By Joanne Bump
Medicaid Work Requirements – These requirements are coming to Michigan as reported by the Michigan Citizens Research Council of Michigan (CRC) on May 26, 2026. The Michigan state government and residents need to get ready. The negative impact, from the loss of health coverage to low-income individuals, will extend to the entire state, including providers and insurers. In Michigan, more than 2 million people are covered by Medicaid, with roughly $25 billion supporting a combined state and federal funding level annually. See the “In a Nutshell” chart below.
Medicaid Loss Hurts Senior Care – State employee retirees in the defined benefit plan may wonder how these work requirements could impact their well-being. Most of them, age 65 and older, have health care coverage through Medicare Advantage or traditional Medicare. However, what isn’t made clear, is that once a retiree can’t take care of themselves, they heavily depend on family or low-paid care givers. Many caregivers are not paid but are a significant part of the long-term care system. According to Justice in Aging, caregivers don’t have time to fill out complex paper work for work requirements and also care for their patients.
According to a June 24, 2025, Justice in Aging report, Medicaid work requirements would indirectly and meaningfully affect nursing home residents care by making the staff shortages in long-term-care even worse. The work requirements do not require nursing home patients to work themselves. But they will disturb care and threaten nursing home operations. The federal work requirements affect long term care facilities in the following ways:
- Medicaid Loss for Caregivers: Millions of family caregivers depend on Medicaid for their health insurance. Work requirements would take away Medicaid from caregivers. Medicaid is the caregiver’s usual health care insurance option because most caregivers are low wage workers. The ability of seniors to stay in their own home, before a nursing facility is needed, is threatened when they can’t get aides to help them when caregivers get sick, and can’t afford medical care without medical insurance.
- Facility Staffing Shortages: Many nursing home staff earn low wages and qualify for Medicaid. If these workers lose Medicaid coverage, they will miss work due to illness. This worsens the existing staffing shortage, and directly reduces the quality of care for nursing home residents, according to the June 5, 2025, Center for Medical Advocacy.
- Medical Exemptions: The work requirement rules generally exempt individuals who are medically frail or disabled from the 80-hour monthly work requirement. Nursing home residents usually meet these exemptions. Nonetheless, the complex paperwork rules to prove and document these exemptions may result in coverage losses.
- Hospital to Nursing Home Transitions: Recent limits on retroactive Medicaid coverage and more frequent eligibility reviews can result in patients discharged from hospitals to nursing homes having coverage interruptions. This results in significant billing and administrative issues for both the patients and the facilities.
These work requirements were passed as part of the 2025 federal reconciliation law.
According to a May 29, 2026, Gongwer report, the State of Michigan needs to implement these work requirements, without delay as required, effective January 1, 2027, according to the CRC report. Able-bodied adults ages 19 – 64 need to prove they have spent at least 80 hours per month working, in job training, in school at least half time, or performing community services. In addition, Michigan will need to redetermine eligibility for enrollees every six months, an increase from every 12 months currently. These combined two policy changes are estimated to result in hundreds of thousands of Michiganders losing their Medicaid healthcare coverage.
New Work Requirement Rule – According to a June 2, 2026, Roll Call, it was reported that the Centers for Medicare and Medicaid Services (CMS) issued a new rule, outlining state requirements to implement the new Medicaid work requirements. The new rule closely follows the list of exemptions already found in federal law. The new rule says that individuals can qualify for an exemption if they have significant impairments affecting their ability to live their daily lives. However, CMS didn’t go further than the exemptions which were already in federal law which says that someone must be medically frail. Starting when the law was passed in 2025, states began asking for clarification on how to determine if someone is frail enough to be exempt from work requirements, without receiving a response. The rule stipulates that states can’t add exemptions to the list.
Fortunately, in the first year of the program, states have wide leeway to accept self-attestations when someone is too sick to comply. This is due to the state not having the information for people new to Medicaid or have not seen a doctor yet. States will also need more time to build out their systems. Beginning in 2028, self-attestation will be available one time only under penalty of perjury.
According to CRC, researchers say that the success or failure of the work requirements implementation will likely come down to “the state’s capacity to inform and assist new applicants and current recipients subject to redetermination through the compliance process.” Adding new requirements to the work of agencies without enough staff, results in a greater chance for individuals to fail verification and lose health care coverage.
The CRC report mentions devoting resources to minimize the number of people that fail to qualify for Medicaid due to technical problems. According to a May 27, 2026, Gongwer report, Governor Whitmer recommended $104 million to implement work requirements for Medicaid and food benefits. The House approved a budget with $22.5 million while the Senate adopted a $59 million budget. CRC concludes that “Michigan can take steps now to prepare for implementation. An implementation process that minimizes coverage losses will be costly for the state, but it is likely that the overall costs to the state would be higher if more people lost Medicaid coverage.”
Joanne Bump serves as feature columnist for “Retirement Matters.” Column content is time sensitive and is based on information as of 6/7/26. Sources are primarily from non-profit, and government policy research organizations. Joanne can be contacted by e-mail at joannebump@gmail.com.