Medicaid Work Requirements: What Changes January 1, 2027
If you're 19 to 64 and get Medicaid through your state's expansion, you may soon need to show 80 hours a month of work, school, job training or volunteering. Here's what starts when, who's exempt, how your state will check, where things stand in each of the 42 jurisdictions where our agent is licensed, and your options if you lose coverage.
Talk to a Licensed Advisor ↓What Are the Medicaid Work Requirements?
Medicaid work requirements (the law calls them “community engagement”) are a new federal condition for adults in the Medicaid expansion group, and certain waiver groups, to get or keep coverage. They come from section 71119 of Public Law 119-21 (H.R. 1, signed July 4, 2025), which adds section 1902(xx) to the Social Security Act. CMS calls the law the “Working Families Tax Cut” legislation; it was also called the “One Big Beautiful Bill.” The national start date is January 1, 2027.
A few states moved first. Nebraska started on May 1, 2026 and Montana on July 1, 2026. Arkansas began a no-penalty soft launch on July 1, 2026, and Iowa starts December 1, 2026 for new applicants. Seven states aren't required to run it at all. Only your state Medicaid agency decides who gets Medicaid, and FreedInsure doesn't enroll anyone in it, but we can explain the rules and compare your other coverage if you're over the limit or lose Medicaid.
FreedInsure LLC is an independent broker; its licensed agent, Constantino Lardi (NPN 20230457), is licensed in 42 jurisdictions. Our help is free to you: (844) 788-3733. This page is general information, not legal advice.
Quick answer (as of October 7, 2026): Medicaid work requirements start January 1, 2027 for adults 19–64 in the expansion group and certain waiver groups in 43 states and DC, unless exempt. To count a month, you need 80 hours of work, volunteering or job training, at least half-time school, or income of at least $580 a month (the 2026 figure).
Last updated: October 7, 2026
Medicaid Work Requirements 2027: What Starts When
The federal deadline is January 1, 2027, but some states started early and the rules phase in through 2028. The statute requires states to begin no later than the first day of the first quarter after December 31, 2026, and lets them start sooner. If you're already enrolled, your state checks you at your first renewal on or after its start date (42 CFR 435.559(c)).
- July 4, 2025: Public Law 119-21 is signed. Section 71119 creates the requirement.
- December 8, 2025: CMS issues a CMCS Informational Bulletin on the requirement.
- March 6, 2026: CMS issues guidance on 6-month renewals for expansion adults (SMD #26-001).
- May 1, 2026: Nebraska starts, the earliest of the states starting before the federal date.
- June 1, 2026: CMS issues its interim final rule. It was published June 3 in the Federal Register (91 FR 33348) and took effect July 31, 2026.
- July 1, 2026: Montana starts. Arkansas begins a soft launch in which, its DHS says, “you will not lose benefits.”
- October 2026: Montana's FAQ said there would be no denials or disenrollments from July through September; from October, people “may be denied coverage or disenrolled.”
- December 1, 2026: Iowa starts for people who apply on or after that date.
- January 1, 2027: National start. Expansion adults move to renewals every 6 months, and expansion adults who apply get no more than one month of retroactive coverage before the month they apply.
- January 1, 2028: Stricter proof rules. States must require documentation whenever it's reasonably available.
- December 31, 2028: The latest date any state delay can last.
Can your state delay it?
Only with a federal “good faith” exemption, which must end no later than December 31, 2028. The law says the requirement itself can't be waived, and CMS's rule limits a first exemption to 6 months. As of October 7, 2026, we found no CMS approval of a delay for any state. Alaska's Department of Health says the state has asked for more time, and Healthcare Dive reported on October 2, 2026 that five governors had asked HHS to push back the January 1 deadline. Until a delay is approved, plan on January 1, 2027.
What's still in court
Twenty-five states and DC sued CMS in Massachusetts v. Oz (D. Mass.), mainly over how the rule defines “medically frail.” The judge denied a preliminary injunction on July 29, 2026, and a summary-judgment hearing is set for October 20, 2026. The CMS rule stays in effect while the case goes on, and being a plaintiff doesn't delay the requirement in a state.
Who Has to Meet the Medicaid Work Requirements?
