(Plain Press September 2026) The following article was drafted by Northern Ohioans for Budget Legislation Equality based on analysis that was published by Families U.S.A. and is designed for everyday residents, families, caregivers, seniors, and community leaders. The article explains—in clear, accessible language—how the new proposed Medicaid work‑requirement rules would operate alongside H.R. 1.

Federal Medicaid policy changes

   A sweeping set of federal policy changes are underway that could reshape Medicaid access for thousands of Ohioans. The Centers for Medicare & Medicaid Services (CMS) has released proposed Medicaid work‑requirement rules, designed to operate alongside the mandates already established under H.R. 1. Advocacy groups—including Families U.S.A., whose analysis informs this report—warn that the combined framework may create significant barriers for vulnerable residents unless the public speaks up during the federal comment period.

   Members of the public received a narrow window to submit comments to the Federal Register, the deadline was July 31st.

   The new proposed rules include: new applicants must show compliance for 1–3 consecutive months before applying; current enrollees must show compliance for 1–3 months, not necessarily consecutive; states decide the duration and whether months must be consecutive; medical frailty must be documented; medical frailty must be reverified annually; and no long‑term medical frailty status exists.

Work Requirements Under H.R. 1

   House Resolution 1 (HR1) establishes strict criteria for demonstrating compliance with federal work‑activity rules. To maintain Medicaid eligibility, individuals must meet one or more of the following monthly requirements: work 80 hours; complete 80 hours of community service; participate in a work program for 80 hours; be enrolled at least part‑time in an education program; earn monthly income equal to minimum wage × 80 hours (currently $580 per month at $7.25/hour); and job‑search activities and job‑search training programs DO NOT count toward work requirements.

   Qualifying education programs include institutions of higher education and career/technical programs which include high school programs, and state‑approved programs leading to high‑school equivalency.

   Community Service work done to fulfill work requirements must be unpaid, performed for the direct benefit of the community, conducted under a public or nonprofit organization, and include documented tracking of dates and hours and must be non‑partisan.

   Exempt individuals include: individuals under age 19; people entitled to Medicare Part A or B; Adults over 65, blind, or disabled with limited income; Supplemental Security Income (SSI) recipients; pregnant women (during pregnancy and 60 days postpartum); children receiving Title IV‑E adoption, foster, or guardianship assistance; and individuals incarcerated at any point in the prior three months

   These individuals are excluded from work requirements entirely: foster youth under age 26 who were Medicaid‑enrolled at age 18; individuals eligible for Indian Health Service; caretakers of dependent children under 13 or caretakers of disabled individuals; disabled veterans; individuals who are medically frail or have special medical needs; individuals participants in drug or alcohol treatment programs; and pregnant or postpartum individuals (60 days or up to 12 months if Ohio opts in)

   The proposed rules narrow the definition of medical frailty to include individuals who have a condition that significantly impairs their ability to work and the States must create a list of qualifying conditions: homelessness is explicitly excluded; individuals capable of completing 80 hours of activity per month cannot be considered medically frail; and medical frailty must be documented and reverified annually.

   Individuals may be exempt if they are experiencing recent inpatient hospitalization or similar high‑acuity care; have a residence in a county with a federal disaster declaration; have a residence in a county with high unemployment (≥8% or ≥1.5× national rate); and require extended travel for medical care for themselves or dependents.

   Proposed rules require states/counties to inform applicants whether they are excluded, required to meet work rules, or compliant; complete disability‑based determinations within 90 days; complete all other determinations within 45 days; and provide no explanation for the determination

   If an applicant or recipient is found to be non-compliant then the states must allow individuals to receive 30 days to make a “satisfactory showing”; send denial/disenrollment notices that include specific reasons; and states may not restrict re‑application or future eligibility.

   The proposed rules—combined with H.R. 1—could create significant administrative burdens, increase disenrollment, and disproportionately affect low‑income workers, caregivers, and individuals with unstable health conditions.