Medicaid: New Federal Work Requirement
A new federal Medicaid work requirement will affect some members enrolled in BadgerCare Plus in 2027
Work requirements are coming in early 2027 for some Medicaid members enrolled in BadgerCare Plus. When the new federal law takes effect, some members between 19 and 64 years old will have to work, go to school, or volunteer in order to keep their health care coverage. If you could be affected, we will send you more information in August or September to explain what you’ll need to do.
Background
The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, added several new red-tape requirements, including new federal work requirements to Medicaid. The federal Medicaid work requirement for states will go into effect early next year. Because of the new federal requirements, some adults enrolled in BadgerCare Plus will need to show that they work, go to school, or volunteer, to keep their coverage.
Do I have to meet the new federal Medicaid work requirement? How will I know?
If you are enrolled in BadgerCare Plus and are between 19 and 64 years old, not pregnant, not disabled, and don’t have dependent children under 19 living with you, then you may need to meet the federal work requirement. There are other reasons (work requirement exemptions) why you may not need to meet the work requirement.
If you could be affected by the federal work requirement, we’ll send you a letter in August or September to explain what you need to know and what will happen next.
Does this apply to me?
Use our screening tool to check whether you may have to meet the new federal work requirement.
When does the work requirement start?
- New applicants: January 1, 2027. You must meet the federal work requirement in the month before you submit an application. For example, if you apply for Medicaid in January 2027, you must meet the federal work requirement in December 2026.
- Most current members: March 2027. The earliest you would be affected by the federal work requirement is at your next scheduled health care coverage renewal, beginning in March. You must meet the federal work requirement in one month since you were last approved for health care coverage. For example, if you are due to renew your Medicaid coverage in March 2027, you must meet the federal work requirement in one month between April 2026 and March 2027.
What can I do now?
- Keep your contact information up to date (mailing address, phone, and email address) with your agency.
- Read any notices you get about your BadgerCare Plus coverage in the mail or online.
- Set up an ACCESS account and get the MyACCESS app to see important notices.
- Opt-in to receive texts and emails. Log in to ACCESS (ACCESS in Spanish) and select Update Contact Information.
- Check our Medicaid News webpage for the latest information.
- Continue to use your BadgerCare Plus coverage to get the health care and services you need.
Questions and answers
Exemptions
Yes, under the law passed by Congress and the President, there are some limited exemptions. Exemptions are reasons that the law says people don’t have to meet the federal Medicaid work requirement.
As a reminder, you don’t have to meet the federal work requirement if you are:
- Enrolled in a Medicaid program other than BadgerCare Plus
- Under age 19 or over age 64
- A parent or guardian of a child under age 19 who lives with you at least 40% of the time
- Pregnant or in the 12 months after your pregnancy
- Someone who has been determined to have a disability
You may be exempt from the federal work requirement if you are:
- A veteran with a total disability rating from the U.S. Department of Veterans Affairs
- Enrolled in FoodShare and not exempt from FoodShare work requirements
- Someone with one or more serious medical conditions
- A caregiver of a dependent child 13 years of age and under or of someone with a disability
- Participating in certain drug addiction or alcoholic treatment and rehabilitation programs
- Currently in prison or jail, or were in prison or jail in the past three months
- Someone who was in foster care, subsidized guardianship, or court-ordered kinship care when they turned 18
- A member of an American Indian Tribal nation or an Alaska Native, or the child or grandchild of a Tribal nation member
- Meeting the Wisconsin Works (W-2) work requirements
Also, Wisconsin intends to allow all additional short-term hardship exemptions permitted in federal law. This means you may not have to meet the federal work requirement if you are:
- Receiving inpatient hospital services or certain other types of medical care
- Residing in a county where there is a presidential declaration of a disaster or emergency
- Residing in a county with an unemployment rate over a certain threshold
- Needing to travel outside of your community for an extended time period to get treatment for yourself or for a dependent
Homelessness was not included in the One Big Beautiful Bill Act (OBBBA) as a reason that someone can be exempt from the work requirement. States are not allowed to add exemptions beyond what is established in federal law. If you are homeless you will still need to meet the work requirement unless you have an exemption.