Adults ages 19 to 64 in the ACA Medicaid expansion group must meet the requirement unless an exemption applies. It also covers adults 19 to 64 in certain Section 1115 waiver programs that give comparable coverage. It never applies to children, people on Medicare, or pregnant or postpartum people, and it doesn't apply in the U.S. territories.
CMS has named 13 waiver populations in eight states: Georgia (Pathways to Coverage), Hawaii (QUEST Integration), Massachusetts (MassHealth), New York (Medicaid Redesign Team TANF group), Oregon (Oregon Health Plan), Tennessee (TennCare III parent and caretaker relatives expansion), Utah (Adult Expansion and Targeted Adults) and Wisconsin (BadgerCare Reform childless adults). Georgia, Tennessee and Wisconsin haven't expanded Medicaid, so only those waiver groups are affected there.
Six-month renewals come with it
A separate part of the law moves adults in the expansion group to renewals every 6 months, starting with renewals scheduled on or after January 1, 2027. CMS says that applies to people in the expansion group even if they're exempt from the work requirement; the one exception is American Indians and Alaska Natives, whom the law exempts from 6-month renewals. Other Medicaid groups, such as children's coverage, stay on 12-month renewals.
Not sure which group you're in or whether your income qualifies? See our guide to Medicaid income limits: in expansion states, adults generally qualify up to 138% of the federal poverty level.
What Counts Toward the Medicaid 80 Hours?
You meet the requirement for a month by doing any one thing in this table, or by combining activities to reach 80 hours. The definitions come from the statute and CMS's rule at 42 CFR 435.552. Your state decides what proof to ask for.
| Way to Qualify for a Month | What Counts Under the Federal Rule |
|---|---|
| Work, 80 hours | Work for pay, work in exchange for goods or services (“in-kind” work), and unpaid work other than community service. |
| Community service, 80 hours | Unpaid work through a structured program run by a public or nonprofit organization that tracks your hours, done for the direct benefit of the community. Court-ordered service can count; work for a partisan purpose doesn't. |
| Work program, 80 hours | Programs such as WIOA title I job training, Trade Act programs, state employment and training programs (including SNAP E&T), DOL and VA veterans' programs, and SNAP workforce partnerships. Job search counts only as a smaller part, less than half the hours. |
| School, at least half-time | Counts on its own, with no hours to log. College, career and technical education, high school and state-approved high school equivalency programs qualify. The school sets your enrollment status, and it carries through breaks. |
| School, less than half-time | The hours count toward 80. In credit-hour programs, each credit hour counts as 3 hours a week times 4.33 weeks, or about 13 hours a month. |
| A mix of activities | Any combination of work, community service, a work program and less-than-half-time school that adds up to 80 hours in the month. |
| Income of at least $580 | Monthly income of at least 80 times the federal minimum wage of $7.25, which is $580 a month in 2026. CMS uses “the individual’s MAGI-based income, for their MAGI-based household.” |
| Seasonal work | A seasonal worker whose average monthly income over the past 6 months is at least $580. |
How the Medicaid 80 hours are counted when pay is low
If you earn less than $580 in a month and your state has no record of your hours, CMS lets the state estimate them by dividing your income by the federal minimum wage. CMS's own example: $380 divided by $7.25 credits about 52 hours, so you'd need about 28 more hours from another activity (our arithmetic).
Two cautions. If you're in school at least half-time, the state can't add other hours on top, because half-time school already qualifies. And each month is counted on its own; Oklahoma's Medicaid agency, for example, says hours can't roll over between months. The $580 figure is tied to the federal minimum wage, so treat it as the 2026 amount.
Who Is Exempt From Medicaid Work Requirements?
Federal law exempts a long list of groups, and every state must honor them. Some people are outside the requirement altogether; others are treated as meeting it for the month. Either way, you don't have to show 80 hours, and your state may use records it already has instead of asking you for proof.
