Keeping Your Members Enrolled in 2027: A Guide for Food is Medicine Providers

On January 1, 2027, Medicaid work requirements go live in every state that expanded Medicaid, which is most of them. Two quieter changes from the same law arrive the same day: eligibility renewals every six months instead of every twelve, and a shorter window for retroactive coverage. Together these changes mostly impact those who qualify for Medicaid on income alone, which is a large share of the people in Food is Medicine programs.

If you run one of those programs, here is what it will look like in practice. More of your members are going to move on and off coverage next year, and most of them will not have stopped qualifying. They will have missed a form, a deadline, or a letter sent to an old address. Every time that happens, a person who needs food loses access to it, and a program that delivered food to that member before seeing the lapse in coverage loses the payment for it.

The good news is that this is one of the few parts of the 2027 landscape that a food program can actually do something about. You are in touch with your members more often than their health plan is. You can check their coverage before each delivery instead of finding out after submitting claims. You can see a renewal coming and remind someone before the deadline, not after. You can build a pause into your program operations so that a short lapse does not become a lost member. None of that requires new funding. It requires treating eligibility verification as part of the delivery, not a box checked at enrollment.

This guide walks through what exactly is changing, what the early data says about who falls off and why, and a monthly routine for keeping the people who qualify enrolled and fed.

What a Lapse Looks like in Practice

Recently, I spoke with a program leader who had a member lose Medicaid coverage on the last day of the month. Their team did what the rules require: they disenrolled the member and closed their grocery benefit card. Days later, coverage came back. Nothing about the member had changed. Paperwork had been sitting on a desk somewhere, and when it got processed, the member was eligible again, retroactively, as if the gap had never happened.

Except it had happened. The card was closed, and closed cards do not reopen. The member had to be re-enrolled, issued a new card, and told that the one in their wallet would not work at the store. The program ate the administrative cost and the member experience was confusing. And the only thing anyone did wrong was follow the process.

Before Provision, I saw a lot of versions of that story for the community providers I supported. As work requirements go live, we are going to see more coverage lapses like this. If you plan ahead for this, there are a few things you can do to help prevent (where possible) and manage these lapses.

What Changes on January 1 and Where it Comes From

All three changes come from the same place: the One Big Beautiful Bill Act, the federal budget law signed on July 4, 2025 (you will also see it written as OBBBA or H.R. 1). It is truly a big bill, and most of its Medicaid provisions are about reducing federal spending by changing who stays enrolled and how often that gets checked. The ones that matter for food programs start on January 1, 2027, though states can start earlier (and some already have).

The changes fall mostly onto one group: expansion adults. That is the term for adults ages 19 to 64 who qualify for Medicaid based on income alone, under the Medicaid expansion that the Affordable Care Act let states adopt in 2014. In the more than 40 states and D.C. that adopted this expansion, this is the group that includes a large share of working adults with diet-related conditions. Children, people over 65, people on disability, and pregnant women are mostly not affected by these three changes, though they are affected by other parts of the law.

Here are the three changes, with the names you will see for them.

1. Work requirements, formally called the “community engagement requirement.” Expansion adults will need to show 80 hours a month of work, school, job training, or community service, or income that shows it, or qualify for an exemption. Exemptions include parents and caregivers of young children, people who are medically frail, pregnant and postpartum women, people already meeting SNAP work rules, and a few other categories. But the person has to be identified as exempt, which is its own paperwork. States must have these requirements live by January 1, 2027, though a few states may get extensions under limited circumstances. (Implementation dates)

2. Renewals every six months, often called “redeterminations.” A renewal, or redetermination, is the state’s review of whether someone still qualifies for Medicaid. For expansion adults, it moves from once a year to every six months. Each one is a form, a deadline, and a chance for an eligible person to fall through.

3. Shorter retroactive coverage. Retroactive coverage is Medicaid paying for care someone received before they applied, or before they re-applied after a lapse. For expansion adults, it will reach back one month instead of three. (Other adults go to two months.) Under the old rules, if a member’s coverage came back after a lapse, it often reached far enough back to cover deliveries made during the gap. Under the new rules, a delivery made to a member whose coverage was restored two months later may never be paid for.

The work requirements will mean that some members lose eligibility. But perhaps the bigger change for Food is Medicine providers is that the requirements change how often eligibility has to be proven, how much paperwork stands between an eligible person and a covered food benefit, and how much it costs a program to get the timing wrong.

