New Hampshire Medicaid Members Should Prepare for 2027 Work-Requirement Changes

New Hampshire is preparing Granite Advantage Medicaid members for eligibility changes that begin January 1, 2027. For adults to whom the new federal community-engagement rule applies, maintaining coverage may require documenting at least 80 hours each month of work, education, job training, volunteer service or community service.

The change will not apply to every Granite Advantage member. According to Concord Monitor reporting based on state information, 47,571 residents were expected to encounter the new rules at their first Medicaid redetermination in 2027. That is an estimate of the population expected to be subject to the rules, not a prediction of how many people will lose coverage.

What changes on January 1, 2027

Federal law requires states, beginning January 1, 2027, to condition Medicaid eligibility for applicable individuals on demonstrating community engagement unless a state starts sooner. New Hampshire’s current implementation information uses the January 1 start date, according to the Centers for Medicare & Medicaid Services.

If the requirement applies, a member generally must complete at least 80 hours per month in one or more qualifying activities. The CMS New Hampshire guidance lists paid work, volunteer or community service, certain job-training programs and qualifying education. School attendance can count; people who work may also qualify through monthly earnings of at least $580. Different activities may be combined to reach the monthly standard.

The requirement is considered during Medicaid eligibility reviews. If it applies and a member does not demonstrate compliance or an exclusion, the state may end coverage or deny an application. Coverage loss is not automatic for every Granite Advantage member who falls short, and New Hampshire is still developing parts of the reporting and review process.

Who may be affected

The general affected group is adults ages 19 through 64 with household income up to 138% of the federal poverty level who receive coverage through the applicable Medicaid adult expansion category and do not qualify for an exclusion. CMS lists approximate annual income figures of $22,025 for a one-person household and $29,863 for a two-person household on its New Hampshire-specific page.

The timing will depend on each member’s first 2027 redetermination. Members should not assume that every person enrolled in Granite Advantage will face the same deadline or the same requirements.

Exclusions can change the result

CMS lists circumstances that may exclude a person from the community-engagement requirement. They include:

• Being under age 19 or age 65 or older;
• Being pregnant or having given birth within the previous 12 months;
• Being a parent, guardian, caretaker relative or family caregiver for a child under 14 or a person with a disability;
• Being released from a correctional facility within the previous three months;
• Being a veteran with a total disability rating from the Department of Veterans Affairs;
• Being a member of an Indian or Urban Indian Tribe;
• Being a current or former foster youth under age 26;
• Already meeting work requirements for SNAP or TANF;
• Having a functional limitation that makes daily activities difficult;
• Being blind or having a physical, intellectual or developmental disability;
• Having a substance-use disorder or serious mental-health condition;
• Participating in a substance-use treatment or recovery program; or
• Having or qualifying for Medicare Part A or Part B.

The state has not finalized every exemption standard, reporting method or operational procedure. The Concord Monitor reported that New Hampshire was awaiting additional federal guidance on who qualifies and how members will report work or community-engagement activities. CMS also says it anticipates further guidance as states implement the policy.

What New Hampshire is doing now

New Hampshire’s Department of Health and Human Services has begun an early-engagement campaign. CMS says Granite Advantage members should expect a letter or email in the coming months if the changes may apply to them.

State officials are also sharing information with Medicaid providers, community organizations and other groups. The immediate goal is to give members time to determine whether the requirement may apply, whether an exclusion may apply and what records they may need to provide.

Renewals will also become more frequent

A separate federal change requires six-month eligibility renewals for most people in the Medicaid adult expansion group beginning with renewals scheduled on or after January 1, 2027. The rule applies to members of that expansion group whether or not they are subject to the community-engagement requirement, according to CMS State Medicaid Director Letter SMD 26-001.

The two changes are related but distinct. The six-month rule changes how often eligibility is reviewed. The community-engagement rule adds an activity or exclusion determination for people to whom it applies.

CMS says states must generally begin a renewal by checking reliable information already available to them. If that information is not enough, the state must send a renewal form and give the beneficiary at least 30 days to return the form and requested information. Before termination or another adverse action, states must provide advance notice and fair-hearing rights under federal rules.

Steps Granite Advantage members can take

Members who may be affected should update their address, telephone number and email address with New Hampshire Medicaid. They should monitor both physical mail and electronic messages for state notices.

Keeping a monthly record of work, school, training and volunteer hours can help document qualifying activity. People who believe an exclusion applies should begin gathering relevant medical, legal, school, military, tribal or other supporting records.

Members should also pay attention to the date of their first 2027 redetermination. The timing will differ by person, and not every Granite Advantage member will face identical requirements.

If coverage ends or an application is denied, CMS says a person may apply for Medicaid again. Depending on the circumstances, the person may also qualify for coverage through the federal Health Insurance Marketplace, although financial assistance may not be available in every case.

Sources

• CMS: Granite Advantage Health Care Program Eligibility Changes
• Concord Monitor: Work requirements coming for people on Medicaid Granite Advantage

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