| Exempt Group | Who Qualifies Under the Current CMS Rule |
|---|---|
| Parents and caregivers | A parent, guardian, caretaker relative or family caregiver of a dependent child 13 or younger, or of a person with a disability. A caregiver who neither lives with nor is related to the person must give at least 80 hours of care a month. |
| Pregnant or postpartum | Anyone who is pregnant or getting postpartum Medicaid coverage. |
| Medically frail or special medical needs | Includes people who are blind or disabled, or who have a substance use disorder, a disabling mental disorder, a disability that significantly impairs one or more activities of daily living, or a serious or complex medical condition. The condition must significantly impair your ability to meet the requirement, and people in stable recovery for 5 or more years aren't in the substance use category. |
| Disabled veterans | A veteran with a disability rated as total (100 percent) by the VA. |
| SNAP or TANF work rules | People complying with TANF work requirements, or members of a SNAP household who aren't exempt from SNAP's work requirement. |
| Drug or alcohol treatment | People in a drug addiction or alcohol treatment and rehabilitation program. States may set a minimum time commitment. |
| American Indians and Alaska Natives | Indians, Urban Indians, California Indians and others eligible for Indian Health Service care. |
| Former foster youth | Former foster care youth under 26 in that Medicaid group. |
| Jail or prison | People who are incarcerated, and people released within the past 3 months. |
| Under 19 or on Medicare | People under 19, or entitled to or enrolled in Medicare Part A or enrolled in Part B, for part or all of the month. |
| Another mandatory group | People who also qualify under certain other mandatory Medicaid eligibility groups named in the statute. |
The medically frail definition is the part being challenged in Massachusetts v. Oz, so it could change. A hospital stay is not one of the mandatory exemptions; it's one of the optional hardship exceptions below.
Short-term hardship exceptions (your state's choice)
States may also excuse a month when, for part or all of it, any of these applies:
- Inpatient care. You're in a hospital, nursing facility, inpatient psychiatric hospital or similar setting. You must ask for it.
- Disaster area. You live in a county under a federally declared emergency or disaster. This applies automatically.
- High unemployment. Your county's unemployment rate is at least 8 percent or 1.5 times the national rate, whichever is lower. The state must ask CMS first; then it's automatic.
- Medical travel. You or a dependent must travel outside your community for an extended time for care for a serious or complex condition that isn't available locally. You must ask for it.
In a KFF and Georgetown CCF survey from March 2026, 34 states planned to use each of these exceptions, 3 said no (Indiana, Iowa and Missouri) and 6 were undecided; Tennessee wasn't surveyed. State pages can differ: Montana says it won't use the high-unemployment exception for now.
Think you're exempt? Tell your state Medicaid agency, answer every notice and keep your proof. For medical frailty, states may accept your own statement made under penalty of perjury until January 1, 2028; after that, they can accept one only once per enrollment period. Once your frailty status is verified, it must be rechecked at least every 12 months.
How Will Your State Check, and How Often?
States check at application and at every renewal, and expansion adults renew every 6 months starting in 2027. States may check more often: in KFF's March 2026 survey, Indiana and New Hampshire planned quarterly checks.
When you apply: the look-back
You show you met the requirement for 1 to 3 consecutive months right before the month you apply; your state picks the number. CMS's example: if you apply in January 2027, you'd show December 2026, or October through December 2026 in a state that picks 3 months. In the March 2026 survey, 36 states planned a 1-month look-back at application, 3 planned 3 months and 4 were undecided.
When you renew
You show at least one month that met the requirement between your last eligibility decision and your next renewal. Your state can require more months, and they don't have to be in a row. Some states ask for more: North Carolina and Kentucky want 3 of the 6 months before renewal, Iowa any 2 months in the review period, and Montana at least 3 months.
Data first, then paperwork
Your state must check reliable data it already has, such as payroll records, before asking you for documents. Through 2027, states may require documents or accept other information. Starting January 1, 2028, they must require documentation whenever it's reasonably available.
If the state can't verify you
You get a notice of noncompliance and 30 calendar days from when it's received (CMS treats it as received 5 days after the date on the notice) to show you met the requirement or qualify for an exemption. If you're enrolled, your coverage continues during those 30 days. If you don't make that showing, the state denies the application or ends coverage no later than the end of the month after the 30 days run out. First it must check whether you qualify for Medicaid or another affordability program some other way, and send written notice with your fair-hearing rights. Missouri, for example, says you have 35 calendar days to respond to its notice.
Protect your coverage: keep your address, phone and email current with your state Medicaid agency; open every letter; keep pay stubs, school enrollment records or volunteer-hour logs; and tell the state if you think you're exempt. States must tell enrollees about the requirement, before it starts and periodically after, by regular mail (or electronically if you chose that) plus at least one other way, such as a phone call, text or website.
