West Virginia’s Department of Human Services says about 33,000 Medicaid recipients do not currently meet the state’s new 80-hour work or volunteer rule, and about 119,000 more are automatically excluded from it. The rule starts January 1, 2027. The two counts describe different groups, and the line between them decides who has to start proving hours.

Two groups, two counts

The numbers come from a Department of Human Services analysis presented to a legislative oversight committee in August by Christy Donohue, commissioner of the department’s Bureau for Medical Services. The 33,000 are recipients who do not meet the federal requirement today and are not exempt. The 119,000 are recipients the rule leaves out automatically.

For a household, the practical question is which side it falls on. Someone in the 119,000 group has nothing to prove. Someone in the 33,000 group will need to show 80 hours a month of work, training or volunteering. The Bureau for Medical Services asks members to update contact information, watch for notices from the department and call 1-877-716-1212 with questions.

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Donohue said in the department’s June announcement that “our responsibility is to ensure West Virginians have accurate information.” The Bureau for Medical Services page adds that members should look for additional contact from the department and from the federal Centers for Medicare and Medicaid Services about the new rules.

The state counted a third group as well. About 4,460 recipients already meet the requirement, Donohue told lawmakers, West Virginia Watch reported. Together the three groups come to roughly 156,000 adults in the state’s Medicaid expansion population.

Why 33,000 may not hold

Donohue said of the 33,000: “That number could change and is likely a conservative estimate.” The analysis was done before a June federal interim final rule that tightened the medically frail exemption. States must now also consider whether a person’s condition affects their ability to meet the requirements.

The medically frail exemption is one of the main ways people stay out of the work test, so the department is trying to find those members itself. Donohue said it is working with other states, including Louisiana, to spot them through claims data, diagnosis codes, prescriptions and managed care records, “so that we are not putting the ownership back on the member.”

Ellen Allen, executive director of West Virginians for Affordable Healthcare, said many recipients are “putting together several jobs to make ends meet and they don’t have healthcare at any of those.” She pointed out that West Virginia has the lowest labor force participation rate in the country and said the deadline “may not be doable for some.”

Allen added that taking away health care “will only make it worse.” The department’s own figures put a number on the stakes: if the 33,000 estimate holds, that is roughly one in five of the expansion adults the state counted.

What the rule asks of the 33,000

The requirement comes from the federal One Big Beautiful Bill Act, which makes work, training or volunteering a condition of eligibility for certain adult Medicaid enrollees. The state is carrying it out through the Department of Human Services, and it has said the rollout is on schedule.

The requirement covers expansion adults ages 19 through 64. They must work, train or volunteer at least 80 hours a month, with exceptions. Donohue told lawmakers that in-kind and unpaid hours can now count, including work for agencies beyond nonprofits.

A separate change took effect October 1, 2026, when eligibility shifted for certain non-citizen categories. That change is not part of either count.

People in drug addiction, alcohol treatment or rehabilitation programs are excluded. Someone with a substance use disorder who has been in recovery for five years or more is not exempt, and Donohue said that five-year rule is federal and the state cannot change it.

The department launched WVMedicaidHelp.org as its main source of information on the changes. Members are advised to update their mailing address, phone number and email, read eligibility mail from the department and watch for notices about actions required before January 1, 2027.

When coverage could actually change

The Bureau for Medical Services says the requirements will not apply to current members until their regularly scheduled renewal in 2027. People applying for Medicaid may need to meet them for the month before they apply, so an applicant for January 2027 may have to show hours from December 2026.

Because the state will look back at two months of work or volunteer history, West Virginia Watch reported that enrollment effects are not expected until March. The department says it is “on track to implement these requirements” and is upgrading its eligibility systems to confirm hours from electronic data where it can, according to its June announcement.

That leaves one open question for each household, and it is the one the department’s count cannot answer for anyone in advance: whether a given member lands among the 119,000 who are excluded or among the 33,000 who will need to document their hours.

Which West Virginia group is a household in?

Whether a recipient sits among the 119,000 excluded or the 33,000 who fall short decides who has to document hours from 2027, and the department has said its count could change. A household that waits for the notice to find out has less time to gather proof.

The SNAP & Medicaid Renewal Organizer explains the new Medicaid work requirement and who is exempt, and it adds a renewal and reporting calendar for tracking the dates that follow.

It includes 51 state packs, West Virginia among them, and a renewal document checklist for pulling the paperwork together ahead of a renewal.

Get the West Virginia pack with the work-rule exemptions →

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This article was produced with AI assistance and edited for accuracy against the sources linked above.