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New Hampshire Medicaid and the new work rules
Granite Advantage Health Care Program — this is New Hampshire's name for ACA expansion Medicaid, covering adults 19 through 64 is run by New Hampshire Department of Health and Human Services (DHHS), Division of Medicaid Services — eligibility is run by the Division of Economic and Housing Stability through district offices and the NH EASY online account. New Hampshire expanded Medicaid on August 15, 2014, which is why the new federal work requirement reaches this state — and why what you do before January 1, 2027 matters.
From January 1, 2027, most adults have to show 80 hours a month
The requirement applies to adults aged 19 to 64 covered through Medicaid expansion — around 47,984 people in New Hampshire. It is not only about paid work: study, job training, volunteering and a mix of them all count , and earning at least $580 a month satisfies it on its own.
New Hampshire has chosen to be stricter than the federal floor, and this is the single most important thing on this page after the exemption list. RSA 126-AA:6 says three things. You cannot be enrolled at application unless you demonstrate compliance for the one month immediately before the month you apply, and DHHS 'shall require documentary evidence and shall not accept self-attestation at the time of application.' Compliance must be verified 'on an ongoing basis, at least quarterly between redetermination periods' — more often than the six-month federal cycle. And exemptions must be verified too: DHHS may use records it already holds, or documents you provide, but 'shall not accept self-attestation from individuals seeking exemptions.' In practice that means a paystub, a school letter, a treatment provider's statement or a doctor's form, not your word for it.
If your hours swing from month to month, say so. The rule is written per month, which is the wrong shape for farm and fishing work, construction, tourism and seasonal retail — a good month and a dead month average out to a living, but the dead month is the one that fails. Federal law has a provision for exactly this: a seasonal worker can satisfy the requirement using their average monthly income over the previous six months instead of hours worked in the month being checked. It is at 42 CFR 435.552(a)(7), and the law defines who counts as seasonal by pointing at the tax code rather than listing jobs, so do not decide for yourself that it misses you. If your work is seasonal or your hours are irregular, tell the state that when you report, and ask for the six-month average to be used.
That is the range the state itself published.
The New Hampshire Fiscal Policy Institute, drawing on DHHS enrollment data, reports early estimates that anywhere from 14,000 to 29,000 New Hampshire Medicaid enrollees could lose coverage by 2028 — 28.2% to 58.5% of the Granite Advantage population as it stood in May 2026 — and says the figure depends heavily on implementation choices the state controls. That is a non-government estimate and is published here as such. The state's own closest statement is older and smaller: in April 2025, before the federal law passed, DHHS's Medicaid Director told a Senate committee that the department had expected about 20,000 people to lose coverage under the 2019 requirement, that it was about 16,000 when the program was halted, and that it expected a similar number again. DHHS has published no coverage-loss projection for the federal requirement.
Most of that is expected to be paperwork rather than people becoming ineligible. Which is the whole reason to sort out your address and your proof now rather than at the last minute.
You do not have to prove anything if any of these describe you
Exemptions are meant to be applied by the state automatically from records it already holds, but records are imperfect. If one of these fits you and you still get asked to report hours, say so and ask them to check — don't assume the notice is right.
What you can earn and still qualify
Monthly income, before tax, for the whole household. These are the state's own published figures, which is what its caseworkers actually apply. If you are close to a line, apply anyway — some income does not count, and only the agency can run the calculation for your situation.
Adults 19 to 64133% of the poverty line
- 1 person
- $1,769
- 2 people
- $2,399
- 3 people
- $3,028
- 4 people
- $3,658
- 5 people
- $4,288
- 6 people
- $4,917
- 7 people
- $5,547
- 8 people
- $6,176
Pregnant196% of the poverty line
- 1 person
- $2,607
- 2 people
- $3,535
- 3 people
- $4,463
- 4 people
- $5,390
- 5 people
- $6,318
- 6 people
- $7,246
- 7 people
- $8,174
- 8 people
- $9,101
Source: NH DHHS Medical Assistance Manual, PART 601 Table G — PIL, Granite Advantage, EMA, CM, CSD, Pregnant Women MA, FPEC MA and Expanded CM, with the 2026 poverty-guideline figures released by Supervisory Release SR 26-03 dated 03/26, effective March 1, 2026. A note on precision: New Hampshire never calls Granite Advantage a 138% program. We publish the state figure.
Two other changes land on the same day
Renewals get more frequent, and back-dated coverage gets shorter.