Medicaid Work Requirements by State: The 42 Jurisdictions We Serve
The requirement applies in 35 of the 42 jurisdictions where FreedInsure's agent, Constantino Lardi, is licensed, including DC. Nationally, KFF counts 44 jurisdictions (43 states and DC) that must run it. The only seven that don't are Alabama, Florida, Kansas, Mississippi, South Carolina, Texas and Wyoming; they haven't expanded Medicaid and have no affected waiver group. Our agent isn't licensed in Colorado, Connecticut, Idaho, Massachusetts, Minnesota, New Mexico, Rhode Island, Vermont or Washington, which are also subject.
Sources and dates: “Subject?” comes from KFF's Medicaid work requirements tracker, updated September 29, 2026, which uses CMS information released June 8, 2026. Status notes come from the state source named in each row, read September 30 to October 7, 2026. Where no source is named, the federal January 1, 2027 date applies.
| State | Subject? | Start and Status (Source) |
|---|---|---|
| Alabama | No | Not required: no expansion group and no affected waiver group (KFF) |
| Alaska | Yes (expansion) | Federal date is January 1, 2027, but Alaska's Department of Health says it has asked for more time; no approval found as of October 7, 2026 |
| Arizona | Yes (expansion) | Starts January 2027 (AHCCCS) |
| Arkansas | Yes (expansion) | No-penalty soft launch since July 1, 2026; fully starts January 1, 2027 (DHS) |
| California | Yes (expansion) | January 1, 2027 for Medi-Cal expansion adults (enacted 2026–27 state budget) |
| Delaware | Yes (expansion) | January 1, 2027 (DMMA) |
| District of Columbia | Yes (expansion) | January 1, 2027 (DHCF) |
| Florida | No | Not required (KFF) |
| Georgia | Yes (waiver group only) | Pathways to Coverage rules change January 1, 2027; current members aren't affected until their 2027 renewal (Georgia Pathways) |
| Hawaii | Yes (expansion and waiver) | January 1, 2027; for current members, not until their 2027 renewal (Med-QUEST) |
| Illinois | Yes (expansion) | Applies to new applicants who apply after 5:00 p.m. on December 31, 2026 (HFS) |
| Indiana | Yes (expansion) | January 1, 2027 for HIP applicants and redeterminations (FSSA); quarterly checks planned (KFF survey) |
| Iowa | Yes (expansion) | December 1, 2026 for new applicants; members with renewal dates in February 2027 or later (Iowa HHS) |
| Kansas | No | Not required (KFF) |
| Kentucky | Yes (expansion) | January 1, 2027; members show 3 of the 6 months before renewal (KHBE) |
| Louisiana | Yes (expansion) | January 1, 2027 for new applicants and members up for renewal (LDH) |
| Maine | Yes (expansion) | Federal date, January 1, 2027 |
| Maryland | Yes (expansion) | Federal date, January 1, 2027 |
| Michigan | Yes (expansion) | January 1, 2027 for applicants; members with renewals on or after March 1, 2027 (MDHHS) |
| Mississippi | No | Not required (KFF) |
| Missouri | Yes (expansion) | January 1, 2027; 35 days to respond to a notice (DSS) |
| Montana | Yes (expansion) | In effect since July 1, 2026; denials and disenrollment possible from October 2026 (DPHHS) |
| Nebraska | Yes (expansion) | In effect since May 1, 2026 (DHHS) |
| Nevada | Yes (expansion) | Federal date, January 1, 2027 |
| New Hampshire | Yes (expansion) | January 1, 2027, so applicants show December 2026 (DHHS); quarterly checks required by state law (KFF) |
| New Jersey | Yes (expansion) | January 1, 2027 for NJ FamilyCare Plan ABP adults (DMAHS) |
| New York | Yes (expansion and waiver) | January 1, 2027 (NY State of Health) |
| North Carolina | Yes (expansion) | January 1, 2027; 3 months in a row before you apply, 3 of 6 months at renewal (NC Medicaid) |
| North Dakota | Yes (expansion) | January 1, 2027 (ND HHS) |
| Ohio | Yes (expansion) | January 1, 2027 (ODM) |
| Oklahoma | Yes (expansion) | January 1, 2027 (OHCA) |
| Oregon | Yes (expansion and waiver) | Starting in 2027, at application or renewal (OHA) |
| Pennsylvania | Yes (expansion) | Federal date, January 1, 2027 |
| South Carolina | No | Not required (KFF) |
| South Dakota | Yes (expansion) | January 1, 2027 (DSS) |
| Tennessee | Yes (waiver group only) | Federal date, January 1, 2027; CMS lists the TennCare III parent and caretaker relatives expansion group |
