As Virginia prepares for sweeping changes to its Medicaid program, state officials say hundreds of thousands of Medicaid expansion enrollees could be at risk under new federal eligibility and work requirements taking effect next year.
The changes, required under federal law, will affect adults ages 19 to 64 enrolled through Medicaid expansion and include new work requirements, six-month eligibility renewals and tighter rules around retroactive coverage.
State officials said during a meeting with legislators on Wednesday that roughly 300,000 of 550,000 Virginians who used Medicaid expansion could be at risk. However, they emphasized that this figure does not mean that many people will lose coverage. Rather, it represents people for whom the state currently lacks enough information to determine whether they qualify for an exemption from the new requirements.
The work requirements take effect Jan. 1, 2027, although current Medicaid expansion enrollees will transition to the new rules when their existing eligibility periods expire.
Under the new system, people will generally need to qualify for an exemption or complete a qualifying activity to remain eligible. Qualifying activities include paid work, certain volunteer work, education and job training.
People can also meet the requirement by having at least $580 in monthly household income used for their Medicaid eligibility determination.
The requirement does not mean enrollees will have to document 80 hours of work every month. At renewal, the state will look back over the previous six months and generally require the person to have met the requirement during at least one month.
There are several exemptions, including for pregnant people, certain former foster youth, some caregivers, certain veterans and people who are medically frail.
The state initially estimated that about 300,000 Medicaid expansion members could qualify for an exemption based on medical information already available to the state. But after federal officials issued guidance narrowing the definition of “medically frail,” that estimate fell to about 170,000.
The narrower federal definition requires that a medical condition also affect a person’s ability to work or participate in another qualifying activity.
Virginia and 24 other states have sued over the federal rules. The lawsuit remains pending, but Virginia officials said they are moving forward with implementation because there is currently no injunction blocking the requirements.
The changes will also move Medicaid expansion recipients from annual eligibility renewals to renewals every six months.
New applicants who are found eligible beginning Jan. 1 will receive six months of eligibility. Current enrollees will continue under their existing 12-month eligibility period until their next scheduled renewal, at which point the new rules will apply.
Virginia is also reducing retroactive Medicaid coverage.
Beginning Jan. 1, Medicaid expansion adults will be eligible for up to one month of retroactive coverage, down from three months. Other Medicaid populations will see retroactive coverage reduced from three months to two months.
The state is attempting to limit the administrative burden by using existing electronic records to identify people who qualify for exemptions or meet the requirements.
For example, officials said someone already receiving Social Security disability income could potentially be identified through state records as meeting a disability-related exemption without having to submit additional documentation.
For 2027, federal officials are also allowing states to accept self-attestation from Medicaid recipients regarding qualifying activities and exemptions. More verification requirements are expected to take effect in 2028.
State officials acknowledged that the impact of the new requirements remains uncertain.
They said states that implemented Medicaid work requirements in 2019 experienced significant coverage losses, although not all of those losses were because people were no longer eligible. Some people lost coverage because they failed to complete administrative requirements or provide required documentation.
Virginia is conducting outreach through community organizations, health care providers, navigators and application assisters as it prepares for the changes.
Officials also said the state is working with workforce development agencies to connect Medicaid recipients with employment and training programs.
The state has created additional online resources and is holding town halls and other outreach events to explain the new rules to Medicaid recipients and community organizations.
The Office of the Secretary of Health and Human Resources has established a dashboard showing how localities could potentially be impacted by these changes.
The changes could potentially impact 15,261 people in Richmond City, 13,617 people in Virginia Beach, 1,078 people in Scott County, 2,333 people in Augusta County, 7,185 people in Loudoun County, and 1,567 people in Accomack County.