Sen. Ron Wyden and Rep. Frank Pallone asked federal health officials Thursday to postpone new Medicaid reporting requirements scheduled to begin January 1, 2027, as Oregon prepares hundreds of thousands of health plan members for changes that could affect their continued coverage.
The November 12 request calls on the Centers for Medicare & Medicaid Services to delay coverage denials and terminations until states have tested their eligibility systems, verification procedures and protections for beneficiaries. It comes as Oregon challenges the requirements in federal court while continuing to notify residents and prepare eligibility workers for implementation.
In their request to CMS Administrator Mehmet Oz, Wyden and Pallone urged the agency to grant states additional implementation time and approve good-faith exemptions. They also sought public disclosure of state readiness assessments, exemption applications and federal decisions, followed by state-level reporting on coverage denials and terminations once the requirements take effect.
The federal policy, enacted through the 2025 budget law, establishes new eligibility conditions for certain adults ages 19 through 64 covered through Medicaid expansion or specified demonstration programs. Qualifying activities include at least 80 hours per month of employment, community service or participation in a work program. Enrollment in an educational program at least half-time and income meeting a specified federal threshold provide other ways to satisfy the requirements.
Federal officials describe the policy as encouraging employment, education, community participation and independence. Wyden and Pallone contend that reporting obligations and incomplete state systems could cause eligible people to lose coverage.
Exemptions cover several groups, including certain caregivers, American Indians and Alaska Natives, veterans with total disability ratings and people with qualifying medical conditions.
States must verify compliance at application and renewal. When a state cannot establish that an individual meets the requirements, federal rules provide 30 days for that person to demonstrate compliance or eligibility for an exemption.
Oregon began its public notification effort in September, when the Oregon Health Authority announced that approximately 600,000 Oregon Health Plan members would receive information about upcoming changes. Subsequent notices tied to renewals will identify whether members need to provide information and the deadline for doing so.
OHA has said most adults enrolled in OHP who can work already do. Some members will need to document employment or another qualifying activity, while others will need to report a qualifying exemption.
Oregon’s published guidance allows members to report an exemption without supplying proof in 2027, with additional documentation requirements expected in 2028. The agency is asking members to keep mailing addresses, telephone numbers and email addresses current so they receive notices about their benefits.
Throughout Southern Oregon, affected OHP members will encounter the changes through the statewide application and renewal process. Assistance is available through certified OHP assisters, Oregon Department of Human Services offices and the state’s benefits service at 800-699-9075.
Attorney General Dan Rayfield filed a lawsuit November 5 challenging the constitutionality of the federal work requirements. Oregon’s Department of Justice said the changes could impose reporting obligations on more than half a million residents. The plaintiff states are seeking a preliminary injunction and summary judgment.
A separate October 29 ruling addressed the exemption for people considered medically frail. A federal judge in Massachusetts rejected additional language CMS had adopted that restricted eligibility for that exemption beyond the categories established by Congress.
The court removed the disputed restriction and provided a six-month enforcement stay concerning determinations of whether someone qualifies as medically frail, while leaving the January 1 implementation deadline intact.
Wyden and Pallone cited uncertainty surrounding the medical exemption in their request for additional time. Their November 12 announcement said Oz had indicated the administration would appeal the ruling, adding another unresolved issue as states prepare their systems.
Gov. Tina Kotek had already sought a longer implementation period. On October 1, she joined governors from California, Maine, New Mexico and Virginia in asking federal officials to give states more time. Her office described ongoing outreach to families and providers and training for eligibility workers.
Federal regulations allow states to request good-faith exemptions from the implementation deadline. Initial approvals may last up to six months, with extensions available to states that continue demonstrating progress toward compliance. Those exemptions must end by December 31, 2028.
Wyden and Pallone are pressing CMS to approve additional time before reporting failures or operational problems lead to coverage losses. Oregon continues preparing for January, notifying members and training workers while pursuing its challenge in federal court.