The Losses So Far are Paperwork, Not People

Nebraska started its work requirement early, so we have the first real implementation data that came in recently. At renewal, 7% of enrollees subject to the rule lost coverage, and 92% of them lost it for not responding to the verification request. Not for failing the test, but for not returning a form. Among new applicants, 14% were denied, 84% of them for non-response.

The people falling off are overwhelmingly people who still qualify. They moved, the letter went to an old address, they are working two jobs and missed the deadline, they did not understand what was being asked. Every one of those is a problem a food program, with regular member engagement, is well positioned to catch.

Why this is a Food Program’s Problem, Not Just the Plan’s

When a member loses coverage, three things happen at once. The member loses access to food they qualify for. The program loses the revenue for that member, and often has already delivered food it will not be paid for. And the plan loses a member it was paying to keep healthy, which is the opposite of what anyone wanted.

So the stakes of knowing who is covered on the day you deliver go up in January. For the member and for you. Here is the routine I would have running before then.

A Monthly Routine that Holds the Roster Together

Here is the routine I would put in place now, so it is running before January.

1. Check eligibility before every cycle, not once at enrollment. Check eligibility monthly, and check it again close to each date of service. For a meal program, the date of service is the delivery. For a grocery card program, it is the reload. In practice that means a batch check across the whole roster once a month, and a real-time check on each member before you deliver or reload. If you only check at enrollment, you will find out about a lapse when the claim is denied, which could be months later.

2. Treat renewal dates as reminders, not facts. Some plans return a renewal date on an eligibility check. Many do not. And sometimes they show a member as active after the date has passed. Use the date as a flag to recheck eligibility and to reach out, not as a guarantee.

3. Reach out before the renewal, not after the lapse. If you know a member’s renewal is coming, a text or a call two to three weeks ahead (“Your Medicaid renewal is due soon. If you have not gotten the form, we can help you find it.”) catches the non-response problem before it becomes a coverage loss. There is a second window worth knowing: under the federal rule, a member the state cannot verify gets a notice and 30 days to show they meet the requirement or qualify for an exemption before coverage ends. Ask members to tell you when they get a letter from Medicaid, and treat any such call as urgent.

4. Help members claim an exemption before they need one. Most Food is Medicine members have a diagnosed diet-related condition, and many are caregivers or on SNAP. Several of those are exemptions from the work requirement, but the member has to be identified as exempt, and that documentation is its own form. Ask at enrollment (“Do you have kids under 14 at home? Are you on SNAP? Has a doctor said you cannot work?”) and help the member get the exemption on file. For that person, the work requirement comes off the table entirely.

5. Make sure the state can reach the member. The single biggest cause of coverage losses in the last big round of Medicaid renewals was mail sent to old addresses. At enrollment and at every reload or delivery, confirm the address and phone number the state has on file, and help the member update it through the state portal or their plan. It takes two minutes and it is the cheapest thing on this list.

6. Do not treat “inactive” as “uninsured.” An inactive result can mean a processing delay, a transfer between plans, or a renewal in flight. Often it means the member moved to a different plan, so check for other coverage before assuming they have none. Before you disenroll, look for a second signal: a note on the referral, a call to the member, an eligibility recheck a few days later.

7. Design a pause, not a close. When you do identify a lapse, see if your program can suspend a member’s benefit for a short window and reinstate it without re-enrollment. You avoid the cost and the confusion of starting over when coverage comes back in a week. If your card or delivery platform only has “active” and “closed,” ask your vendor for a third state. Keep the member’s record open until the last claim is paid; disenrolling someone from the benefit and closing their record are different actions. And when coverage does come back, recheck and rebill promptly. With the shorter retroactive window, you cannot assume the gap will be covered.

One more thing that is not an eligibility step but belongs here. Programs end. Authorizations expire. A member who has had a grocery card for six months and loses it with no warning is worse off than one who was told three weeks ahead and connected to a food pantry, SNAP enrollment help, or a care manager. Build the discharge conversation into the program, not just the enrollment one.

A Word About the People this is For

It is easy to write about eligibility as a billing problem. It is also a dignity problem. The member in that story did everything right, and the system still said, for a few days, that they did not qualify for food they had been counting on. Many people who will lose coverage next year will be in that position: eligible for the benefit, but losing access because of a missed or incorrect form.

The programs that keep their members supported through 2027 will be the ones that treat an eligibility check as the first step of a delivery and a renewal date as a reason to call. That is work a food program can do better than almost anyone else in the system, because you already have the relationship. And if you are designing a program now, this is the part to build first.

Provision runs the healthcare back office for food organizations, including eligibility checks before every delivery and the notices that go with them. If you want to compare notes on what you are seeing with your members, schedule a call