Medicaid Six-Month Renewals and Work Requirements: What Changes for Health Centers in 2027

Updated November 4, 2026, based on CMS and state Medicaid agencies as of that date.

Starting in 2027, adults in the Medicaid expansion group renew their coverage every six months instead of once a year. Most of those adults aged 19 to 64 must also show 80 hours a month of work, school, or community service, or qualify for an exemption. Both changes come from H.R. 1, which CMS calls the "Working Families Tax Cut" legislation, and both take effect in January 2027.

For a health center, the two changes land on the same patients. The expansion group is low-income adults, and the same person can face a renewal, a work requirement check, and a 30-day notice in the same season. States are publishing their own plans now, and the details differ in ways that change when your patients' first deadlines fall.

This guide covers what federal law requires, how states are moving current enrollees onto the new schedule, and what health center staff can do before the first renewals go out. For how a specific state is handling it, see the state list below.

Who the changes apply to

Six-month renewals apply to adults enrolled in the Medicaid expansion group, and to people covered through a section 1115 demonstration that covers everyone in that group. CMS's guidance on section 71107 exempts certain American Indians and Alaska Natives. It also leaves other groups on their current schedules: children, pregnant people, people eligible through other income-based groups, and people eligible because of age or disability.

Work requirements apply to a narrower slice of the same group. CMS's interim final rule covers non-pregnant adults aged 19 to 64 who aren't enrolled in Medicare. A patient can be exempt from work requirements and still be on six-month renewals.

What states must still do at every renewal

The renewal steps stay the same and happen twice as often. Under the federal rules CMS restates in its guidance, a state must:

1. Try to renew the person from information it already has, without contacting them (an ex parte renewal).
2. If that fails, send a renewal form filled in with what the state knows.
3. Give the person at least 30 days to return the form and anything else it asks for.
4. Check every other way the person might qualify before finding them ineligible.
5. Give at least 10 days' notice, with fair hearing rights, before ending coverage.

People who newly enroll in the expansion group with coverage starting on or after January 1, 2027 get a six-month eligibility period from the start. Household members can end up on different schedules, because a parent in the expansion group renews every six months while a child renews every 12. CMS says states can't shorten or stretch anyone's period to line them up.

How current enrollees move to six months

People already enrolled on January 1, 2027 have 12-month periods with renewals already scheduled. CMS gives states two ways to move them over:

• Option 1: reschedule. The state pulls 2027 renewals forward so people reach a six-month cycle as soon as possible. CMS notes this means starting a large number of renewals as early as January 1, 2027.
• Option 2: switch at the next renewal. The state keeps each person's existing renewal date, then grants six months after it. CMS says this avoids a cluster of renewals in January 2027 and keeps the workload more even.

The difference matters for planning. Under option 1, a patient enrolled in May 2026 could be renewed in early 2027. Under option 2, the same patient renews on their normal date and only then moves to six months.

Ten states with many health center patients on Medicaid have published their plans:

• New York: Option 2. People renewing before March 1, 2027 get 12 more months, then move to six. (NY State of Health)
• Massachusetts: Members aren't affected until their first renewal of 2027; MassHealth tries automatic renewal first. (MassHealth)
• California: Option 2. Counties start moving members to six months with renewals due in March 2027; January and February 2027 renewals get one more 12-month period. (DHCS ACWDL 26-14)
• Washington: Coverage periods change to six months at each person's first renewal in 2027. (HCA)
• Illinois: Six-month redeterminations start in 2027, and work requirements apply at each person's first redetermination in 2027. (HFS member notice)
• Ohio: Renewals initiated on or after January 1, 2027, starting with March 2027 due dates, are approved for six months. (ODM partner packet)
• Pennsylvania: Renewals due September 2026 through January 2027 follow the old rules. Renewals due February 2027 or later move to six months. (DHS briefing)
• Missouri: Requirements start January 1, 2027; adults need one qualifying month in each six-month renewal period. (DSS FAQ)
• Michigan: Six-month renewals start January 1, 2027. Work requirements apply to current members with renewal dates on or after March 1, 2027. (MDHHS)
• Indiana: Work requirements apply to redeterminations initiated on or after January 1, 2027, though a sample notice uses April 1, 2027. (FSSA)

Check your state's Medicaid agency for updates. Several of these documents are labeled draft or preliminary.

