County, state gear up for Medicaid work requirement

FINDLAY — Starting Jan. 1, new work requirements go into effect for many Medicaid recipients under new federal law. Over the next five months, Hancock County and state leaders are trying to communicate these requirements as best as they can, but many things are still up in the air. H.R. 1, also known as the "One Big Beautiful Act," was signed into law on July 4, 2025. While some provisions went into effect right away, states were given until Jan. 1, 2027 to establish work requirements for the Medicaid expansion population. Medicaid is federally funded but administered by states. The new requirements will apply specifically to those who are enrolled in what Ohio calls Group VIII coverage (also known as MAGI Adult or Ribicoff coverage). These are adults aged 19 through 64 who have Medicaid because their income is at or below 138% of the Federal Poverty Level. The changes do not affect individuals who have Medicaid for reasons other than income, or those who have certain health conditions or meet other exemptions, states an Ohio Department of Medicaid website on the topic. Triena Miller, family assistance and workforce development administrator at Hancock County Job and Family Services, said these individuals will need to demonstrate they are spending 80 hours each month at work or participating in "community engagement." That is, the "work" requirements could include paid work or workforce training, but if someone is in school or struggling to find paid employment, other activities may also count toward the requirement. "That can be employment, that can be volunteering, it can be community service, it can be schooling, a combination of those," Miller said. Approximately 3,300 Hancock County residents are enrolled in Group VIII coverage, she said. State Medicaid officials have calculated that roughly 22% of Group VIII enrollees statewide aren't already fulfilling the requirement or meeting an exemption, leaving about 700 individuals that Miller's team will need to connect with. The Ohio Department of Medicaid will send letters to Group VIII enrollees around mid-August. "And then of course we'll be notified of the people who fall into this category and then we'll do some outreach to say, 'Do you meet any of these criteria?'" Miller said. If they don't, that doesn't mean they will immediately lose coverage. Miller said she and her staff will meet with these individuals and try to determine if they qualify for an exemption. The work requirements do include exemptions, including for pregnant or postpartum women, individuals caring for children under age 13 or a disabled family member, and people considered "medically frail" because of disabilities or serious medical conditions. However, June guidance from the federal Centers of Medicare and Medicaid Services (CMS) defined "medically frail" more strictly than H.R.1 itself had. Under this guidance, the individual must have a "serious or complex medical condition" which must also "significantly impair their ability to comply with the (work) requirement." "When this came out, there was a lot of surprise because it's harsher than it was expected and it's really hard to operationalize," said Brian O'Rourke, healthcare policy analyst at the Health Policy Institute of Ohio. Democratic attorneys general from 25 states and Washington, D.C. sued CMS over the new definition. On Wednesday, U.S. District Judge Richard Stearns denied the states' motion for a preliminary injunction. In 2027, Medicaid recipients will be able to self-attest that they meet the "medically frail" exemption, but, beginning in 2028, states will need to verify that recipients meet the requirement. O'Rourke said states are concerned that it is hard to verify, since whether a person's medical condition means they cannot work may be subjective. Patient advocacy groups such as the American Cancer Society and mental health organizations have raised concerns that it will put more burden on Medicaid enrollees and their healthcare providers, he said. As an example, O'Rourke said a cancer patient might be considered "medically frail" under this definition while actively in the midst of treatment, then might be deemed no longer frail and required to work while between treatments, then might be considered "medically frail" again during the next course of treatment. But it may be a challenge for that person to find employment, knowing they will likely need to quit soon after, he said. He added that primary care providers in rural and underserved areas of the state will also likely need to devote significant time to documenting that their patients meet the exemption. O'Rourke noted that RAND has projected that about 172,000 Ohioans will lose coverage because of the work requirements over time. Statewide, about 700,000 Ohioans are enrolled in Group VIII coverage. Miller said her team has gone through an initial training and expects to go through further training this fall with the Ohio Department of Medicaid. On her end, there remain a lot of unknowns, but she said that is often the case with this type of policy change as it takes time for the specific rules to be worked out. She emphasized that Hancock County JFS wants to work with Medicaid enrollees and help them to comply with the requirements. "If they say they're having trouble obtaining the verification (of an exemption), you know, we can help them," she said. "We can reach out to the doctor's office and see what they might need." She encouraged enrollees to reach out with any questions. A call center is open from 8 a.m. to 4:30 p.m. Monday-Wednesday and from 8 a.m. to 3:30 p.m. on Fridays. The number is 844-640-6446.