P.L. 119-21 §71112, amending 42 U.S.C. §1396a(a)(34). Applies to applications submitted on or after January 1, 2027.
New Hampshire has a law that would end expansion automatically
Coverage here is tied by statute to how much the federal government pays.
Who this reaches. The law covers every adult covered through Granite Advantage — 47,984 people in August 2026, about 29% of everyone on New Hampshire Medicaid.
Section 10, paragraph I of Chapter 3, Laws of 2014, as amended by Chapter 13, section 13, Laws of 2016 and Chapter 342, section 12, Laws of 2018 — an uncodified session-law provision rather than a numbered RSA section, which is why it is easy to miss. If at any time the federal match rate applied to medical assistance for newly eligible adults under RSA 126-AA is less than 90 percent in 2020 and any year thereafter in which the program is authorized, then RSA 126-AA and the granite advantage health care program established thereunder is hereby repealed 180 days after the event occurs, upon notification by the commissioner of the department of health and human services to the secretary of state and the director of legislative services, and consistent with the terms and conditions of any waiver approved by CMS. The commissioner must notify the Governor, the Speaker, the Senate President and the chair of the legislative fiscal committee within 48 hours, and notify program participants within 10 business days.
This is a hard trigger. It repeals the program by operation of law 180 days after the matching rate drops, with no further vote required, and the only discretion left to anyone is the mechanics of notification. KFF and Georgetown's Center for Children and Families both count New Hampshire among the small group of states whose trigger requires termination of expansion rather than merely some mitigating action. A DHHS spokesman has stated it to the press in one sentence: if federal support for Granite Advantage were reduced or eliminated, 'the program would be terminated in 180 days.' New Hampshire is unusually exposed because of how the program is funded. RSA 126-AA:2, I(a) requires Granite Advantage to be paid for 'exclusively from non-general fund sources,' RSA 126-AA:3, I forbids state general funds being deposited into its trust fund at all, and the state share comes from an insurance assessment, premium tax revenue, the Medicaid enhancement tax and liquor profits. New Hampshire Fiscal Policy Institute calculated that had the match fallen to 50% in state fiscal year 2025, the state would have needed about $249 million more for a program whose state-generated contribution that year was $61.2 million against total costs of $620.8 million. There is a second, separate termination duty too: RSA 126-AA:3, VI requires the commissioner to check quarterly whether the trust fund can cover the next six months, to draw on the liquor commission fund if not, and — if the liquor fund cannot cover the shortfall either — to terminate the program, notifying the Legislature within 48 hours and participants within 10 business days.
Unexercised. The expansion matching rate has not fallen below 90%, Granite Advantage has run continuously since January 1, 2019 and its predecessor since 2014, and nobody has lost coverage through this provision. It has never been tested, and because it sits in uncodified session law rather than the RSA chapter it governs, it does not appear when you read RSA 126-AA. The Legislature has looked at this and has not removed it: Senate Bill 401 of 2024 would have repealed the prospective repeal of Granite Advantage and its trust fund outright, including the 2023 extension, and did not become law, and an amendment that would have codified the 90% trigger inside RSA 126-AA:3 as a new paragraph VII is not in the current statute either. There is a second date worth knowing about, separate from the trigger and much less alarming. Granite Advantage has always had an expiry date and has always had to be renewed. The 2018 act that created it set the repeal for December 31, 2023; Chapter 79, section 407, Laws of 2023 moved it to December 31, 2030, and DHHS's own words to the Legislative Budget Assistant are that this "authorized the Granite Advantage Health Care Program through December 31, 2030." Every section of RSA 126-AA carries that repeal note at the head of its text. Unless the Legislature extends it again — which it has done every time the question has come up, most recently for seven years rather than five — the program ends at the end of 2030. That is also why New Hampshire has a standing commission to evaluate the effectiveness and future of the program at RSA 126-AA:4, which reports recommendations for legislation each November 1 and is itself repealed November 1, 2028.
Nothing has changed, and this is not a reason to delay applying. It is a reason to keep your contact details current, open everything the state sends, and not assume coverage renews itself.
Do this now
Update your address and phone number first. Everything about the new rules arrives by mail, and a stale address is the most common reason people lose coverage they are still entitled to. Then check whether an exemption applies to you.
