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Work requirementsNebraska pilot May 2026 · national start January 1, 2027
medfrail.com
How it worksFrailty scalePractice the callFor navigatorsHealth systems
OBBBA work requirements · Jan 1, 2027 · you may already qualify for an exemption

Most people who lost Medicaid under work requirements actually qualified.

In Arkansas's 2018 pilot — the only state to implement work requirements before courts struck them down — 95% of people who lost coverage were working, exempt, or both. They failed the paperwork, not the requirement.

What works today: a dated record of your condition that stays on your device, so you have something specific to show your state, and a practice run of the call to your Medicaid office. Physician review is planned and not open yet.

Dated record and call practice, on your device · physician review not open yet · nothing charged
The 100-person picture · Arkansas, 201895 of 100

Of every 100 people who lost coverage, 95 were working, exempt, or both.

medfrail in 15 seconds

Text version:
  1. Most who lost coverage qualified. Arkansas 2018: 95% were working, exempt, or both.
  2. Frailty is a measured state. A 1-to-9 clinical scale, not a feeling.
  3. A dated record, on your device. Nothing leaves it. Print it, keep it with your papers.
  4. Then check with your state. Each state decides whose documentation it accepts.
  5. medfrail. Keep your Medicaid. medfrail.com
the stakes

Up to 10.1 million people could lose Medicaid by 2028.

Many of them already meet the rule or qualify for an exemption. The trouble is proving it. In Arkansas's 2018 pilot, about 95% of people who lost coverage were working, exempt, or both: they failed the paperwork, not the requirement. The same paperwork gap is the risk at national scale.

Source: Urban Institute / Robert Wood Johnson Foundation · March 2026
Peer-reviewed · JAMA Health Forum · August 2026

You can work full-time and still fail this rule.

Researchers at Boston University and the University of South Carolina studied employment in all 40 Medicaid expansion states. Two-thirds of the people this rule targets are already in the labor force — and 85% of those average more than 35 hours a week, roughly double what the rule asks. One in five is still at risk. The rule does not measure whether you work. It measures whether your hours are legible to a state computer, every single month.

19.8%
at risk of noncompliance
Nearly one in five adults plausibly eligible for expansion Medicaid is unlikely to clear 80 hours in a given month — not because they don’t work, but because of how the hours land.
Read the study →
13.6%
working near the threshold
Sitting within five hours a week of the 20-hour line. A single slow shift, a flare-up, one week of reduced duty — and the month falls short.
Is a condition holding your hours down? →
7.6%
hours swing month to month
Retail, hospitality, food service, health care, agriculture. The schedule is set by someone else, and it changes. Compliance becomes a coin flip you have to win twelve times a year.
See which exemptions apply →
The sentence this whole site is built around

The study’s lead author names the gap precisely: the rule is hardest on people with less education, part-time or gig work, less control over their hours — “and those who have substantial health concerns that may not rise to the level of a documentable disability.”

That last group is the one medfrail exists for. You do not need to qualify for disability. The federal standard is narrower and more specific than that: a serious physical, mental, or behavioral health condition that significantly impairs your ability to comply. It is a functional test, not a diagnosis list — which means it has to be documented by someone qualified to assess function. That is what a physician attestation is.

See where you fall on the clinical frailty scale
Where we stop

Most of the 19.8% are not medically frail. They are people whose employer changed the schedule. We cannot write an attestation for that, and we will not try. A physician signs a statement about your health, or signs nothing — and an attestation that overreaches is worse than none, because it is the one a state will audit.

If your hours are unstable but your health is not the reason, the route that works is the other 80-hour path: school, job training, or structured volunteering through a nonprofit or public organization all count the same as paid work. Some health systems are now running volunteer programs specifically so their patients can meet the requirement. Ask yours. If a health condition is part of why the hours don’t add up, that is the case we take.

And if you are not sure yet: build your baseline record. It stays on your device, it is dated, and from January 2028 a dated trail is what the state will ask for.

