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Hey friends, Nebraska Expansion Medicaid enrollees who miss 80 hours of work, school, or service during a qualifying month start losing coverage August 1, 2026. Somebody wrote that rule, and it wasn't a caseworker, a doctor, or anyone who's ever filled out a Medicaid renewal form. Today's issue is H.R. 1, the law that added work requirements to Medicaid, and Nebraska, the state that volunteered to enforce it early. By the end you'll know exactly how the rule works, why Congress passed it, who has to prove it, who's exempt, how to actually prove your hours, when it reaches the rest of the country, and why a patient, a doctor, a rural hospital, an RCM team, and a state agency each have a different stake in the same 80 hours - Tania

Hey there, We’re Shivang & Tania. Each week, we write in plain English (and some sass) about how health insurance works, why claims get denied, and how patients and healthcare teams can get paid or reimbursed. If you’re new here, we recommend you start with RCM 101: How Healthcare Gets Paid, Eventually, Maybe

TL;DR

Last year, Congress added a new condition to Medicaid coverage for certain low-income adults: work, study, train, or volunteer for at least 80 hours per month, unless exempt. Nebraska became the first state to put the rule into effect.

A short pre-read before you dive in

Medicaid is a health insurance program jointly funded by the federal government and the states for people with limited income, including children, pregnant people, older adults, and people with disabilities. Under one name, it covers several very different groups.

H.R. 1, formally called the One Big Beautiful Bill Act, was a sweeping tax and spending law signed in July 2025. It extended major tax cuts while reducing federal spending across programs including Medicaid. One of its largest Medicaid savings came from a new work requirement. Supporters argued that certain adults should work, study, train, or volunteer to receive coverage, allowing Medicaid to focus its resources on people who cannot work. The Congressional Budget Office estimates that this provision will reduce federal deficits by $317 billion through 2034.

Now, the meaty stuff, what the rule actually says

Put simply: Nebraska now requires certain adults on expansion Medicaid to show one qualifying month of 80 hours work, school, training, volunteering, sufficient earnings, or an exemption when they apply for or renew coverage. Nebraska DHS explains the rule here.

This does not apply to everyone on Medicaid. It applies to Nebraska’s expansion group, called Heritage Health Adult: generally adults ages 19 to 64 with income up to 138% of the federal poverty level. Children, older adults, pregnant people, people covered based on a disability, and other traditional Medicaid populations are not subject to this requirement.

Even within the expansion group, many people are exempt. That includes certain caregivers, people who are medically frail, some former foster youth, tribal members, totally disabled veterans, and people meeting certain SNAP or TANF requirements.

For existing members, Nebraska looks for at least one qualifying month since their last renewal, not 80 hours in every month. For new applicants, the state generally looks at the month before they apply.

Nebraska began applying the rule to new applicants on May 1, 2026. Existing members are checked when their coverage renews, with the first affected coverage periods ending July 31. The rollout continues renewal by renewal through June 2027. DHHS checks its own records first and only asks members for additional information when it cannot verify compliance or an exemption.

Why did Congress do this

Congress’s case for the rule had two parts: changing behavior and saving money.

In H.R. 1, of everything changed in Medicaid, work requirements are projected to save the most money: the Congressional Budget Office estimates they'll cut federal Medicaid spending by $326 billion over ten years, the single largest piece of the law's total Medicaid cuts.

Supporters argue that Medicaid should prioritize people who cannot work while encouraging other adults to work, study, train, or contribute to their communities. Nebraska Governor Jim Pillen has said employment provides purpose, builds independence, and makes people more active members of their communities. He has described the policy as “a hand up, not a handout.” Nebraska’s official announcement lays out that argument here.

Critics argue that taking away health coverage is unlikely to make more people work. When Arkansas introduced a similar requirement in 2018, more than 18,000 people lost Medicaid, but researchers found no significant increase in employment, as per New England Journal of Medicine.

The CBO expects the same basic tension nationally: most affected enrollees will already meet the requirement or qualify for an exemption, but millions could still lose coverage. It estimates that 5.3 million more people will be uninsured in 2034 because of the provision, including many who lose coverage because they cannot navigate the new verification process.

That policy debate sounds abstract. Then a letter arrives.

CBO's analysis of an earlier version of the bill projected the rule would mostly cause coverage loss, not new employment, an estimated 4.8 million more people uninsured nationally by 2034. When Arkansas tried a similar rule in 2018, 18,164 people lost coverage in the first year, largely because they didn't know about the requirement or found it too hard to document, not because they weren't working.

Milo gets a letter

Milo, a grey schnauzer in Lincoln, called his best friend Biscuit, a corgi (remember him from Medical billing 101

"Biscuit, I got a letter from the state," Milo said. "I'm on Medicaid through the expansion program. Now, when I renew, Nebraska has to confirm I had at least one qualifying month since my last renewal, or that I’m exempt."

"Since when? And wait, they actually mail you a letter?"

"Yeah, DHHS mailed a notice to every expansion member back in January. Nebraska started with new applicants in May. Existing members are checked when they renew. My coverage ends July 31, so I’m in the first group affected."