About the phone numbers: One number does nearly everything in New Hampshire, which is simpler than most states, but a few details trip people up. DHHS publishes two different sets of hours for the same line: the Medicaid pages say Monday to Friday, 8:00am to 4:00pm Eastern, while NH EASY says 9:00am to 4:00pm. Call between 9 and 4 and you are safe either way, and the automated self-service runs around the clock. If you are calling about a renewal, press option 3 — the renewal page and the fee-for-service page both direct callers there, and it skips the general menu. And know which number you want: 1-844-275-3447 is DHHS, for applying, renewing, a notice you have been sent or an address change, and it is the number that matters for the new work rules; your health plan's own number is for finding a provider or a prior authorization.
Deaf, hard of hearing or speech-impaired: 1-800-735-2964.
Every page on the New Hampshire DHHS website carries a Get Help In Your Language link and a Relay NH number, 1-800-735-2964, at the foot. Interpreters for covered services are themselves a covered Medicaid benefit in New Hampshire — the department lists them among covered services alongside physician and hospital care — so asking for one at a medical appointment is asking for something Medicaid pays for, not a favor. For paperwork, Spanish is the one language with a full translated set: the Application for Assistance (Form 800), the children, pregnant women and parent/caretaker insert, and the Application for Health Coverage and Help Paying Costs (Form 800MA) all exist in Spanish. For the eligibility changes arriving now, DHHS has gone considerably wider: its page on the new rules for non-citizen adults publishes translated explainers in Arabic, Bosnian, French, simplified Chinese, Spanish, Kirundi, Kinyarwanda, Swahili, Haitian Creole, Nepali, Brazilian Portuguese, Russian and Thai, with a frequently-asked-questions sheet and a pocket card in Spanish as well. The language switcher on dhhs.nh.gov itself is Google Translate — useful for getting your bearings, not a translated document, so check anything that matters with a person on 1-844-275-3447.
Most people who lose coverage lose it over paperwork, not eligibility
Nationally, most people who lose Medicaid lose it over paperwork rather than because they stopped qualifying. From January 1, 2027 that matters more, not less.
NOTICE OF ELIGIBILITY DETERMINATION
Case number: ███████
Date of this notice: 1January 12, 2027
Our records do not show that you met the community engagement requirement for the reporting period.
2If you believe this is incorrect, or if an exemption applies to you, contact us on or before February 11, 2027.
3Coverage for other members of your household is not affected by this notice.
What the federal data says about coverage here
Public federal data describes how each state runs its program. Almost all of it is written for policy analysts. Here is what those numbers mean if you are the person enrolled.
Provider supply here is around the national middle.
Book an appointment before you need one, not when you do.
Coverage here runs through private health plans rather than the state paying providers directly. You pick a plan, and your plan decides your network.
Check your doctor is in the plan before you choose it.
Where you live in this state changes what coverage is worth. New Hampshire is a small state with a big empty top, and the North Country is where the new work rules and thin provider supply meet. DHHS's own 2024 Annual Report on the New Hampshire Health Care Workforce puts population density at 29.9 people per square mile in the North Country public health region against 675.1 in Greater Manchester, and primary care provider supply in the rural North Country at 119.2 full-time equivalents per 100,000 residents — down from 127.2 the year before, and against 144.4 in the rural Upper Valley. The department's 2023 edition states that the North Country, which is all of Coos County and part of Grafton, is federally designated as a health professional shortage area. DHHS says small rural hospitals 'make up 13 of the 26 acute-care hospitals in the state,' and all 13 are Critical Access Hospitals, capped at 25 beds; New Hampshire also has 10 federally qualified health centers and 15 rural health clinics across 63 sites. Nine of New Hampshire's ten counties are designated at least partial primary care shortage areas. The state's own commercial network adequacy rule, Ins 2701.06, shows what distance means here in regulation rather than rhetoric: in rural counties including Coos, a plan satisfies the standard with core services 30 miles or one hour away, common services 80 miles or two hours away, and specialized services 125 miles or two and a half hours away — against 10, 20 and 40 miles in Strafford, Hillsborough and Rockingham. New Hampshire Medicaid's own managed care standard does not vary by region: two primary care providers within 40 driving minutes or 15 miles, and one OB/GYN and one hospital within 60 driving minutes or 45 miles, statewide. There is money arriving: the Governor's Office of New Opportunities and Rural Transformational Health, GO-NORTH, was created to run New Hampshire's share of the federal Rural Health Transformation Program and received over $204 million for 2026. What none of that changes is the practical point for January 2027. If you live in Coos County, the hours are the same 80 as in Manchester, the exemptions are the same, and the thirty days you get to send in proof after a letter arrives are the same — but the paystub, the school letter or the doctor's certification may be a great deal harder to get hold of in time. Start before the letter. NH DHHS Rural Health and Primary Care Section, 2024 Annual Report on the New Hampshire Health Care Workforce and Data Collection, and the 2023 edition (dhhs.nh.gov/sites/g/files/ehbemt476/files/documents2/); NH DHHS, 'Rural Hospitals' (dhhs.nh.gov/programs-services/health-care/rural-health-primary-care/rural-hospitals) and the Critical Access Hospital Improvement Project solicitation RFA-2024-DPHS-08-CAHIP; HRSA Maternal and Child Health Bureau Title V state overview for New Hampshire; N.H. Admin. Code Ins 2701.06, Standards for Geographic Accessibility; SFY 2023 New Hampshire Network Adequacy and Validation Annual Report, prepared for NH DHHS (medicaidquality.nh.gov); NH DHHS, Rural Health Transformation Program / GO-NORTH
New Hampshire already ran a work requirement — and a federal court struck it down in 2019
You face one work requirement in New Hampshire, not two — and for a current Granite Advantage member it does not begin until that member's first redetermination in 2027.