Disability and medical exemptions
No. If you have a disability determination from the Social Security Administration (SSA), that is an exemption from the work requirement. This exemption will be applied automatically, without action from a member, because we will already have that information on file. You do not have to get another disability determination.
Maybe. There are a few different ways in which someone who is waiting on a disability determination still might be able to get an exemption. If you are already enrolled in a Wisconsin Medicaid long-term care program like Family Care or IRIS, we will automatically exempt you. If you aren’t enrolled in a Medicaid long-term care program, then another possibility would be to get an exemption based on having a serious or complex medical condition.
No. If someone is getting Supplemental Security Income (SSI), it means they are not subject to the work requirement.
No. Members enrolled in a Medicaid long-term care program (IRIS, Family Care, Family Care Partnership, PACE) do not have to meet the work requirement. They will automatically be exempt based on their enrollment in a long-term care program. They do not need to have a disability determination from the Social Security Administration.
No. Someone who has a serious or complex medical condition does not need a disability determination to qualify for an exemption.
Activities that meet the work requirement
If you are not exempt, to meet the federal work requirement, you can work, volunteer, participate in a work program, and/or participate in an education program.
- If you are a current BadgerCare Plus member, you must meet the requirement in one month since you were last approved for health care coverage.
- New applicants must meet the requirement in the month before you submit an application.
You can also meet the requirement if you were enrolled in school at least half time or have monthly income of at least $580 (the federal minimum wage x 80 hours) in one month since you were last approved for coverage (for current members) or in the month before you submit an application (for new applicants).
If you are getting paid to do work, we would consider it to be employment, however, you don’t need to be paid money for your work to count. Work could also be in exchange for goods or services. We call this in-kind work. You can also be doing unpaid work, such as an internship. You can also meet the work requirement through work programs, volunteering, and education.
No. Getting unemployment compensation was not included in the One Big Beautiful Bill Act as a reason that someone can be exempt from the work requirement. However, someone can meet the work requirement by having $580 in income in a month, and unemployment compensation counts as income. So, if you got at least $580 in unemployment compensation in a month, or in unemployment plus other sources of income, that would meet the work requirement.
Timing for meeting work requirements
No, you do not need to meet it every month.
For new applicants, we will look back at the month prior to the month of application to see if the person met the work requirement or was exempt.
For current members, we will check when they complete their annual renewal. At that time, we will look back and see if they were exempt or met the work requirement for one month since they were last approved (at renewal or application) for coverage, which in most cases will be the last 12 months.
For new applicants, we will look back at the month prior to the month of application to see if the person was exempt or was meeting the work requirement.
For current members, we will look back and see if they were exempt or were meeting the work requirement for one month since they were last approved (at renewal or application) for coverage, which in most cases will be the last 12 months.
It depends. For new applicants, we would look at the month before the month they applied to see if they met the work requirement or were exempt. For current members, we will look back and see if they were exempt or met the work requirement for one month since they were last approved (at renewal or application) for coverage, which in most cases will be the last 12 months.
No. We will check for compliance or an exemption when someone first applies and then we'll check annually at renewal.
For parents or guardians
Maybe. Under the federal law, you may have to meet the federal work requirement if you are a BadgerCare Plus member and if your children are 19 or older or if your children do not live with you at least 40% of the time.
If your children/dependent(s) are under age 19 and live with you at least 40% of the time, you are considered a parent/guardian. You would then not be subject to the work requirement.
Losing health care coverage
If someone is a current member, is not exempt, and does not meet the work requirement, at renewal their benefits will end with advance notice. If an applicant does not have an exemption or does not meet the work requirement, their application will be denied.
No. Members can reapply at any time, and if they meet the program's rules, can gain eligibility at any time.
Someone who is unable to get Medicaid because they didn’t meet the work requirement can apply for health care coverage via the federal Marketplace, however, they will not qualify for Advance Premium Tax Credits. This restriction is part of the One Big Beautiful Bill Act.