"So how do you prove it?"

"First, I don't have to do anything unless DHHS asks. The state checks its own records first, wage data, that kind of thing, and if that's enough, it just sends an approval notice. If it's not enough, it mails me a specific notice asking for more, with a form attached. I've got 30 days to send it back."

"How do you send it back?"

A few ways: log into iServe, Nebraska's online portal, and upload it there. Or scan the QR code printed right on the notice. Or mail it in, call it in, or walk it into a local DHHS office. For a job, pay stubs or wage records usually cover it. For school, training, volunteering, or caregiving, I fill out a form called the Declaration Form and send that instead."

"What if you miss the 30 days?"

"Then I lose coverage, and have to reapply and prove compliance all over again to get back on."

When this reaches other states

Nebraska was first, but other states are already moving.

Montana launched its requirements on July 1, 2026. However, July through September is a hold-harmless period: the state checks compliance but does not deny or end coverage for failing the requirement. But, the catch is Montana requires 80 hours every single month, unless the person qualifies for an exemption. Those consequences begin in October. Montana explains its rollout here.

Arkansas also began a “soft” launch on July 1. It is checking who meets the requirement or qualifies for an exemption, but no penalties will apply until January 1, 2027. Arkansas DHS explains the soft launch here.

Iowa follows on December 1, 2026, but only for people applying on or after that date. Existing Iowa Health and Wellness Plan members begin facing the requirement at renewals scheduled for February 2027 or later. Iowa HHS provides the timeline here.

Georgia already operates a separate work requirement through its Pathways to Coverage waiver. That waiver expires on December 31, 2026, just as the new nationwide federal requirement takes effect. CMS lists Georgia’s waiver dates here.

For every other state and D.C. that covers the affected Medicaid expansion population, the requirement must be implemented no later than January 1, 2027. CMS issued the implementation details through an interim final rule in June 2026. The federal rule is available here.

Nebraska, by the numbers

About 112,600 Nebraskans are enrolled in expansion Medicaid, out of 338,000 total Medicaid enrollees statewide. Nebraska's DHHS estimates 60 to 72 percent of expansion enrollees already meet the requirement, either because they're working, in school, or otherwise exempt. The Center on Budget and Policy Priorities, a nonpartisan research group, estimates 28,000 to 41,000 Nebraskans are at risk of losing coverage, and stresses that risk is driven mostly by paperwork and reporting burden, not by people failing to work.

About 112,600 Nebraskans are enrolled in expansion Medicaid, out of 338,000 total Medicaid enrollees statewide. Nebraska's DHHS estimates 60 to 72 percent of expansion enrollees already meet the requirement, either because they're working, in school, or otherwise exempt. The Center on Budget and Policy Priorities, a nonpartisan research group, estimates 28,000 to 41,000 Nebraskans are at risk of losing coverage, and stresses that risk is driven mostly by paperwork and reporting burden, not by people failing to work.

What to do, by your role

  • Patients on Nebraska expansion Medicaid: Log into iServe and check two things: your renewal date and whether your address and contact information are current. Then identify the qualifying month since your last renewal when you worked 80 hours, earned at least $580, attended school, trained, volunteered, or qualified for an exemption. Do not send documents in advance. DHHS checks its records first; if it needs more information, it will send you a notice and the appropriate form. Return it within 30 days to avoid losing coverage. If you live outside Nebraska, check your state Medicaid agency because its timeline and reporting rules may be different.

  • Providers and labs: Verify active Medicaid eligibility when care or testing is scheduled and again on the date of service or specimen collection. Prior authorization is not proof of eligibility and will not protect a claim if the patient is ineligible on that date. If a renewal is pending or coverage is unclear, make sure frontline staff know where to send the patient for help before the issue becomes an unpaid claim.

  • RCM teams: Maintain a state-by-state tracker with implementation dates, affected populations, exemptions, qualifying periods, required forms, and response deadlines. Check eligibility on the date of service, save the eligibility response with the account, and report eligibility denials separately from authorization and medical-necessity denials. Beginning with renewals scheduled on or after January 1, 2027, most expansion adults will move to six-month eligibility periods. A separate H.R. 1 provision will also limit retroactive coverage for new adult-group applicants to no more than one month before the application month, leaving less time to fix eligibility after care has been provided.

  • CFOs and market access leads: Use Nebraska as an early case study, not a template; Montana’s monthly requirement already shows how differently states can apply the federal rule. CFOs should calculate how much revenue depends on expansion Medicaid and establish a baseline for eligibility denials, unpaid claims, financial assistance, and uncompensated care. Market access teams should map each state’s rollout and identify which services and patient groups face the greatest access risk. Decide in advance what increase in denials or unpaid care would justify more eligibility checks, patient navigation, or financial assistance as the January 1, 2027 federal deadline reaches other states.

That's issue 15

If you're on Nebraska Medicaid, or you bill someone who is, save this one, your renewal date is the only deadline that matters. We'll keep tracking Montana, Iowa, Arkansas, and Georgia as they hit their own dates.

That's it for this issue. Hit reply. I read everything.

Sources

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