New Hampshire's own policy manual is the clearest statement anywhere: sections 230.03, 230.07 and 230.09 each now say only "DHHS is prohibited from implementing the Granite Advantage community engagement requirement at this time," citing Philbrick v. Azar. DHHS's waivers page files the Granite Advantage demonstration under Archived Demonstrations and says it "is not enforceable at this time.".
100 hours a month of community engagement for Granite Advantage adults 19 through 64, reported monthly, with no carrying hours forward. Qualifying activities under RSA 126-AA:2, III were unsubsidized employment including by nonprofits, subsidized private or public sector employment, on-the-job training, job skills training including accredited college credit hours counted hour for hour, job search and job readiness assistance including time with Employment Security counsellors, vocational educational training up to twelve months, education directly related to employment for someone without a high school diploma, attendance at secondary school or a general equivalence course, community or public service, and participation in substance use disorder or mental health treatment or recovery activities.
A new member got at least 75 days' notice before the requirement started, and it always began on the first of a month. Miss a month and you got one month to cure it. Fail to cure and your case was suspended; a suspended case closed at the end of the redetermination month. Reapply within six months and you did not get a fresh 75-day notice period; reapply within 90 days and you faced a reconsideration requirement. Anyone whose exemption ended always got a new 75-day notice period. Good cause could reduce the hours required, calculated at 8 hours for each day you were prevented from participating, for things like the birth or death of a family member living with you, severe weather or a natural disaster, a family emergency or life-changing event such as divorce, or being a victim of domestic violence, dating violence, sexual assault or stalking.
It collapsed in three weeks. On July 8, 2019 DHHS reported that of the 24,766 Granite Advantage members subject to the requirement in June, it had no information at all about the compliance status of approximately 17,000 of them — about two thirds of everyone the rule applied to, and roughly a third of the whole expansion program — and that those people would be at risk of suspension in early August. The state's stated reason for stopping was its own ability to reach and counsel members, not the policy: Governor Chris Sununu signed Senate Bill 290 that same day, and Commissioner Jeffrey A. Meyers used the power it gave him to suspend the requirement through September 30, 2019. On July 29, 2019, in Philbrick v. Azar, 397 F. Supp. 3d 11 (D.D.C.), Judge James E. Boasberg vacated the federal approval under the Administrative Procedure Act, holding that the Secretary of Health and Human Services had failed to consider the requirement's effect on Medicaid coverage. The opinion notes that New Hampshire's rule was harsher than Arkansas's and Kentucky's — 100 hours rather than 80, across a wider age range — and that the Government conceded at argument that its reasoning had been deficient. HHS withdrew the approval in March 2021; New Hampshire did not appeal the withdrawal, which made it final.
The 2027 requirement is not the same kind of thing as the one that was struck down, and if you are waiting for the courts to do it again the ground has moved. In 2019 New Hampshire asked a federal official for permission to depart from the ordinary Medicaid rules; a court found he had not thought it through, voided the permission, and the ordinary rules snapped back. The 2027 requirement is the ordinary rule — Congress wrote it into the Medicaid statute itself at section 71119 of Public Law 119-21, and New Hampshire has no choice about applying it. There is no state waiver for anyone to challenge, no official whose reasoning can be attacked as arbitrary, and nothing for a court to vacate that would leave coverage as it was. The exact legal mechanism that won in 2019, review of an agency's reasoning, is not available against an act of Congress. Litigation over how the rule is being implemented does exist and is live, principally over the federal definition of medical frailty, and New Hampshire is not a party to it; nothing here predicts how that comes out, but a challenge to implementation details would not remove the requirement. Plan on it applying to you, and find your exclusion now if you have one.