How work requirements work

A person meets the requirement for a month with any of these, alone or combined, per CMS's interim final rule:

• 80 hours of work, community service, or a work program
• Enrollment in school at least half time
• Monthly income of at least the federal minimum wage times 80 hours ($580 a month in 2026)

Applicants must meet it for at least one month, and states may require up to three consecutive months, before the month they apply. Current enrollees must meet it for at least one month between renewals. States may check more often.

The CMS summary of the law says states must use data they already have where possible, so people don't have to submit proof. When the state can't verify compliance, it must send a notice and give the person 30 calendar days to show compliance or an exemption. If they don't, and they have no other basis for coverage, the state denies the application or ends coverage by the end of the following month. A person who loses coverage can reapply at any time.

Mandatory exemptions include:

• Parents and caretakers of a child 13 or under or of a disabled person
• Medically frail people
• Pregnant and postpartum people
• People in drug or alcohol treatment
• Veterans with a total disability rating
• Former foster youth, and American Indians and Alaska Natives
• People meeting TANF or SNAP work rules

States may also excuse people for short-term hardships, such as a hospital stay or living in a county with high unemployment.

A state can ask to delay work requirements by showing a good-faith effort to comply, but any exemption ends by December 31, 2028. None of the ten states above says it has requested one.

Other changes that affect billing

Two smaller provisions change what a health center can bill, according to the CMS summary:

• Retroactive coverage gets shorter. For applications made on or after January 1, 2027, coverage for expansion adults can reach back only one month before the month of application, down from up to three. For everyone else it reaches back two months. A patient who applies after a visit may no longer have that visit covered.
• Cost sharing starts in October 2028. States must charge expansion adults above 100% of the federal poverty level up to $35 per service. FQHC, rural health clinic, primary care, and behavioral health services are exempt.

What health centers can do now

The first six-month renewals arrive in early 2027 in most states. Steps a health center can take now:

1. Find your expansion adults. They're the patients on six-month renewals and, in most cases, work requirements.
2. Learn each patient's renewal date, from the state's portal or the patient's renewal notice, so outreach starts before the form arrives.
3. Watch for state outreach. States must tell enrollees about work requirements before they start, and several have already mailed notices.
4. Plan for the 30-day notices. A patient who gets a noncompliance notice has 30 days to respond. Enrollment staff who know about it early can help with exemption paperwork.
5. Check presumptive eligibility changes. Some states are adding work requirement questions for providers who do presumptive eligibility.
6. Use your state's partner materials. Several state agencies run webinars and publish toolkits for providers.

Options for the added volume include more enrollment staff, renewal reports from managed care plans where they offer them, and automation for the portal checks and reminder calls.

Frequently asked questions

When do Medicaid six-month renewals start?

They apply to expansion adults for renewals scheduled on or after January 1, 2027, and to new enrollees whose coverage starts on or after that date. When a current enrollee first moves to six months depends on whether their state chose CMS's option 1 or option 2.

Who is exempt from Medicaid work requirements?

The mandatory exemptions include parents and caretakers of a child 13 or under or of a disabled person, medically frail people, pregnant and postpartum people, and people in drug or alcohol treatment. Veterans with a total disability rating, former foster youth, American Indians and Alaska Natives, and people meeting SNAP or TANF work rules are exempt too. States can add short-term hardship exemptions.

Do six-month renewals apply to children or older adults?

No. They apply only to the expansion adult group. Children, pregnant people, and people eligible because of age or disability keep their current schedules, even when a parent in the same household moves to six months.

Can a state delay work requirements?

A state can request an exemption by showing a good-faith effort to comply, but it must end by December 31, 2028. Six-month renewals have no such option.

What happens if a patient misses a work requirement notice?

If the state can't verify compliance, it sends a notice and allows 30 days to respond. Without a response, and without another basis for coverage, the state ends coverage by the end of the following month. The patient can reapply at any time, but under the new rules retroactive coverage reaches back only one month.

Keeping track of renewal dates across your Medicaid patients?

Champ automates portal work like eligibility checks. We set it up and run it, so your staff sees only the finished results, and we can handle the patient outreach too. If six-month renewals will mean more coverage checks for your health center, learn more here.

This post is general information, not legal, compliance or billing advice. Medicaid rules vary by state and change often, so confirm with your state Medicaid agency before acting. Champ is not affiliated with or endorsed by any state agency or CMS.