Arkansas Medicaid Work-Requirement Checks Begin, With Penalties Delayed Until 2027

Arkansas has begun checking whether some Medicaid expansion beneficiaries meet a new work and community-engagement requirement, but residents will not lose coverage under that requirement during the 2026 soft-implementation period.

The Arkansas Department of Human Services began the checks on July 1 for many adults enrolled in Arkansas Health and Opportunity for Me, or ARHOME. DHS says the six-month period is being used to test verification systems and notify beneficiaries before penalties begin on January 1, 2027.

The change principally affects nonpregnant ARHOME adults ages 19 through 64 who are not otherwise exempt. It does not apply to every Arkansas Medicaid beneficiary.

What DHS is checking

Beginning January 1, 2027, people subject to the requirement generally must demonstrate 80 hours per month of qualifying activity. The hours can come from paid work, community service, qualifying work programming, qualifying education or a combination of those activities.

Under the federal rule, an individual may also meet the standard through qualifying monthly income. The Centers for Medicare & Medicaid Services says the 2026 income threshold is at least 80 times the federal minimum wage, or $580 per month, with a different calculation for seasonal workers.

During the soft implementation, DHS may compare Medicaid records with wage information, Supplemental Nutrition Assistance Program and Transitional Employment Assistance records, medical claims, diagnosis information and other available data. The goal is to determine whether the agency can verify a person’s status without requiring every beneficiary to submit documents immediately.

A notice now does not mean coverage is ending

Beneficiaries may receive notices explaining whether state records verify that they are meeting the upcoming standard. A notice saying DHS could not verify compliance is not the same as a final finding that a person is ineligible or has failed the requirement.

DHS says no penalties under the new requirement will be imposed during the 2026 soft implementation. Residents who continue to meet existing Medicaid eligibility rules will not lose coverage solely because the new requirement could not be verified during this period.

Arkansas Advocate reported that DHS is using the six-month period to test automated checks and give beneficiaries an early indication of what state records show. The agency has said the notices will explain that the requirement does not take effect until January 1, 2027, even if the state cannot verify a beneficiary’s status during the soft implementation.

Who may be exempt

Federal rules exempt or otherwise protect some categories of people, including pregnant or postpartum individuals, people who are medically frail or have special medical needs, certain caregivers, some veterans, American Indians and Alaska Natives, people in qualifying treatment programs and people in certain other Medicaid eligibility groups.

The list is not a guarantee that an exemption will be recognized automatically. If DHS cannot verify a person’s status through its records, the beneficiary may need to provide information showing that an exemption or exception applies.

CMS says states must give people an opportunity to demonstrate compliance or establish that the requirement does not apply to them when automated records are insufficient. States may also provide certain short-term hardship exceptions under the federal rule.

What changes on January 1, 2027

Once the requirement is in effect, people subject to the rule whose compliance cannot be verified generally will receive a notice and have 30 calendar days to provide information showing that they met the requirement or qualify for an exemption or exception.

If a person does not respond successfully, coverage may be suspended or an application may be denied under applicable Medicaid procedures. CMS says people disenrolled for failure to meet the requirement may reapply, but their compliance will be assessed again.

What ARHOME beneficiaries should do now

DHS advises ARHOME beneficiaries to update their contact information and sign up for text and email alerts through Access Arkansas. Residents can update their information online, call the Access Arkansas hotline at 1-855-372-1084 or visit a DHS county office.

Beneficiaries should keep records that may show qualifying work, education, community service or participation in an approved work program. People who believe they are exempt should review the applicable rules and be prepared to provide supporting information if the state’s records do not identify their status.

The immediate deadline is not a penalty date. The practical step now is to make sure DHS can reach you and that you understand any notice before the new enforcement period begins on January 1, 2027.

Sources

• Arkansas DHS: ARHOME Community Engagement and Work Requirement
• CMS: Medicaid Community Engagement Requirement Fact Sheet
• Arkansas Advocate: Arkansas has begun a soft launch of Medicaid work requirements

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