How health systems are covering both routes
Source: Shafer PR et al., “Medicaid Work-Reporting Requirements Under HR 1 and Insufficient or Inconsistent Work Hours,” JAMA Health Forum 2026 · Boston University School of Public Health
Analysis of 2023–2025 federal survey data across 40 expansion states and DC. “At risk” = within ±5 hours of the 20-hour weekly threshold, or reporting hours that vary by more than ±5 from usual.
For navigators and caseworkers

One printed page for the client who says “my health is why I can’t work 80 hours.”

When to point a client to a dated record that stays on their own device, what it does and does not do, and why the state decides what it accepts.

Open the one-pager
For health systems and Medicaid plans

How many of your members are at risk of losing coverage on paperwork.

A model you can run in your browser, with its sources on the page. Physician review is planned, not open, and nothing is priced.

Run the estimate
the process

Three steps. Start with your record. Nothing is charged today.

When review opens, every attestation will be reviewed by a licensed physician and signed only if your record supports it. Today, build your record and practice the call.

Why a physician attestation works when the paperwork doesn’t.
Most people who lost Medicaid qualified — a self-reported form got lost or bounced. Documentation that is dated, specific and cites the federal criterion is easier for a caseworker to check than a bare form. Your state decides what it accepts, so ask it first.
The standard now has a name — and a clock.
Under CMS’s interim final rule (in effect since July 31, 2026), a diagnosis alone is not an exemption. It is a two-step test: a serious physical, mental, or behavioral condition — and your state determining that it “significantly impairs” your ability to meet the requirement. (That second step is CMS’s addition; 25 states plus DC, including Colorado, are challenging it in court.) Your state checks its own records first. Until January 1, 2028, states may accept your own attestation under penalty of perjury. From 2028, self-attestation counts only once per enrollment period — after that, the state must verify against reliable documentation, drawing on the prior twelve months of your medical record. The functional record you build now is the exemption you keep then — and for many conditions, the moment you most need the exemption is exactly when you are least able to assemble paperwork. Document while you can.
quick self-check

Tap every category that applies to you. See what may fit.

These are the categories this check screens. You only need one. This is not a medical or legal determination. It is an orientation, and your state decides.

This self-check is educational, not a legal or medical determination. One selected category is sufficient to start the attestation process. A licensed physician makes the final determination.

what "medical frailty" actually means

Frailty is not a feeling. It's a measured clinical state.

Clinicians describe frailty on a 1-to-9 scale — from very fit to terminally ill. Move through it below to see what each level means for daily life, and what it implies for care planning. This is the same vocabulary a physician uses when documenting frailty.

Tap a level · 1 = very fit  →  9 = terminally ill

Educational illustration of the Clinical Frailty Scale (Rockwood et al., Canadian Study of Health and Aging). Plain-language summary only — not a diagnosis. A frailty level is assigned by a clinician reviewing your full history.
When physician review opens, a licensed physician would make that assessment; today the level you pick is your own placement, kept on your device.

practice, on your device

Practice the caseworker call before you make it.

Four invented, scripted calls with a Medicaid office: say your situation, ask which form and what the deadline is, get a confirmation number in writing, ask how to appeal. A phrase-checker in your browser marks each answer. It is not an AI, and nothing is sent or recorded.

Start a practice call
Practice call 1 · invented caseworker
DanaMember services, this is Dana. How can I help you today?
An answer that meets the need“I have a health condition that keeps me from working most weeks. I’d like to ask for the exemption. Which form do I need, and what is the deadline?”
three paths in

Enrollees, health plans, and providers — same attestation engine.

for enrollees

I might lose my Medicaid.

You've heard about the new work requirements and you're worried. Start with the dated record on your own device, and practice the call to your Medicaid office. Physician review is planned and not open yet; nothing is charged, and a person writes to you when it opens.

Dated record · review not open yet
Start mine →
for medicaid mcos

My members are at risk.

Every enrollee who churns off costs you capitation revenue. medfrail.com is planning an exemption-documentation service for frail members. Nothing is open or built for plans yet.

Not priced yet
Plan partnership →
for fqhcs + hospitals

My patients need documentation.

Your safety-net patients maintain coverage and you maintain reimbursement. A planned attestation service for your frail panel. Nothing is open or priced yet, and EHR integration is not built.

Not priced yet
Provider partnership →
the architecture

Built for defensibility. Made to scale.