| Texas | No | Not required (KFF) |
| Utah | Yes (expansion and waiver) | January 1, 2027 for Adult Expansion and Targeted Adult Medicaid (DHHS) |
| Virginia | Yes (expansion) | Federal date, January 1, 2027 |
| West Virginia | Yes (expansion) | January 1, 2027; current members starting with renewals due in March 2027 (DoHS) |
| Wisconsin | Yes (waiver group only) | January 1, 2027 for new applicants in the affected BadgerCare Plus adult group; most current members at their renewal from March 2027 (DHS) |
| Wyoming | No | Not required (KFF) |
In the seven “No” states, the federal Medicaid work requirement doesn't apply because the state didn't expand Medicaid and has no affected waiver group. Adults there often face a different problem, the coverage gap; our free and low-cost health insurance guide and state pages cover the options.
FreedInsure doesn't sell ACA Marketplace plans in DC, Maine, Maryland, Nevada, Pennsylvania or Virginia; DC residents use DC Health Link. In Maine, Maryland, Nevada, Pennsylvania and Virginia we can help with private plans sold outside the Marketplace, short-term plans where state law allows and plans are sold (none are currently sold in Maine), and supplemental and life insurance. In DC, we can help with life and supplemental coverage.
Lost Medicaid Over the Work Requirement? Your Options
You can reapply at any time once you meet the requirement or qualify for an exemption. The CMS rule bars states from restricting your ability to reapply (42 CFR 435.558(e)), and the notice of noncompliance must explain how to reapply. Our guide to applying for Medicaid walks through each step.
Why a Marketplace subsidy isn't the fallback
If you're denied or disenrolled only because you didn't meet the work requirement, you can't get Marketplace premium tax credits for those months. The law treats you as eligible for Medicaid, which counts as minimum essential coverage, for any month you would have qualified except for this rule. CMS says such a person “is precluded from eligibility for APTC and PTC.” Wisconsin's Department of Health Services says people who lose Medicaid this way can use the federal Marketplace but “will not qualify for Advance Premium Tax Credits,” and Get Covered Illinois says they “will not be eligible for tax credits.”
The bar applies to subsidies, not to buying coverage, and only to months you'd otherwise qualify for Medicaid. So for those months, you can't use a premium tax credit to lower the cost of any option below.
✅ Get Back on Medicaid
Usually the most affordable route. Meet the 80 hours or the income test for the look-back period, or show an exemption, and reapply. Children are never subject to the requirement and may still qualify for Medicaid or CHIP.
🏢 Coverage Through a Job
If you or a family member has a job with a health plan you're eligible for but didn't join, federal law generally lets you ask to join within 60 days after Medicaid coverage ends because you lost eligibility (29 U.S.C. 1181(f)(3)). Ask HR right away; the plan's rules decide who's eligible, and you'll pay your share of the premium.
📅 A Full-Price Marketplace Plan
You can buy a Marketplace plan without a tax credit during Open Enrollment, November 1, 2026 to January 15, 2027 on HealthCare.gov (state exchanges can set different dates). Don't assume losing Medicaid this way opens a mid-year enrollment window; ask the Marketplace before you count on one.
📋 Private Plans Outside the Marketplace
An option where you're eligible, but at full price. Each plan has its own eligibility rules and may be subject to underwriting. Ask us to confirm in writing how a plan handles pre-existing conditions. Marketplace plans must cover them.
⏳ Short-Term Plans, Where Allowed
Temporary coverage that usually excludes pre-existing conditions, can turn you down based on your health and isn't ACA-compliant. How long you can keep one depends on your state and the plan, and some states, including Illinois, don't allow them.
🏥 Community Health Centers
Not insurance, but a place to get care. HealthCare.gov points people without other options to community health centers, which offer sliding-scale care based on income.
