OKPOLICY.ORG
The Oklahoma Health Care Authority (OHCA) recently used a letter written on yellow paper to begin notifying certain SoonerCare (Medicaid) members to begin preparing for new federal work requirements that could impact their coverage beginning January 1, 2027. SoonerCare is Oklahoma’s Medicaid program.
The federal 2025 budget reconciliation bill, known formally as H.R. 1 or more commonly referred to as The One Big Beautiful Bill Act (OBBBA), added the work requirements for Medicaid enrollees who became eligible with passage of the Affordable Care Act (ACA), otherwise known as Obamacare.
An important part of the ACA was expanding Medicaid coverage to previously uncovered low-income adults between the ages of 19 and 64. Previously, only financially qualified children, pregnant women, parents or caretakers of children under 19, and aged (65 and over) and disabled persons were eligible for Medicaid coverage.
The ACA expanded Medicaid eligibility to financially qualified adults ages 19 to 64 and made substance use disorder services one of ten essential health benefits. This marked one of the largest expansions of mental health and substance use disorder coverage in a generation; previously, states had to fund substance use disorder treatment on their own.
However, Congress made Medicaid expansion voluntary for states. To incentivize states to adopt the program, the federal government pays 90% of the cost for the expansion population — a higher match rate than it provides for other Medicaid groups. Despite the favorable match rate and substance use disorder coverage, Oklahoma failed to expand Medicaid for an entire decade after passage of the ACA.
After circulation of a citizen initiative petition that resulted in the passage of State Question 802 — despite opposition from Gov. Kevin Stitt — coverage for low-income adults aged 19-64 whose income is at or below 138% of the federal poverty level was added to the constitution and took effect on July 1, 2021.
Some people never liked the ACA. Congressional opponents have tried to repeal or limit its provisions for years, and they finally were able to take a major step with the work requirements and more frequent eligibility checks in the OBBBA.
The yellow letter is just the beginning of an expensive bureaucratic process that is predicted to reduce Medicaid enrollment by millions nationally, with coverage losses often resulting from administrative and documentation challenges rather than the increased employment requirements.
To remain eligible, adults must complete 80 hours per month of approved activities, which can include paid employment, volunteering or community service, participation in job training or work programs, enrollment in school at least half-time, or earnings equivalent to 80 hours at the federal minimum wage (approximately $580/month in 2026). Hours from multiple activities can be combined to meet the monthly threshold.
States must eventually require proof of monthly activities. Initially, self-attestation may be accepted if reliable electronic data is unavailable, but by January 1, 2028, documentation will generally be required. Eligibility redeterminations for the expansion population will occur every six months instead of annually.
If a beneficiary cannot provide verification, states must give 30 days to submit evidence or claim an exemption. Failure to comply may result in disenrollment, requiring reapplication once proper documentation is provided.
This is the kind of recordkeeping and reporting that businesses often hire and train clerical workers to accomplish. Imagine the burden on individuals struggling financially and potentially with healthcare challenges.
OHCA should do all it can to help Oklahomans keep up with and fulfill the arduous reporting requirements necessary to continue their healthcare coverage. Whether it does or not will depend on whether Oklahoma’s political leadership is more interested in saving money by removing people from Medicaid or in providing healthcare for its citizens.
And saving money is likely a delusion because Oklahoma’s medical providers and hospitals will eventually pay the price with uncompensated emergency room care.
