MASSHEALTH HAS ITS EYES on January 2027, when it now anticipates that closer to 310,000 members in Massachusetts will be subject to new federal work and education requirements.
MassHealth Chief Operating Officer Elizabeth LaMontagne’s new figure is lower than the prediction she made at a 2026 Medicaid summit in June, when she said about 360,000 members would be impacted by the overarching Medicaid work and education requirements in President Donald Trump’s July 2025 One Big Beautiful Bill Act.
LaMontagne on Wednesday pointed to ways the law will also shorten retroactive coverage and require renewals more often for some groups. But she told the Permanent Commission on the Status of Persons with Disabilities that “most individuals with disabilities are likely not going to be subject to work and education requirements because they often don’t fall into the impacted population.”
“If you do have a federal or state disability, not only will you be automatically exempt from work and education requirements, assuming you were subject to them, but you also will not be impacted by the six-month renewal,” LaMontagne said. She said across MassHealth’s roughly 1.9 million-resident caseload, 250,000 members have a disability.
MassHealth sent initial notices to members who may be impacted by the new requirements in August, and will be following up with emails, texts, and robocalls through the fall. Work and education requirements will be applied at a person’s regular renewal, she explained, at which point MassHealth will do a data check to try to automatically exempt them.
MassHealth is “actively exploring new data sources” to try to exempt as many people as possible, LaMontagne said.
For those with disabilities or who are dependents under 14 years of age, the agency will use its eligibility system and Social Security Administration data. MassHealth is newly planning to use claims data to exempt those who are pregnant or postpartum, along with people who have a complex medical condition or are considered to have a “medical frailty.”
“We also are working with the federal government to ingest Veterans Affairs data, which will allow us to automatically exempt veterans with a total or 100 percent disability rating,” LaMontagne said. “We are setting up a data exchange with the Department of Transitional Assistance, which will allow us to exempt people who are compliant already with [Transitional Aid to Families with Dependent Children] work requirements or who are subject to SNAP work requirements.”
“If we’re not able to exempt people, then it falls to step two: do we have data that can show that people are already meeting work requirements?” she continued. “So for income, we already have access to federal and state data sources like Department of Revenue data, IRS data, and we’re newly integrating with Equifax, which will allow us to have more real-time data in terms of hours worked.”
The agency is working through “technical hurdles” to integrate data from the National Student Clearinghouse, which LaMontagne said would allow it to pull in data on people enrolled in higher education. MassHealth is also working with a small group of nonprofits to support people who will want to comply with the requirements through volunteering.
If the state can’t automatically prove a member is exempt from work and education requirements, the individual will have to answer new questions on their application or renewal, and if they’re considered “medically frail,” they will have to reply to a “request for information” with more details.
There are 47 community-based organizations that will be providing outreach and enrollment assistance as part of a statewide campaign to address federal changes, according to Hannah Frigand, senior director of the HelpLine and public programs at Health Care For All. LaMontagne said MassHealth is also working to connect people with volunteer and educational opportunities, as well as providing resources to help them fill out paperwork.
MassHealth applicants in 2027 will have to show they’re meeting work and education requirements in the month before they apply, while existing members will have to show they’re meeting the requirements in any one month between renewals. While people won’t have to provide additional documentation proving they’re compliant in 2027, that won’t be the case in 2028 when self-attestation methods change, LaMontagne said.
LaMontagne also told the Commission on Persons with Disabilities on Wednesday that MassHealth is also preparing for this October, when it anticipates about 7,300 individuals in Massachusetts will see their coverage impacted by new federal limits to coverage for certain noncitizens.
