cost/hr1-work-requirements-and-renewals-fact-sheet.pdf",
        "https://www.hca.wa.gov/free-or-low-cost-health-care/i-need-medical-dental-or-vision-care/what-changes-apple-health-mean-you"
      ],
      "quotes": [
        {
          "quote": "We will accept self-attestation of an individual’s medically frail status without requiring additional proof through 2027. Verification requirements of medically frail go into effect January 2028.",
          "url": "https://www.hca.wa.gov/free-or-low-cost-health-care/i-need-medical-dental-or-vision-care/apple-health-medicaid-work-requirements"
        },
        {
          "quote": "If you are enrolled in Apple Health for Adults, you will be required to renew your coverage every 6 months instead of 12 months.",
          "url": "https://www.hca.wa.gov/free-or-low-cost-health-care/i-need-medical-dental-or-vision-care/what-changes-apple-health-mean-you"
        }
      ],
      "unknowns": [
        "Self-attestation for activities and income in 2027",
        "CMS tier adoption"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "WI": {
      "name": "Wisconsin",
      "start_date": "New applicants: 2027-01-01. Most current members: renewals beginning March 2027. Member letters went out Aug-Sep 2026.",
      "self_attestation_2027": "Serious or complex medical condition: yes. Applicants are asked at application with no further action needed; current members are checked against data first and asked to self-attest at renewal if needed. No provider forms. Self-attestation for work, volunteer, income or student status is not explicitly published ('Members may need to report they are compliant').",
      "lookback_months": "Application: the month before the application month. Renewal: 1 month since last approval, 'in most cases the last 12 months'.",
      "renewal_frequency": "The agency describes an annual renewal check: 'we'll check annually at renewal'. A 6-month renewal is not stated for this group.",
      "frailty_method": "Automatic exemptions for an SSA disability determination and for enrollment in long-term care (Family Care, IRIS, PACE). Multiple data sources including claims data. Self-attestation of a serious or complex medical condition at application or renewal. No condition list or CMS tiers are published.",
      "subject_note": "SUBJECT. Wisconsin did not expand Medicaid. The requirement applies to the BadgerCare Plus 'childless adult' group, covered under the section 1115 BadgerCare waiver up to 100% FPL: ages 19-64, not pregnant, no dependent child under 19 at home. DHS estimates about 200,000 of about 800,000 BadgerCare Plus members. Parents whose child lives with them at least 40% of the time are not subject.",
      "member_page_url": "https://www.dhs.wisconsin.gov/medicaid/work.htm",
      "sources": [
        "https://www.dhs.wisconsin.gov/forwardhealth/partners/work-requirement-webinar-7-30-2026.pdf"
      ],
      "quotes": [
        {
          "quote": "No. We will check for compliance or an exemption when someone first applies and then we'll check annually at renewal.",
          "url": "https://www.dhs.wisconsin.gov/medicaid/work.htm"
        },
        {
          "quote": "At application, we’ll ask if they have a serious or complex medical condition. No further action is needed by the applicant.",
          "url": "https://www.dhs.wisconsin.gov/forwardhealth/partners/work-requirement-webinar-7-30-2026.pdf"
        },
        {
          "quote": "Most current members: March 2027.",
          "url": "https://www.dhs.wisconsin.gov/medicaid/work.htm"
        }
      ],
      "unknowns": [
        "Self-attestation for activities and income",
        "Whether 6-month renewals will ever apply to the group",
        "Frailty condition list",
        "CMS tier adoption"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "WV": {
      "name": "West Virginia",
      "start_date": "2027-01-01. Applicants may need to comply in the month before (Dec 2026 for Jan 2027 applications). Current members start with renewals due March 2027.",
      "self_attestation_2027": "not published as of 2026-10-20. DoHS checks the data it holds; if it needs more, it may ask for pay stubs, hours records or a volunteer list with a verifier contact, due within 30 days. Not from the agency: KFF (March 2026) lists WV as planning self-attestation for frailty if allowed. A 2026 bill, HB 5645 (work requirements), was introduced; its status was not verified and no law barring attestation was confirmed.",
      "lookback_months": "Application: the 1 month before applying. Renewal: all or part of at least 1 month since the last renewal. Inmate exception: the 3 months before application or renewal.",
      "renewal_frequency": "6 months for some members beginning January 2027.",
      "frailty_method": "Agency lists frail conditions (serious or complex conditions requiring regular care, disabling mental health conditions, etc.) but no identification method. Not from the agency, per KFF, March 2026: planned sources are claims, data match with other programs, treating-provider confirmation, self-attestation and a screener.",
      "member_page_url": "https://wvmedicaidhelp.org/",
      "sources": [
        "https://bms.wv.gov/new-medicaid-rules-are-coming"
      ],
      "quotes": [
        {
          "quote": "The new requirements will not apply to current Medicaid members until their regularly scheduled renewal in 2027, beginning with those due in March 2027.",
          "url": "https://bms.wv.gov/new-medicaid-rules-are-coming"
        },
        {
          "quote": "Beginning in January 2027, renewals for some members will be scheduled more often – every six months rather than every 12 months.",
          "url": "https://wvmedicaidhelp.org/"
        },
        {
          "quote": "If you are not contacted, you do not need to send anything.",
          "url": "https://wvmedicaidhelp.org/"
        }
      ],
      "unknowns": [
        "2027 self-attestation policy",
        "Frailty method and list",
        "CMS tier adoption",
        "Whether any WV statute constrains attestation"
      ],
      "source_tier": "agency",
      "checked": "2026-10-20"
    },
    "WY": {
      "name": "Wyoming",
      "not_expansion": "Wyoming did not expand Medicaid to low-income adults. The federal work rule covers the expansion adult group and section 1115 adult demonstrations, so most people on Medicaid in Wyoming (children, parents, pregnancy, disability, older adults) are not subject to it. If a letter about work hours comes anyway, answer it by its date.",
      "sources": [
        "https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/"
      ],
      "checked": "2026-10-20"
    }
  }
}
