New federal rules for Medicaid: Here’s what’s changing in Michigan

For some recipients, new rules will mean submitting more paperwork, including proof of employment, to keep Michigan’s Medicaid beginning Jan. 1
Questions linger about who will have to work or somehow be engaged in the community for at least 80 hours a month and who will not
But new federal guidance and a recent update from the state clarified some pieces

Hundreds of thousands of working-age Michiganders will face new paperwork requirements to keep their Medicaid coverage, beginning next year.

But not all Medicaid beneficiaries will need to do so.

Some may be exempted for “medical frailty,” although it’s still unclear how they’ll prove it. Some caregivers will be exempt, too.

And people on a variety of traditional Medicaid programs — rather than expanded Medicaid known as the Healthy Michigan Plan — are not affected. (Here’s a listing of various Michigan Medicaid programs and their eligibility.)

As some details become clearer, here’s what we now know:

Let’s start with the basics

Medicaid beneficiaries 19-64 years old who are part of what’s known as “Medicaid expansion” will be subject to the new work requirements.

In Michigan, those are people who are covered by the Healthy Michigan Plan, which at the end of April covered nearly 700,000 Michiganders.

Related:

If you don’t get insurance through your employer, at the federal marketplace, known as www.healthcare.gov or through Medicare, there’s a good chance you get Medicaid. About 2.7 Michiganders now are covered by traditional Medicaid programs, but about 678,000 are in the expansion part of the program known as Healthy Michigan.

Michiganders receiving Supplemental Security Income (SSI) and Social Security Disability Insurance (SSDI) for disabilities will not face work requirements, according to state officials in a recent briefing for organizations.

Rules are effective Jan. 1, 2027, but renewals — which will now happen twice rather than once a year — will be staggered. A first cohort of Michiganders must submit paperwork by March 31 of next year or lose coverage.

Those who face work requirements must provide proof of “80 hours per month of qualifying activities, such as employment, participation in certain work programs, or community service, or be enrolled in [an] educational program at least half time,” according to the US Centers for Medicare and Medicaid.

What counts toward 80 hours?

You meet work requirements if you earn at least $580 in at least one month during the review period. That includes “all forms of earned income including jobs and self-employment, according to the state.

You can also meet work requirements by completing at least 80 hours of approved activities in one month during the review period.

Approved activities include:

Paid or unpaid employment
Internship or work program
Volunteering or community service
Attending a high school or GED program
Attending a college or vocational program

Are there exceptions?

Some parents, pregnant people and people with disabilities or special circumstances will be exempt.

They include:

Former foster care youth
American Indians and Alaska Natives
Parents, guardians, caretaker relatives or family caregivers of a dependent child 13 years of age and under or a disabled individual;
Veterans with a total disability rating
People who are medically frail or otherwise have special medical needs that significantly impair their ability to comply with the requirement
Members of households receiving Supplemental Nutrition Assistance Program who are already subject to work requirements
Participants in a drug or alcohol rehabilitation or treatment program;
Inmates of a public institution
People who are pregnant or eligible for postpartum coverage

Who can help me sort through this?

Navigating the changes can be confusing.

Staff at community health centers, social services offices and others may be able to answer questions eventually, but several told Bridge Michigan there are too many unanswered questions still.

The state eventually also will add staff. Lawmakers earlier this month budgeted for an additional 421 state workers to assist beneficiaries, train community organizers and manage the new processes. Whether it’s enough is not clear; the Whitmer administration had asked for nearly 600.

woman works at a computer — Angélica Garcia is the outreach coordinator at Ypsilanti-based Washtenaw Health Project, which helps consumers connect to insurance and health care. She says those who visit often haven’t opened their mail, which includes important insurance information. That’s an easy way to lose coverage, she and others warn. (Robin Erb/Bridge Michigan)

Meanwhile, advocates say beneficiaries should open all letters from the state, set up an online MiBridges account if they haven’t already and make sure their Medicaid profile includes a current mailing address. (If not, look for the “Report changes” button on your MIBridges portal.)

It’s important to know that updating addresses through your doctor or other state websites will not update your address for Medicaid.

What about immigrants?

Certain non-citizens also face changes.

The following people will continue to be covered by full Medicaid if they meet all other eligibility provisions:

Lawful permanent residents after the 5-year waiting period
Cuban/Haitian entrants
Migrants who fall under the Compacts of Free Association

Beginning Oct. 1, 2026, other non-citizens will be moved to coverage for emergency services only, which includes treatment for an emergency medical condition that has severe symptoms requiring immediate medical attention.

Emergency-only coverage excludes routine doctor visits, preventive care, ongoing treatment for chronic conditions, most prescription medications and non-emergency procedures.

The changes are the result of the 2025 budget reconciliation bill — the “One, Big Beautiful Bill,” as it’s known — that was signed into law on July 4, 2025.

How will I know if I’m required to meet new eligibility rules?

While nearly 700,000 Michiganders will be reviewed under the new requirements, many won’t have to do anything at all.

The good news: The state will first cross-reference other state files to automatically re-enroll some beneficiaries, including those who already have proven they meet work requirements or are exempt from them, for SNAP food assistance, for example. Those people — and it’s not how many of them there are — will be exempted from the extra paperwork.

Jeremy Lapedis, executive director of the Ypsilanti-based Washtenaw Health Project, which helps consumers connect to insurance and health care, worries about an onslaught of consumer questions when work requirements are effective next year. (Robin Erb/Bridge Michigan)

And just because you have Medicaid doesn’t mean you’re one of the 700,000.

An additional 1.8 million Michiganders are on traditional Medicaid, which generally covers people who are pregnant, disabled or very low-income.

However, some beneficiaries don’t realize their Blue Cross Blue Shield of Michigan or Priority insurance card is actually Medicaid. (Generally speaking, most people in Michigan with insurance get it through their employer, though the federal marketplace at healthcare.gov or though Medicare.)

Others don’t know if they are enrolled in traditional Medicaid, which covers pregnant women or those with certain disabilities, or the Healthy Michigan Plan, which in general covers healthy adults up to 138% of the federal poverty level — about $22,024.80 for an individual or $45,540.00 for a family of four this year.

What counts as a ‘medical frailty?’

The new rules allow people living with disabilities and chronic illness to be exempted from challenging work reporting requirements and stay enrolled in Medicaid.

But just how that will be defined — or how those frailties will be proven — is still being nailed down.

For example, the new rules allow exemptions for people with “a disabling mental disorder” or anyone with “serious or complex medical conditions,” according to a summary by the American Medical Association.

But it’s not clear what will qualify as “disabling” or “complex” enough.

The state awaits more guidance.

My Medicaid is currently lapsed. Can’t I just wait and renew it when I need it?

Big mistake, advocates say. The new rules won’t be as forgiving if your coverage has lapsed.

As it stands now, a person applying for Medicaid may get retroactive coverage for 90 days. That means once you renew it, Medicaid might still cover an emergency room visit in May for someone who just now in July gets approved for Medicaid.

But under the new rules, that retroactivity in the Healthy Michigan Plan only goes back just 30 days — not enough time, in many cases, to apply and be approved for coverage for an accident that happened just last month.

Where do I get more information?

If the state has your most updated mailing address, you should receive notices if you may have to comply with work requirements or prove you qualify for an exemption.

Additionally, the Michigan Department of Health and Human Services has created this webpage to update residents of the coming changes. Representatives also offered a webinar last month for organizations.

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