Idaho health officials are preparing to roll out work requirements for Medicaid expansion enrollees beginning January 1, 2027, following action by Republican lawmakers and Gov. Brad Little in April to align the state with President Donald Trump’s One Big Beautiful Bill Act. An early review of enrollment data suggests that most participants already satisfy the new conditions.

Who Must Comply

Under the new rules, Medicaid expansion enrollees must demonstrate at least 80 hours per month of qualifying activity — including employment, community service, education, or job training. Idaho has set a three-month lookback period, meaning applicants must show documented work history from the three months prior to their Medicaid application. That window is the longest permitted under federal law, and Idaho joins Indiana and North Carolina as the only three states planning to use it.

Medicaid expansion in Idaho covers residents earning up to 138 percent of the federal poverty level — roughly $29,863 annually for a household of two. The state is also tightening the renewal cycle, requiring enrollees to re-apply every six months rather than annually.

Idaho voters originally approved Medicaid expansion through a 2018 ballot initiative. The state currently has approximately 85,000 enrollees in the expansion program.

Early Data Shows Broad Compliance

An initial review of roughly 83,000 expansion enrollees found that 68,400 already meet the forthcoming requirements based on existing records. That leaves a smaller segment of the caseload that will need to furnish additional documentation before implementation begins.

Sasha O’Connell, Idaho’s Medicaid Administrator, said “the vast majority” of expansion enrollees “were already meeting the new requirements.” She added that those not initially captured in the data review will still have the opportunity to submit documentation demonstrating compliance.

To satisfy the earnings-based pathway, enrollees need to show at least $580 in earnings across three consecutive months, though qualifying hours can also be met through non-paid activities such as volunteering or coursework.

Projected Coverage Losses

Not all analysts expect a smooth transition for the full enrollee population. Researchers at the Urban Institute and the Robert Wood Johnson Foundation have projected that 20,000 to 34,000 Idahoans could lose Medicaid expansion coverage by 2028 as a result of the new requirements and accompanying administrative changes.

That estimate represents a substantial share of the current expansion population, and advocates for low-income Idahoans have pointed to the shortened re-application cycle and documentation burdens as potential barriers — particularly for workers in irregular or informal employment.

State officials, however, have emphasized that the preliminary data is encouraging, and that enrollees will have time and pathways to demonstrate eligibility before the January start date.

What Comes Next

With implementation roughly six months out, Idaho’s Department of Health and Welfare is expected to continue outreach and system preparation through the remainder of 2026. Enrollees who were not captured in the initial review will need to submit documentation of qualifying work history before the rules take effect.

The six-month re-application requirement also means that the administrative burden on both enrollees and state staff will increase on an ongoing basis once the program launches. Officials have not yet detailed the specific outreach or notification process for the roughly 14,600 enrollees whose records did not initially confirm compliance.

Broader Policy Context

The Medicaid work requirement push is part of a broader shift in federal and state health policy under the current administration. Idaho’s Republican-controlled Legislature embraced the change in April, positioning the state as an early adopter alongside a small number of other states implementing the maximum lookback period allowed by federal rules.

The move fits within a wider pattern of Idaho policymakers aligning state programs with the Trump administration’s domestic policy priorities. Gov. Little has also joined other governors at the White House this year to coordinate on federal-state policy matters, reflecting the administration’s outreach to Republican-led states on shared legislative goals.

For Idaho’s expansion population, the practical test of the new requirements begins January 1.