How Michigan Medicaid fits around your group health plan
Michigan’s Medicaid program, including the Healthy Michigan Plan, covers some of your employees and their children. It does not replace your plan, but federal law gives the state ways to reach it. This hub sorts out what applies to employers and what we could not verify.
Four Pages On One Relationship.
General information, not legal advice.
The Healthy Michigan Plan and Your Group Plan
Who the program covers according to MDHHS, and what the federal text says about employees who also have employer coverage.
MIChild and Premium Payment for Employer Plans
What Michigan’s CHIP state plan says about employer coverage, and what we could not confirm about premium payment.
Third-Party Liability and Medical Child Support
Why a group plan is billed before Medicaid, and what employers and plans do when a medical support notice arrives.
Work Requirements in 2027
The new Healthy Michigan Plan rule, the details MDHHS has published and why more employees may ask about your plan.
Where Things Stand.
Medicaid is a joint federal and state program, and in Michigan the Michigan Department of Health and Human Services (MDHHS) runs it. The Healthy Michigan Plan is the state’s Medicaid coverage for adults. MDHHS lists these conditions: age 19 to 64, income at or below 133 percent of the federal poverty level under the modified adjusted gross income method, Michigan residency, no Medicare or other Medicaid eligibility, and not pregnant at application. The federal rule for the adult group, 42 CFR 435.119, uses the same age and income figures.
None of that creates a duty for your business to offer a plan or tells you how to design one. What the law does is line your plan up with the state’s coverage. Section 1902(a)(25) of the Social Security Act, 42 U.S.C. 1396a(a)(25), requires a state to look for third parties that may owe for a person’s care and names group health plans among them. ERISA section 609(b), 29 U.S.C. 1169(b), tells a group health plan to disregard Medicaid eligibility when it enrolls someone or pays benefits. An employee can therefore hold both kinds of coverage, and the state is to seek reimbursement from a plan that is liable.
This hub has four pages, each with its own angle. We keep the federal CHIP premium assistance duty on our CHIPRA pages and link to them rather than repeating them.
Four Touchpoints.
Enrollment. A plan may not use an individual’s Medicaid eligibility as a reason to refuse or limit enrollment or benefits under 29 U.S.C. 1169(b)(2). It is worth checking that your plan document and your carrier’s enrollment rules say nothing to the contrary.
Orders and notices. When a medical child support order or a National Medical Support Notice arrives, deadlines run. The employer must transfer the notice to the plan within 20 business days under 42 U.S.C. 666(a)(19)(B), and the plan administrator has separate duties under ERISA section 609(a).
Special enrollment. An employee who loses Medicaid or CHIP coverage because of lost eligibility may ask to join your plan within 60 days under ERISA section 701(f)(3), 29 U.S.C. 1181(f)(3), if the employee is otherwise eligible under the plan’s terms. Our CHIPRA pages explain the right and the related employer notice, so we do not restate them here. The Healthy Michigan Plan work requirement beginning in 2027 may bring more such requests.
Payroll. Premium contributions come out of pay, and Michigan’s Payment of Wages and Fringe Benefits Act, MCL 408.477, sets the consent rules for deductions from wages. Our wages act guide covers the Act, and our medical child support page adds the point where a support notice meets a payroll deduction.
Open Points, Stated Plainly.
We read the primary sources listed below in preparing this series. Several points could not be confirmed, and we say so rather than guess.
Employer coverage and eligibility. The MDHHS program page and the Michigan eligibility policy item we read do not address how employer coverage affects Healthy Michigan Plan eligibility, and the federal adult-group text lists no such condition. Ask MDHHS about an individual case.
Premium payment in Michigan. Federal law lets a state pay premiums for employer coverage. The Michigan pages we could read did not describe such a program for the Healthy Michigan Plan, and the Michigan CHIP state plan text we read described no premium assistance program.
The MDHHS child support employer page. It did not load for us, so the Michigan side of medical support notices rests on statute text and federal law.
Figures. We state no dollar income limits for eligibility, no benefit levels and no enrollment counts, because we did not fetch them from a primary source.
Status. The federal community engagement rule is an interim final rule, and MDHHS says it is reviewing it, so Michigan details may change.
Related Rules And Tools.
CHIPRA Premium Assistance and CHIP Special Enrollment
The federal 60-day special enrollment right and the employer premium assistance notice.
Participant Contribution Timing for Group Health Plans
When employee contributions must reach the plan, a rule that matters when a premium is withheld.
ERISA Part 7 Group Health Plan Requirements Checklist
The federal group health plan rules a plan document should reflect.
HIPAA Special Enrollment and the Newborns Act
Special enrollment events and the notices that go with them.
Michigan Wages and Fringe Benefits Act Guide
Final pay, deductions and fringe benefits under Michigan law.
Michigan Employer Benefits Law at a Glance
A one-page view of the Michigan and federal rules that touch your plan.
Laws And Sources
42 U.S.C. 1396a: Section 1902 of the Social Security Act, including the third-party liability rule in paragraph (a)(25).
29 U.S.C. 1169: ERISA section 609, medical child support orders and state Medicaid rights.
29 U.S.C. 1181: ERISA section 701, including the Medicaid and CHIP special enrollment right in subsection (f)(3).
42 U.S.C. 666: Employer duties on a National Medical Support Notice, paragraph (a)(19).
42 CFR 435.119: The federal adult group: age, income and the community engagement cross-reference.
MDHHS, Healthy Michigan Plan: The state’s program page: conditions, how to apply and the work requirement start date.
MCL 408.477: Deductions from wages under the Michigan Payment of Wages and Fringe Benefits Act.
Quick Answers.
Brief answers to what employers ask about Medicaid and their group plan, each linked to the fuller page.
Does Michigan Medicaid require us to offer group health coverage?
Nothing we reviewed in the Healthy Michigan Plan or the federal Medicaid provisions requires an employer to offer coverage. Any duty to offer comes from other laws, such as the employer shared responsibility rules covered on our ACA page.
Can an employee be on our group plan and the Healthy Michigan Plan at once?
Possibly. The federal text for the adult group does not list employer coverage as a condition, and the MDHHS pages we read do not address it, so we could not confirm how MDHHS treats a particular employee. Send the employee to MDHHS.
Does a group health plan pay before Michigan Medicaid?
Federal law directs the state to look for third parties that may owe for a person’s care, group health plans included, and to seek reimbursement from a liable one. In practice the group plan pays under its own terms and Medicaid is the secondary source.
What do we do when we receive a National Medical Support Notice?
Federal law gives an employer 20 business days to transfer the notice to the health plan that covers the child, and the plan administrator has its own deadlines. Our third-party liability and medical child support page walks through both.
Do employers have to administer the Healthy Michigan Plan work requirement?
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. Details may change as MDHHS reviews the federal rule.
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