There is one lesson from 2019 that transfers completely, and it is not about courts. The roughly 17,000 were not people who refused to work — the state never claimed that, and most Granite Advantage members were employed then as now. They were people the state could not get information from or about. New Hampshire's own fiscal analysts identified the mechanical reason at the time: unlike Arkansas, New Hampshire had no automatic cross-verification against other programs' data, so compliance depended on each member reporting by hand every month, and about three in four of those required to report failed to do so. The new federal rule is built the other way round, on checking state records first — New Hampshire's passive renewal rate has been above 75% since December 2023. The part of this you control is making sure the records DHHS checks have you in them and that your address is right.
The two rules never run side by side. RSA 126-AA:2, III is still in the statute book and still says 100 hours, but section 3 of Chapter 18, Laws of 2026 provides that the provisions of RSA 126-AA:2 directly related to the community engagement and work requirements "shall be suspended for the duration of the federal community engagement and work requirements under Public Law 119-21, Section 71119" — and that if the federal requirement is ever eliminated, the Commissioner must immediately certify the removal of that suspension in writing to the Legislature and the Governor. So the federal rule displaces the state one while it exists, and the state one waits underneath it.
Two pieces of the 2019 scheme are worth knowing about because they are more generous than the federal rule and are still written into New Hampshire law. RSA 126-AA:2, III(d)(9) exempts anyone homeless as defined by the McKinney-Vento Homeless Assistance Act, and III(d)(4) reaches a custodial parent or caretaker of a dependent child through 12 years of age or a child with developmental disabilities. The federal rule has no homelessness exclusion and states may not add one. If you are homeless, tell DHHS and ask them to check anyway — but do not rely on it, and look hard at the medically frail exclusion, which many people in that situation meet.
One point of precision about the 2019 numbers, because they are quoted loosely. DHHS's own determination letter of July 8, 2019 gives 24,766 members subject to the requirement with no compliance information for approximately 17,000 of them. At the press conference the same day the Commissioner was reported giving 24,895 subject and 16,874 without proof. New Hampshire Fiscal Policy Institute, from DHHS June data, gives 16,637 of 24,766. These are the same snapshot with slightly different caseload counts, and roughly 17,000 out of about 24,800 — close to two thirds of those subject — is the honest way to state it. National summaries that put the share at about 40% are using a larger denominator than the state's own.
NH DHHS Medical Assistance Manual sections 230.03, 230.07 and 230.09 (SR 19-31 dated 07/19); SR 19-03 dated 03/19 and SR 19-04 dated 06/19; NH DHHS Medicaid Waivers and Demonstrations page, Archived Demonstrations; RSA 126-AA:2, III; Chapter 18, Laws of 2026 (Senate Bill 134), section 3
Questions people ask about this
Do the new Medicaid work rules apply to me in New Hampshire?
How many hours a month do I have to work?
Who is exempt from the work requirement in New Hampshire?
When do the New Hampshire work rules start?
What is the income limit for New Hampshire Medicaid?
How do I apply for Granite Advantage Health Care Program — this is New Hampshire's name for ACA expansion Medicaid, covering adults 19 through 64?
How often do I have to renew New Hampshire Medicaid?
Guides for neighboring states
The rules change completely at the state line. If you moved recently, or you're helping family somewhere else, start with their state rather than this one.
If you remember 2019, when New Hampshire ran a Medicaid work requirement and roughly 17,000 Granite Advantage members were weeks from losing coverage before a federal court struck it down, the thing to understand is that this time is not that.
The 2019 rule was a waiver New Hampshire asked for and a court voided because the federal official who approved it had not considered the effect on coverage. The rule starting January 1, 2027 is in the Medicaid statute itself, Congress put it there, and New Hampshire has already written it into state law — there is no waiver for a court to vacate. The date that matters to you is not January 1 but your first redetermination in 2027, when the 80-hour requirement and six-month renewals both begin; anyone applying fresh has to show the month before, which for a January application means December 2026. New Hampshire will not take your word for any of it: state law requires documents rather than self-attestation, for exemptions as well as for hours. So make sure NH EASY at nheasy.nh.gov has your current address, phone and email and turn on text alerts, because all of this arrives by mail and you get 30 days from the date on the letter.
Updating your address takes two minutes and protects everything else. Do that first, then check the exemption list above.
Go to NH EASY Gateway to Services →