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Wisconsin's work rules reach further than people expect
BadgerCare Plus is run by Wisconsin Department of Health Services (DHS), Division of Medicaid Services. Programs are administered under the ForwardHealth brand, and applications are handled by county and tribal income maintenance agencies. Wisconsin never adopted Medicaid expansion — and the new federal work requirement still applies to some people here, because it reaches certain waiver coverage too.
Not expanding Medicaid did not put Wisconsin outside the new rules
Yes. The federal work requirement in Section 71119 does reach Wisconsin's childless-adult waiver population, and Wisconsin DHS is implementing it. This is settled, not speculative.
Section 71119 defines an 'applicable individual' in two parts, not one. The first part is the ACA state-plan expansion group at 42 U.S.C. § 1396a(a)(10)(A)(i)(VIII). The second part, at new § 1902(xx)(9)(A)(i)(II), covers a person who 'is otherwise eligible to enroll (or is enrolled) under a waiver of such plan that provides coverage that is equivalent to minimum essential coverage' and who is 19 to 64, not pregnant, not on Medicare Part A or Part B, and not otherwise eligible under the state plan. Wisconsin's childless adults are enrolled under a Section 1115 waiver that provides full Standard Plan benefits, so they fall squarely inside that second part.
It is easy to read the provision as applying only to the statutory expansion group and conclude that an 1115 state is outside it. That reading is wrong. CMS addressed it directly: 'Regardless of whether a State covers the adult group under the State plan, a person could still be an applicable individual if that person is otherwise eligible for or enrolled in Medicaid under certain section 1115 demonstrations.'
Section 1902(xx)(10) provides that, notwithstanding Section 1115(a), these requirements may not be waived. Wisconsin cannot ask CMS for an exemption.
Who this actually reaches in Wisconsin
BadgerCare Plus members aged 19 through 64 with no dependent child under 19 living with them at least 40% of the time. DHS puts the number at about 200,000 people. People in other Medicaid programs — SSI Medicaid, Family Care, IRIS, Katie Beckett — are not affected.
80 hours in a single qualifying month of work, volunteering, a work program, an education program, or any combination. Being enrolled in school at least half time counts. Earning at least $580 in a month counts — that is 80 hours at the federal minimum wage. Unpaid work such as an internship counts, and so does work paid in goods or services rather than money.
Wisconsin is not moving to monthly reporting. DHS checks compliance only at application and at renewal.
Who it does not reach. If one of these describes you, the requirement is not yours to worry about:
When it starts for you
The number being quoted. DHS estimates about 63,000 members are at immediate risk — roughly a third of the affected group. Secretary Johnson defined that number precisely on July 30, 2026: these are members for whom the state has no work-history information on file. It is a gap in the state's records, not a count of people who are not working, and not a prediction of how many will lose coverage.
DHS has confirmed it will take the more generous options available: compliance in any one month out of twelve rather than every month, and self-attestation of medical frailty during the first year while the department gathers supporting documentation. Where it can, DHS plans to use existing medical records and diagnosis codes to identify exempt members automatically rather than asking them for paperwork.
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.
You do not have to prove anything if any of these fit you
The state is supposed to apply these automatically from records it already holds. Records are imperfect. If one of these describes you and you are still asked to report hours, say so and ask them to check rather than assuming the notice is right.
There is no exemption for homelessness. Congress did not include one and states are not allowed to add exemptions beyond the federal list. DHS has said it is working with local organizations to help unsheltered people document an activity or another exemption.
Wisconsin has no Medicaid coverage gap. It is the only state that declined the ACA expansion and still leaves nobody stranded between the two systems without an enrollment condition attached.
In most states that refused the ACA expansion, an adult with no children and no disability cannot get Medicaid at any income, and cannot get marketplace help either, because the tax credits only start at the poverty line. That trap is the coverage gap. Wisconsin does not have it. BadgerCare Plus covers adults up to 100% of the poverty level, and the marketplace tax credits pick up at 100%. The two coverage systems meet, so there is no income where you fall between them.
