The Michigan Department of Health and Human Services (MDHHS) has released a proposed Medicaid policy outlining significant changes to Healthy Michigan Plan (HMP) eligibility requirements in preparation for the January 1, 2027, implementation of federal Medicaid requirements under H.R. 1.
The MDHHS Proposed Policy 2636-Eligibility addresses three key changes:
- Work Requirements: Establishes work or other qualifying activity requirements for certain HMP beneficiaries, with exemptions for eligible individuals.
- Six-Month Eligibility Renewals: Shortens HMP eligibility renewal periods from 12 months to six months.
- Retroactive Medicaid Coverage: Reduces retroactive coverage from three months to one month for HMP beneficiaries and two months for individuals enrolled in other Medicaid programs.
These changes may have important implications for patients, physicians, and practices, particularly regarding continuity of coverage, eligibility verification, and reimbursement for services provided before Medicaid enrollment.
Although the policy is scheduled to take effect January 1, 2027, current HMP beneficiaries who are subject to the new work requirements will first be reviewed at renewals beginning March 1, 2027.
Comments on the proposed policy must be submitted by November 23, 2026. Physicians, practices, and other stakeholders are encouraged to review the proposal and provide feedback on potential implementation and patient care impacts.
Review the proposed policy: MDHHS Proposed Policy 2636-Eligibility-P (PDF)
Submit comments to: Kayla Lowers, MDHHS, at LowersK@michigan.gov by November 23, 2026.
For more information, contact Dara J. Barrera, Michigan State Medical Society (MSMS) Director, Health Quality, Equity and Technology, at 517-336-5770 or djbarrera@msms.org.