Public face
medfrail.com — consumer-facing intake; plan and provider contracts are handled directly (no contract portal yet)
this page
Platform
ClinicalSwipe — review marketplace · specialty routing · audit trail · attestation log
infrastructure
Clinical authority
altru.care — one licensed physician of record
supply
Reviewer network
Specialty panel — planned, not built — psychiatry, PMR, addiction medicine, primary care, cardiology. Today there is one physician of record.
planned
Build my dated record
We are not legal representatives. Today we provide only the on-device record and call practice; when physician review opens, a licensed physician will review and sign or decline. Final eligibility determinations are made by your state Medicaid agency.
the honest part

What our physician of record signs — and what they won't.

When review opens, a licensed physician of record will handle medfrail attestations. A physician drafts “if appropriate” — and that phrase is doing real work. Here is what it means.

they sign
  • ✓ Attestations the record supports (planned, not open yet). A licensed physician would review your file and — if appropriate — draft an attestation against the federal OBBBA medical frailty criteria. Your state decides whose documentation it accepts — check with your state first.
  • ✓ Any of the eight federal categories. Disability, serious or complex medical condition, substance use disorder, disabling mental disorder, caregiving role, pregnancy or postpartum, foster youth, veteran with total disability. You only need one.
  • ✓ Documents a caseworker can check (planned). When review opens: a physician-signed PDF citing the specific OBBBA criteria your record supports.
  • ✓ Only what a physician has reviewed. When review opens, every attestation will be reviewed and signed by a licensed physician — none will be issued without that signature.
they won't sign
  • ✗ Files with a documentation gap. A draft that doesn’t hold up goes back for clarification or additional records — not into the signature queue.
  • ✗ Frailty where there isn’t any. On the 1–9 clinical frailty scale above, levels 1–3 — very fit, fit, managing well — are unlikely to qualify.
  • ✗ Your state’s decision. Final eligibility determinations are made by your state Medicaid agency — an attestation is evidence, not a verdict.
  • ✗ Legal representation. We are not legal representatives. Today we provide only the on-device record and call practice; when physician review opens, a licensed physician will review and sign or decline.

Join the review list. Build your record now.

No price and no checkout. Leave your email and state and we write when physician review opens.

What review would include · not open yet
  • Planned: a physician-signed medical frailty attestation — a signed, dated PDF to bring to your state Medicaid agency, if your state accepts it.
  • Cited to the federal criteria your record supports — references the specific OBBBA medical-frailty categories (H.R.1, P.L. 119-21).
  • Planned: review by a licensed physician, not open yet. Your state is checked first. Nothing is charged today.
  • Records go to the physician, not to this website — after we confirm your intake, you send diagnoses, medications, and prior letters by the method the reviewing physician specifies.
  • No turnaround promised — review is not open yet, so there is no review window to quote.
Medicaid MCOs and providers: nothing is priced yet — see partnerships.
Physician review list · takes 30 seconds

Enter your email and state. Physician review is not open yet, so you join a list: we log your state and a person writes to you when review opens. Nothing is charged.

✓ Got it. You’re on the list. Physician review is not open yet; nothing is charged, and a person writes to you when it opens.
Have ready · you can add records later
Your diagnoses · medication list · any prior physician letters
Email + state only · nothing charged · we write when review opens

An attestation is medical evidence, not a verdict — final eligibility determinations are made by your state Medicaid agency. When review opens, a physician will decline any case the record doesn't support, and say why in writing. See what they sign — and what they won't.

after your attestation

You kept your coverage. Now keep your independence.

A medical frailty attestation documents your condition — it doesn't improve it. If daily activities are harder than they used to be, co-op.care is building neighborhood care co-ops: in-home support from caregivers who are paid fairly and accountable to you — not to a staffing agency. Paid care has not started yet.

See what co-op.care is building
What co-op.care is building
  • + In-home personal care and daily living support, once paid care begins
  • + Caregivers who will be W-2 co-owners, not gig workers
  • + Care that qualifies can be documented with a physician’s letter; your plan decides.
  • + The co-op will handle scheduling and paperwork, not your family
Build my recordPractice the call