Wisconsin built its adult coverage before the ACA existed, through a Section 1115 waiver rather than through the ACA expansion, and kept it. When the ACA arrived, the state lowered the BadgerCare ceiling from 200% to 100% of the poverty level and dropped the enrollment cap, so everyone below the poverty line could enroll and everyone above it could buy subsidized marketplace coverage. Because the ceiling is 100% and not 138%, Wisconsin is still a non-expansion state in federal terms and still gets the ordinary federal match instead of the ACA's 90% rate — it pays for the coverage itself rather than leaving a hole.
What that leaves. No gap does not mean no problem. Wisconsin's adult ceiling is 100% of poverty, not 138%, so an adult earning between those levels is sent to the marketplace rather than to Medicaid, and since the enhanced premium tax credits expired at the end of 2025 that coverage costs considerably more than it did. Commenters on the 2022 waiver extension raised exactly this point.
KFF, 'How Many Uninsured Are in the Coverage Gap...', July 27, 2026: 'Although Georgia and Wisconsin have not adopted the Medicaid expansion, both states have expanded coverage to adults with income up to 100% FPL through an 1115 waiver, and therefore, a coverage gap does not exist in either state.'; KFF Medicaid state fact sheet, Wisconsin, May 2025: 'Adults in coverage gap: 0'; KFF State Health Facts, coverage gap indicator, June 2026: Wisconsin reported as NA, with the footnote 'Wisconsin covers adults up to 100% FPL in Medicaid under a waiver but did not adopt the ACA expansion.'
What you can earn and still qualify
Monthly household income before tax. These are the state's own published figures, which is what its caseworkers apply. If you are near a line, apply anyway — some income does not count, and only the agency can run the calculation for your household.
Source: BadgerCare Plus income limits and thresholds, effective February 1, 2026 through January 31, 2027, published at dhs.wisconsin.gov/badgercareplus/fpl.htm (page last revised July 10, 2026) and in DMS Operations Memo 26-02, January 30, 2026.
What else changes that day
P.L. 119-21 §71112, amending 42 U.S.C. §1396a(a)(34).
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 keep proof of whatever you do that counts, and check the exemption list.
Deaf, hard of hearing or speech-impaired: 711.
ACCESS, the application site, has a full Spanish version, and Spanish-language forms and notices are standard. Hmong is Wisconsin's third major language for health program materials — DHS published its BadgerCare waiver hearing materials in English, Spanish and Hmong. Beyond those three, interpretation is free in any language: ask for an interpreter when you call Member Services at 800-362-3002 or contact your county or tribal agency, and you will not be asked to bring your own. If you need a letter in a different format or a different language, say so and DHS will arrange it. For sign language interpreters and other accommodations, the DHS civil rights coordinator is at 844-201-6870.
“Our records do not show” is not the same as “you did not”
The state checks against employment and benefit databases that are often incomplete or out of date. A notice saying it cannot see your hours is a gap in its records, which you can close.
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.
Questions people ask about this
Wisconsin didn't expand Medicaid. Do the new work rules really apply here?
Who exactly does the work requirement affect in Wisconsin?
How many hours, and what counts?
Who is exempt in Wisconsin?
What should I do before January?
How do I apply for BadgerCare Plus?
How do I renew Wisconsin 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.
Wisconsin is the unusual non-expansion state: adults with no children at home can get BadgerCare Plus at or below $1,330 a month for one person, so if you have been told your state leaves you out, check again.
What changes next year is paperwork, not eligibility. From January 1, 2027 new applicants must show 80 hours of work, school or volunteering in the month before they apply, and current members will be asked at their renewal starting in March 2027. The state has no work history on file for about 63,000 people, so make sure your address and phone number are current in ACCESS and start keeping pay stubs, school records or volunteer logs now.
Updating your contact details takes two minutes and protects everything else. Do that first, then check whether an exemption fits you.
Go to ACCESS Wisconsin →