Nebraska is the first state to enforce a Medicaid work requirement, and the first numbers show people losing coverage over paperwork. Researchers at Georgetown University’s Center for Children and Families count at least 1,090 Nebraskans who have lost coverage or been denied at application since the rule began. In an analysis posted Sept. 30, executive director Joan Alker called the figure a floor, not a final count.
The state’s Department of Health and Human Services released the data on Sept. 29. Human Rights Watch, working from the same release, puts the total at over 1,000 people lost or denied for May through August.
The rule applies to adults covered through Nebraska’s Medicaid expansion. According to the state’s work requirements page, a member must complete at least 80 hours in a calendar month of work, school or an apprenticeship at least half time, a work program or volunteering, or earn $580 in a calendar month, which is 80 hours at the federal minimum wage. Exemptions include parents or caretakers of a child 13 or younger, veterans with a total disability rating, people with a medical condition that prevents work, members of federally recognized tribes, pregnant or postpartum women and people in treatment for drug or alcohol use. When DHHS asks for more information, the page says a member “must submit the information within 30 days of getting the notice, or you may be denied or lose coverage.”
An exemption only counts if it is documented before a 30-day notice runs out, and that is where Nebraska’s numbers show people slipping. The SNAP & Medicaid Renewal Organizer explains the new Medicaid work requirement and who is exempt.
See how the Medicaid work requirement and its exemptions work in the Renewal Organizer →
Where the losses come from
Alker’s analysis ties most of the losses to missing paperwork rather than to people who failed to meet the rule. Among existing enrollees who lost coverage at renewal, 92 percent were denied for failing to provide the information requested to show they met the requirement or qualified for an exemption. Among new applicants whose denial reasons were clearly reported, 84 percent were procedural. “They are very effective at taking Medicaid coverage away by tangling folks up in red tape,” Alker wrote.
The data also show 2,449 people kept coverage because they met the qualifying-activity test, and 97 percent of them did it through the $580-a-month income route. It also lists 4,434 new applicants who were unable to enroll for “any other reason.” Alker said it is unclear whether that group includes people stuck on paperwork and called it “a key question for the state to answer.” She also noted that more than half of new applicants are now being denied and said she would like to see the denial rate from before the policy.
The January deadline for other states
The federal version is on its way. The Centers for Medicare & Medicaid Services says in its June 1 fact sheet that “states must generally implement this requirement no later than January 1, 2027,” and a state may start earlier. Adults in expansion states have to show 80 hours a month of qualifying activity, with exemptions for groups such as former foster care youth, American Indians and Alaska Natives, and people who are medically frail.
Human Rights Watch counts about 20 million adults in the 40 states and the District of Columbia with expanded Medicaid as affected. Matt McConnell, a researcher with the group, called Nebraska “the canary in the coal mine” for problems other states will face. Nebraska began on May 1 for applicants and July 1 for current enrollees, before CMS issued its June interim rule on medically frail exemptions, and Alker wrote that the state must tell CMS in October how it will change its process for them.
What Nebraska’s own advocates say
Amy Behnke, who leads the Health Center Association of Nebraska, told Human Rights Watch that “the biggest concern is the administrative burden” placed on patients, and that without detailed data “we’re flying blind.” Sarah Maresh, health care access program director at Nebraska Appleseed, said, “You can’t fix problems you refuse to measure.” Human Rights Watch says the department has been slow to release figures and that the count is likely to grow as it reviews enrollees on a rolling basis.
Answering a Nebraska Medicaid request in 30 days
The state’s work requirements page is the free official route. Members can respond online at iServe Nebraska, by mail to P.O. Box 2992, Omaha, NE 68103-2992, or by phone at (855) 632-7633, option 3. DHHS checks each member in the month their coverage is up for renewal, starting with coverage periods that end on or after July 31, 2026, and members with May or June renewal dates do not have to show compliance until their 2027 renewal.
Before a notice arrives, it helps to gather the documents that prove the claim: pay records showing $580 in a month, or timesheets, school or volunteering records that add up to 80 hours. For an exemption, gather the proof for that category, such as a doctor’s statement for a medical condition or a disability rating letter for a veteran. The 30 days run from the date the notice is received, so a stack of mail left unopened can cost a member coverage.
92 percent of Nebraska renewal denials were paperwork
Georgetown’s analysis found that 92 percent of the people denied at renewal were denied for not providing the information the state asked for. The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, so the right exemption is identified before a notice starts the clock. It is a 20-page organizer.
Sort out an exemption before a 30-day Medicaid notice with the Renewal Organizer →
This article was produced with AI assistance and edited for accuracy against the sources linked above.




