Medicaid Work Requirements

With the introduction of H.R. 1, aka One Big Beautiful Bill (OBBB), Medicaid eligibility will require low income adults without disabilities to work, or participate in qualifying activities for 80 hours a month. Prime Health’s goal is to aid in keeping as many members covered as possible, and aid in the development of a work requirements tracking system.

What work is Prime Health doing around the Medicaid Work Requirements?

Prime Health is working to help develop recommendations from public stakeholders including Medicaid users, to inform how a future system for tracking hours towards the Medicaid work requirements might function. Here’s what we’ve done so far:

September 2025: When Policy Moves Fast, We Build Responsibly— Responding to Medicaid Work Requirements with Purpose

October 2025: Insight to Impact: Reflections. Realignment. Readiness for 2026.

What’s next:

Town Halls will be held from February to May, in an effort to determine best practices, group recommendations and considerations.

Medicaid Participatory Action Incubator (PAI) Challenge— this will be a competition held in a similar style to our Innovation Challenge, for tech companies with a system or product that can be used to track Medicaid work requirement hours. More info on this coming soon! Solutions will be informed by the prior discovery process with consistent feedback loops from impacted stakeholder groups.

Following the PAI Challenge, the top solutions will run pilot programs with validator groups.

Why is Prime health doing this work?

The ultimate goal of our work surrounding the Medicaid work requirements is to reduce the burden of Medicaid users and maintain eligibility for as many people as possible through building and executing of a process that utilizes a robust community engagement strategy to develop best practices and informs the building, testing, and vetting of technology solutions for consideration by the state agencies.

Health First Colorado Members
Employers

Get Involved and Learn More

Over the next 5 months, Prime Health will be hosting a series of Town Hall meetings to gather information and data, with the goal of creating guidelines and recommendations for a technology product to be used in the tracking and reporting of work requirements.

Upcoming Town Hall Meetings:

Non Profits: February 25th (virtual) and March 13th (in person)

Education: April 2nd (in person)

Job Training Organizations: March 25th (in person)

Data Validators/Verifiers April 13th (virtual and in person)

Employers: April 22nd (in person)

Supporters and Communicators: May 6th (virtual) and 7th (in person)

Use the links below to learn more about the each Town Hall.

Nonprofits
Education
Data Validators/Verifiers
Job Training Organizations
Technologists
Supporters and Communicators

Key Things We Know

Work (Community Engagement) Requirements will become active in January 2027

Work Requirements will not apply to:

  • Kids under 19 or adults 65 and older

  • Individuals with disabilities or medically frail individuals

  • Native American or Alaskan American residents

  • Pregnant people

  • Parents or caregivers of children ages 13 and under or disabled individuals

  • Veterans with total disability ratings

  • Individuals participating in substance abuse treatment programs

  • Individuals already meeting work requirements for TANF or SNAP

The following are qualifying activities for the work requirements:

  • 80 hours per month of work, community service, and/or “work program” participation

  • Enrolled in education at least half of time

  • Any combination of minimum wage multiplied by 80 hours

  • Seasonal workers with an average monthly income over 6 months of minimum wage multiplied by 80 hours

Hardship exceptions will be available (this is outside of Prime Health’s scope or work and will be handled by the State)

Check out our resources below to learn more.

Resources

While there are still many questions about what this will look like, we do have some resources to share.

HCPF

Kaiser Family Foundation

Have any questions that aren’t answered on this page? Please feel free to reach out to us at admin@primehealthco.com

Through a collaborative health innovation ecosystem, we can:

  • clarify common barriers, problems, needs, and shared priorities within the healthcare industry

  • identify companies and healthcare that are pursuing ways to solve those problems

  • validate solutions impactful to Colorado and California healthcare

  • accelerate the adoption of these solutions within safety-net health organizations

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