Healthy Michigan Plan work rules start in 2027, and your employees will notice
Beginning January 1, 2027, adults applying for the Healthy Michigan Plan must show work or other qualifying activity, and current members are checked at renewals from March 1, 2027, according to MDHHS. This page covers the rule and what it may mean for HR.
What the Federal Rule and MDHHS Say.
Federal law added a community engagement requirement for adult-group Medicaid enrollees to section 1902(xx) of the Social Security Act. CMS published an interim final rule on June 3, 2026, at 91 FR 33348, effective July 31, 2026, which requires states to implement the requirement by January 1, 2027. 42 CFR 435.119(d) makes adult-group eligibility subject to it, and 42 CFR 435.559 sets medical assistance furnished on or after January 1, 2027 as the starting point, with verification at the first renewal after that date for people already enrolled.
MDHHS applies the rule to Healthy Michigan Plan adults ages 19 to 64. A person meets it by earning at least $580 in at least one month of the review period, or by completing at least 80 hours in one month of approved activities: paid or unpaid employment, internships or work programs, volunteering or community service, high school or GED programs, and college or vocational programs, alone or combined. MDHHS says the $580 figure is not a Medicaid income limit. The federal rule describes the same 80-hour test.
Who the Rule Does Not Reach.
MDHHS lists these exemptions: people subject to or meeting SNAP or TANF work requirements; people who are pregnant or gave birth in the past 12 months; parents or caregivers of a child 13 or under, and caregivers of a person with a disability; American Indian and Alaska Native people; former foster youth under 26; disabled veterans; people in substance use treatment or in jail or prison; people who are medically frail or have a serious health condition; and people facing temporary hardships such as facility care, a federally declared disaster or high local unemployment.
We cannot tell you which of your employees falls within an exemption, and you should not guess. MDHHS says it checks some exemptions automatically.
What MDHHS Says About Your Role.
The MDHHS page we read does not mention employer verification of work hours or any other role for employers. It says applicants report their job and all income on the application, that MDHHS uses available data sources to check exemptions, and that at renewal it tries to verify compliance automatically from existing data. We found no duty to complete a form for an employee.
If an employee asks for a letter confirming employment or hours, supplying accurate information is an HR decision. The sources we read neither require it nor prohibit it. Release only what the employee asks for.
What May Reach Your HR Team.
Questions come first. Employees who work few hours may ask whether your plan or Medicaid is the better fit, and the honest answer is that MDHHS decides Medicaid eligibility. Second, MDHHS says people who lose Healthy Michigan Plan coverage solely for not meeting the requirement cannot receive Marketplace financial help, which can make an employer plan the most realistic option for some.
Third, special enrollment. If coverage under Medicaid ends because of lost eligibility, ERISA section 701(f)(3), 29 U.S.C. 1181(f)(3), lets an employee who is otherwise eligible under your plan’s terms ask to enroll within 60 days. Whether MDHHS’s termination for not meeting this rule counts as lost eligibility in that sense is a question to put to counsel. Our CHIPRA and HIPAA special enrollment pages describe the right itself.
One more point: if you cut an employee’s hours, two separate tests move, your plan’s eligibility rules and the employee’s own 80-hour or $580 test. They are unrelated, and our ACA page covers the first.
What To Do Now.
Brief HR that the requirement begins January 1, 2027 for applicants and March 1, 2027 for renewals, and that employees report changes through MI Bridges or a local MDHHS office.
Make sure your handbook and enrollment materials state the 60-day special enrollment window, and log the date an employee reports losing Medicaid.
Check back with us before open enrollment. MDHHS says it is reviewing the federal rule, so the details may change.
Common Misreadings.
Advising an employee on whether an exemption applies. That is MDHHS’s determination.
Treating the numbers as permanent. MDHHS says it is reviewing the federal rule, and details may change.
Assuming the rule covers all Medicaid. The MDHHS page we read applies it to adults ages 19 to 64 on the Healthy Michigan Plan.
Related Rules And Tools.
CHIPRA Premium Assistance and CHIP Special Enrollment
The 60-day special enrollment right for lost Medicaid or CHIP coverage.
HIPAA Special Enrollment and the Newborns Act
Special enrollment events and the notices that go with them.
Affordable Care Act for Employers
Eligibility, hours and the employer mandate.
Laws And Sources
MDHHS, New Medicaid Work Requirements: Hours, income measure, exemptions, start dates and verification.
91 FR 33348, Community Engagement Requirement: CMS interim final rule, published June 3, 2026.
42 CFR 435.119: The adult group and the community engagement cross-reference.
42 CFR 435.559: Implementation date and first-renewal verification.
29 U.S.C. 1181: ERISA section 701(f)(3), the Medicaid and CHIP special enrollment right.
Quick Answers.
Short replies on this page’s topic, each tied to a fuller guide.
When do the Healthy Michigan Plan work requirements start?
MDHHS says applicants on or after January 1, 2027 answer work questions on the application, and current enrollees are checked at renewals on or after March 1, 2027.
Do employers have to verify an employee’s hours for Medicaid?
The MDHHS page we read gives employers no verification role. It says applicants report their own job and income and that MDHHS checks available data sources. Details may change as MDHHS reviews the federal rule.
What happens to an employee who loses Healthy Michigan Plan coverage?
MDHHS says people who lose coverage only for missing the requirement cannot receive Marketplace financial help. An employee who is otherwise eligible for your plan may have a 60-day special enrollment right under ERISA section 701(f)(3) if the coverage ended because of lost eligibility, so ask counsel how it applies.
The Rest Of This Series.
Michigan Medicaid and Employer Group Health Coverage
The overview page for this series.
The Healthy Michigan Plan and Your Group Plan
Who the program covers and how employer coverage fits.
MIChild and Premium Payment for Employer Plans
Michigan’s CHIP state plan and premium payment, with what we could not confirm.
Third-Party Liability and Medical Child Support
Plan and employer duties when a state agency or support order reaches your plan.
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