In 2027, Medicaid redeterminations will change as a result of legislation passed under H.R.1. Among the biggest differences coming are new requirements for states to verify eligibility every six months and most adults needing to document qualifying community engagement activity to keep their coverage. 

Analysts project millions of people will lose Medicaid, not because they’re ineligible, but because no one reached them in time. Many of those at greatest risk of losing coverage are the same clients served by community health workers (CHWs) and community-based organizations (CBOs).

January will mark the beginning of a new year and a new administrative reality for millions of people and for the community health workforce that helps them navigate the healthcare system. The question for every CHW, doula, and CBO is the same: when that happens in your community, will your organization be ready?

What’s changing for new and existing enrollees

Beginning Jan. 1, 2027, most states will begin implementing new Medicaid community engagement requirements for certain adults ages 19–64. Depending on their circumstances and state implementation, individuals may need to demonstrate monthly minimums for qualifying work, community service, education, or other activities, while others may qualify for an exemption. That means more members and the care teams who support them will need to understand new rules, document their circumstances, and respond to verification requests to maintain coverage.

For the frontline community health workers engaged with this work every day, one thing is clear: Medicaid eligibility is becoming increasingly intertwined with the ability to navigate an administrative system. And CHWs will be among the first people asked to help.

The next Medicaid challenge? Proving what you already qualify for

For many Medicaid members, the question won’t necessarily be whether they meet a requirement; it will be whether they can successfully document and communicate that they meet it. That distinction matters.

A person may be working but not know what documentation is acceptable. Someone may qualify for an exemption but not realize it. Another person may receive a notice, misunderstand what action is required, or simply miss a deadline while juggling work, transportation, caregiving, or other responsibilities. In other cases, a current Medicaid recipient may need to seek a qualifying community engagement opportunity, such as employment, volunteer service, or education, but may need assistance uploading verifiable proof to the appropriate government agency system.

These aren’t hypothetical barriers. In Nebraska, the first state to navigate early implementation since May, these are precisely the kinds of administrative obstacles that health systems, CHWs and CBOs are already helping people overcome.

As requirements take effect — and as other Medicaid administrative changes increase the frequency and complexity of eligibility processes — the volume of navigation work is likely to grow. More questions will be asked, appointments will run longer, and the paperwork for each member will increase significantly. The system will ask more of members, and in turn, ask more of the people helping members navigate it.

CHWs are the frontline defense against loss of coverage

CHWs have always occupied a unique position in healthcare: close enough to communities to understand the realities people face and connected enough to health systems to help translate those realities into action. On a daily basis, the community health workforce builds trust, helps people overcome barriers to care, and keeps them engaged. That role becomes even more important when a person’s access to coverage depends on completing multiple administrative steps.

CHWs can help answer questions members have, such as:

• What exactly is Medicaid asking me to do?
• Does my situation qualify for an exemption?
• What activities count?
• What documentation do I need?
• Where and how do I submit it?
• What happens if something is missing?
• What do I do if I receive another notice?
• Who can help me if I’m at risk of losing coverage?

But there are compounded challenges in adding more responsibilities to an already stretched workforce.

The answer isn’t more paperwork. It’s better preparation.

Health plans, providers, CBOs, public agencies, and community-based care teams should be preparing now to understand how they will identify people who need help, track outstanding requirements, coordinate outreach, and follow up when something falls through the cracks. That requires infrastructure that supports the workforce rather than creating another layer of work for them.

The implementation of Medicaid community engagement requirements shouldn’t simply be viewed as a compliance challenge. It is an opportunity to rethink how stakeholders work together to keep people connected to coverage and care. Because ultimately, a person shouldn’t lose access to health care simply because a piece of paperwork got lost in the system.

CHWs should not be expected to carry this burden alone. With the right tech-driven tools, workflows, and coordination, they can be empowered to serve as the trusted human connection between Medicaid members and an increasingly complex system.

The organizations that prepare now will be better positioned to identify gaps early, support members through the process, and prevent administrative complexity from becoming an additional, unnecessary barrier to care.