Beginning next year, roughly 85,000 Idahoans enrolled in Medicaid expansion will need to demonstrate they are working to maintain their health insurance coverage. Those who cannot work due to school attendance, caregiving responsibilities, or documented medical fragility may qualify for exemptions—but proving that last category has become significantly more complicated under new federal rules.
The federal Centers for Medicare and Medicaid Services narrowed the definition of “medically frail” in June, requiring evidence of both a serious health condition and substantial work impairment. Idaho’s Department of Health and Welfare will not invoke a federal one-year grace period that would allow individuals to self-attest their exemption status. Instead, the state has adopted a two-tier verification process that begins with attestation but quickly shifts to requiring medical records.
How Idaho’s Verification System Works
When Medicaid expansion enrollees first encounter work requirements, Idaho will accept their written attestation of medical frailty without immediate documentation. However, ongoing verification will depend on what the state’s claims data already contains. If records show no recent doctor visit, hospital stay, or other healthcare interaction, the department will request medical documentation directly from applicants.
Sasha O’Connell, the Idaho Medicaid Administrator, indicated the state will evaluate whatever medical records individuals submit. “The department will review any medical documentation submitted, but the most straightforward documentation will be a note from their health care provider,” O’Connell said.
The state intends to combine its own medical claims database with notes and records from healthcare providers to determine ongoing eligibility for the medical frailty exemption. This hybrid approach means people without recent interaction with the healthcare system may face particular difficulty proving their condition.
Who Is Most at Risk
Initial reviews conducted this year showed that 68,400 Idahoans on Medicaid expansion already satisfied work requirements. However, independent analysis from the Urban Institute and the Robert Wood Johnson Foundation suggests between 20,000 and 34,000 people could lose Medicaid coverage by 2028 if they fail to meet requirements or secure exemptions.
It is important to note that Medicaid expansion serves a different population than traditional Medicaid. The vast majority of Idahoans relying on Medicaid for disability services are enrolled in traditional Medicaid, which does not impose work requirements. Medicaid expansion primarily covers low-income working-age adults without disabilities.
Still, people with serious diagnoses face an unexpected burden. Randy Johnson, government relations director for the American Cancer Society Cancer Action Network Idaho, described the stakes for those battling critical illnesses. “If somebody is diagnosed with cancer, it’s already a full-time job in itself…the ability to have your insurance being taken away by another set of bureaucracy that’s put in front of people – it’s terrifying,” he said.
The Broader Policy Divide
Idaho’s approach reflects broader disagreement between Republican and Democratic-led states over federal Medicaid policy. Twenty-five states led by Democrats have sued to challenge the narrowed definition of medical frailty published in June. Idaho’s Republican leadership has declined to seek the federal grace period, moving instead toward expedited verification of exemption claims.
The decision to require medical documentation rather than accept ongoing self-attestation aligns with the stricter interpretation of federal guidance, but it may create barriers for people without consistent access to healthcare providers or those unable to navigate bureaucratic documentation processes.
What Comes Next
The new work requirements take effect in 2027. Medicaid expansion enrollees should begin gathering medical documentation now if they believe they qualify for a medical frailty exemption. Those with recent healthcare provider interactions should ensure their medical records are current and available to Idaho’s Department of Health and Welfare upon request. Individuals facing barriers to work due to health conditions should consult with their healthcare providers about documenting their situation before the transition deadline.