About private plans sold outside the Marketplace: These plans are not sold through the ACA Health Insurance Marketplace (HealthCare.gov or your state's exchange) and are not individual-market ACA plans. You can't use a premium tax credit or cost-sharing reduction to pay for them. As HealthCare.gov puts it, “the only way to get the premium tax credit is through the Marketplace.” See how private health insurance works and short-term health insurance for details.
Important: Plans sold outside the ACA Marketplace may be subject to underwriting, age limits, state availability and each plan's own eligibility rules. Not all plans are available in all states. Rates are not guaranteed and can change. Benefits, limits and exclusions are set by the official plan document or policy, which controls if it differs from this page. This page is a general summary, not a contract or an offer of coverage.
Straight talk: A plan sold outside the Marketplace can cost less than a full-price ACA plan if you're healthy, earn too much for a tax credit, or want a specific network. But if you qualify for a tax credit or Medicaid, have a pre-existing condition, are pregnant or planning to be, or take expensive medications, an ACA plan is usually the safer buy, and the only way to get the premium tax credit is through the Marketplace. If you lost Medicaid over the work requirement, getting back on Medicaid, by meeting the requirement or showing an exemption, is usually the most affordable path, because no tax credit applies to the months the subsidy bar covers. If your income has risen above your state's Medicaid limit, the bar doesn't apply to those months and you may qualify for a Marketplace tax credit instead. Where we sell Marketplace plans, we'll price both side by side before you decide; in DC, Maine, Maryland, Nevada, Pennsylvania and Virginia we don't, so we'll point you to your state's exchange. Call (844) 788-3733.
Sources
- Public Law 119-21 (GPO) — sections 71107 (6-month renewals) and 71119 (community engagement), enacted July 4, 2025.
- CMS interim final rule, 91 FR 33348 (June 3, 2026) — 42 CFR 435.550–435.563: definitions, exemptions, verification, notices and the $580 figure.
- CMS fact sheet on the interim final rule — issued June 1, 2026.
- CMCS Informational Bulletin (December 8, 2025) — look-back example and the bar on premium tax credits.
- CMS SMD #26-001 (March 6, 2026) — 6-month renewals for expansion adults.
- CMS IFC overview deck (July 2026) — 13 waiver populations in eight states.
- KFF Medicaid work requirements tracker — 44 jurisdictions subject, updated September 29, 2026; state survey tables from March 2026 (with Georgetown CCF).
- O'Neill Institute litigation tracker: Massachusetts v. Oz — preliminary injunction denied July 29, 2026.
- Healthcare Dive (October 2, 2026) — governors' letter asking HHS for a delay.
- State Medicaid agencies: Nebraska DHHS, Montana DPHHS, Iowa HHS, Arkansas DHS, Georgia Pathways, Alaska DOH, Wisconsin DHS, Missouri DSS, NC Medicaid, Kentucky KHBE and Oklahoma OHCA; other state notes as named in the table.
- Get Covered Illinois: marketplace changes — no tax credits after a work-requirement denial.
- 29 U.S.C. 1181(f)(3) (govinfo) — 60 days to request employer plan enrollment after Medicaid ends because of loss of eligibility.
- HealthCare.gov: dates and deadlines — Open Enrollment for 2027 coverage; Medicaid expansion and you — community health centers.
How FreedInsure Helps
FreedInsure LLC is an independent insurance broker; its licensed agent, Constantino Lardi (NPN 20230457), is licensed in 42 jurisdictions. We don't decide Medicaid eligibility or enroll anyone in Medicaid; only your state Medicaid agency does that. What we do: point you to your state's application and show you your other options. Where we sell Marketplace plans, that includes any Marketplace tax credit you qualify for, next to any private plan; in DC, Maine, Maryland, Nevada, Pennsylvania and Virginia, we don't sell Marketplace plans and will point you to your state's exchange. Our help is free to you.
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Important: Plans sold outside the ACA Marketplace may be subject to underwriting, age limits, state availability and each plan's own eligibility rules. Not all plans are available in all states. Rates are not guaranteed and can change. Benefits, limits and exclusions are set by the official plan document or policy, which controls if it differs from this page. This page is a general summary, not a contract or an offer of coverage.
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