Work Rules, Frequent Checks and Fees Ahead Under New Law
Editor’s note: We gathered information for this article prior to September 4, 2025, when the Division of Developmental Disabilities (DDD) and the Arizona Health Care Cost Containment System (AHCCCS) announced changes to policies for Home and Community Based Services (HCBS). These changes affect assessments for and limits to habilitation and attendant care hours, mostly for children under age 18. Encircle Families will continue to share updates and information related to state and federal changes on our website (https://encirclefamilies.org) and social media channels.
Congress recently passed the One Big Beautiful Bill Act, signed into law by President Trump on July 4. The legislation makes sweeping changes to Medicaid, including what experts are calling the largest cuts in the program’s history. Understandably, many Arizona families are worried about how this national law might affect eligibility and healthcare services for their loved ones, including those with medical conditions, diagnoses and other needs.
For now, families should know that nothing changes immediately for those covered by AHCCCS. The first changes from the new law won’t be seen until late 2026. And even then, states could request extensions that could delay implementation even farther.
The new legislation primarily changes requirements for what’s called the “Medicaid expansion population.” This group includes low-income adults without dependent children and others earning up to 138 percent of the federal poverty level (about $21,600 for an individual in 2025). Many of this population became eligible through the Affordable Care Act’s Medicaid expansion.
“Aside from that information, we don’t have much guidance yet,” said Marcus Johnson, Deputy Director of Community Engagement and Regulatory Affairs for AHCCCS. “All states are waiting for federal direction.”
Here’s what we know so far about the changes and their timing.
WORK REQUIREMENTS
Starting December 31, 2026, “expansion” adults ages 19-64 will need to complete 80 hours per month of approved activities to stay covered. That could include working, going to school part-time, job training or volunteering.
Some groups won’t need to meet this rule, including pregnant or postpartum women, foster or former foster youth, Native Americans, parents of young children, veterans with disabilities, incarcerated individuals and some people with disabilities and their caregivers.
The exact language and specifications for exemptions should be confirmed when federal and state guidance is released. How some of these requirements will be verified, especially the volunteer option, is not yet clear, Johnson noted.
MORE FREQUENT ELIGIBILITY CHECK-INS
Currently, Medicaid members renew eligibility once a year. Beginning in late 2026, certain “expansion” individuals will need to do this every six months. Along with monitoring new work requirements and checking eligibility more often, states will also need to develop systems to verify addresses and identify deceased enrollees to prevent inaccurate coverage and payments.
COST-SHARING FEES
In October 2028, “expansion” members who are above 100 percent of the federal poverty level will start paying fees for certain kinds of care. Fees will be capped at $35 per service or item. Preventative and essential services, such as primary care, prenatal care, pediatric care, emergency care and rural health visits, will be exempt.
In 2025 the federal poverty level is $15,650 for one person, with about $5,500 added for each extra household member. We don’t yet know what those amounts will be for the year 2028. The Department of Health and Human Services updates these guidelines each year, typically in January.
HOSPITAL FUNDING
Changes in how hospitals are funded and reimbursed are scheduled to begin in 2028, phasing in each year until 2032. These changes have raised concerns about the law’s long-term effects on healthcare facilities, primarily rural hospitals. The full impact remains uncertain.
WHAT FAMILIES CAN DO NOW
While we still don’t know how everything will change, there are some actions that individuals can take now. These include creating or verifying their online AHCCCS accounts and subscribing to news and updates from reputable sources.
First, families can track and manage their Medicaid coverage online at HealtheArizonaPlus.gov. Although the process for twice yearly eligibility verification is not yet finalized, the portal is expected to play a central role in meeting these requirements.
Next, families can subscribe to and rely on credible information sources. Updates will continue to come from AHCCCS, community organizations and advocacy groups. You can subscribe to AHCCCS newsletters (https://www.azahcccs.gov/PlansProviders/AHCCCSlistserve.html) and see public notices (https://www.azahcccs.gov/AHCCCS/PublicNotices/).
Encircle Families also regularly shares updates and calls to action on social media and our website, and through our email newsletter Connecting Weekly. Visit Encircle Families (https://encirclefamilies.org) to subscribe.
Some lawmakers say the new law is meant to reduce waste while keeping Medicaid strong for the people who need it most and should have overall positive results. Advocates, however, are concerned about how these changes could affect access to care.
Johnson emphasized that for now, people should continue using their Medicaid benefits as usual. “There are no immediate changes to eligibility, services or rates,” he added. “Nobody wants to lose their benefits, and I believe our agency will do everything possible to help eligible people maintain coverage.”
