Work Requirements and What Really Drives Disability Employment
Written by DNWML Community Engagement Coordinator, Eliot Carter
Every October, we celebrate National Disability Employment Awareness Month. America has been honoring workers with disabilities in October as far back as 1945: that’s when Congress declared the first week of October “National Employ the Physically Handicapped Week” [1]. In 1987, Congress declared that all of October would be dedicated to celebrating workers with all kinds of disabilities. This October feels different though, because big changes will start to occur on January 1st of 2027 when it comes to disability and work. If you have insurance under Medicaid Expansion, you will have to start filling out extra paperwork to show that you are working, volunteering, or going to school (or that you meet one of the “exemptions” that allows you to keep your insurance). This is because of the budget bill passed on July 4, 2025, also known as the “One Big Beautiful Bill Act.” We have discussed this in previous blog posts, so we will focus on what is most important for people with disabilities to know going into 2027.
- This only applies to Medicaid Expansion plans. In Michigan, this is called the Healthy Michigan Plan (HMP). Medicaid Expansion is for people and families who make a little more than the poverty level and are between the ages of 19-64 [2]. Check MI Bridges to see what type of Medicaid you are enrolled in.
- The general requirement is 80 hours of work per month, but there are other ways to meet the requirement. You may be working as a volunteer or intern for the same amount of time per month. You also may be going to school – this includes high school/GED programs as well as college and vocational education.
- Also, if you or a member of your household is making 80 times the federal minimum hourly wage (currently $580) per month, you are considered to meet the work requirement. You can also meet the 80-hour requirement based on a combination of work, school, and volunteer hours.
- Medicaid Expansion enrollees will have to renew their coverage every six (6) months. Currently these enrollees must be renewed once a year, much like regular Medicaid. If you enroll in Medicaid Expansion/HMP in January 2027, you will have to prove you met the work requirement when you apply and again in June 2027.
- Many of our consumers will be exempt (excused) from work requirements. Here are a few ways you might get an exemption:
- You meet the work requirements for SNAP (food stamps)
- You care for someone with a disability or a child under 13 years old (meaning you are living with them, a relative of them, and/or spend 80 or more hours a month supporting them)
- You are in a substance use disorder treatment program
- You have a disability or health condition that makes it difficult to work (see below)
- Many other exemptions exist and can be found on Michigan.gov (click here to see more)
- States have gotten mixed messages from the federal government when it comes to how disability might exempt someone from work requirements. The Department of Health and Human Services calls this a “medical frailty” exemption. In June, they released a rule that said that people applying for this exemption must submit some sort of proof from a professional that says that they are unable to work. States were not expecting this, and we still don’t know exactly what counts as proof [3]. Luckily, Michigan has a self-attestation rule. That means that the state will accept a written or spoken statement as proof that you are following the rule for a short period of time. Bottom line, saying that you have a disability will exempt you from the work requirement, but only until January 1, 2028 [4]. After that, you will probably need some type of doctor’s note, but we are waiting to learn more.
- States are required to gather information they need based on the data they have already collected or have access to, such as payroll data and past claims data. This is called “ex parte” verification. States may be able to get information that confirms you meet the work requirement without you needing to submit proof. It is important to check your mail and your MI Bridges account regularly, so you don’t miss requests for information.
This information is up to date as of October 9, 2026. Parts of these rules are being challenged in court, including the Medical Frailty exemption. We also can’t say for sure how these will play out when the rules go live. We have seen states try work requirements though, such as Arkansas, and the picture is clear: these policies did not increase employment among people eligible for Medicaid Expansion – it did however cause many people to lose their insurance [5].
We believe a much better way to promote employment is to support people entering or re-entering the workforce. This might mean getting them ready for a job or helping them follow work-related rules from Social Security and Medicaid. DNWML is a proud part of the American Dream Employment Network (ADEN), and we work to help people with Social Security benefits find and keep employment. What sets us apart from many other employment agencies is that many of our staff have dealt with the rules and paperwork for these programs ourselves. Our staff get special training for planning out how to balance work and benefits, or how to work your way off of benefits.
If you’re on the Healthy Michigan Plan and want to prepare for the new rules, please reach out to us! We can also help answer questions you have about benefits and work. Even if you just want a bit of help figuring out what that letter Social Security sent you is even saying – DNWML is just a phone call or message away!
https://www.loc.gov/accessibility/disability-employment-awareness-month
https://www.michigan.gov/healthymiplan/new-medicaid-work-requirements
https://shvs.org/resources/cms-releases-interim-final-rule-on-medicaid-work-reporting-requirements/
https://www.nejm.org/doi/10.1056/NEJMsr1901772