H.R. 1 One Big Beautiful Bill Act (OB3)
Medicaid eligibility and community engagement requirements are changing in 2027.
Beginning January 1, 2027, certain Medicaid members may need to complete eligibility-related actions, respond to requests for information, and meet applicable Community Engagement requirements to maintain coverage. Requirements, exemptions, and implementation processes will vary by state.
Who may be impacted?
Community Engagement requirements generally apply to certain adults ages 19 through 64 enrolled in the Affordable Care Act Medicaid Expansion population or certain Medicaid waiver programs that provide minimum essential coverage. Some individuals may qualify for an exception or exclusion based on federal and state criteria.
What are Community Engagement requirements?
Impacted members may satisfy the federal requirement through monthly earnings of at least $580 (described in the provider materials as equivalent to 80 hours at the federal minimum wage), or by completing at least 80 hours per month of qualifying activities. Examples include work, approved employment or training programs, qualifying education, community service, or a combination of qualifying activities.
How this affects members
Affected members who fail to respond to notices or complete required actions by applicable deadlines may risk an interruption in coverage or loss of eligibility. Routine eligibility verification can help identify changes earlier, reduce avoidable claim denials, and support continuity of care.
What providers can do now
Verify eligibility before every visit.
Providers can also help their patients by:
- Encouraging them to open and respond promptly to Medicaid communications.
- Making sure their contact information is current.
- Reminding them to retain applicable eligibility or Community Engagement documentation.
- Advising them to complete requested actions by stated deadlines.
- Directing eligibility and reporting questions to the appropriate state Medicaid agency or Member Services.
Review Standard Federal Exemptions
While some specific definitions may vary by state, the following exemptions are available to members affected by H.R. 1.
| Exemption Criteria | Exemption Details |
|---|---|
| Pregnant or postpartum | Exempt during pregnancy and for a set time after birth. |
| Disabled or blind | Meets Medicaid or SSI disability rules. |
| Medically frail | Has a condition that seriously limits their ability to work. |
| Caregiver | Cares for a child 13 years of age or younger, or a family member with a disability. |
| Tribal member | Enrolled in a federally recognized tribe, or eligible for Indian Health Service care. |
| Veteran with total disability | Has a full disability rating from the VA. |
| Already meeting SNAP or TANF work rules | Member hours count toward both programs. |
| Student | Enrolled at least half-time in school or job training. |
Review state resources
Implementation will vary by state. Providers should continue monitoring state Medicaid announcements, health plan communications, provider newsletters, and provider portals for additional guidance, including: