Nebraska made history on May 1, 2026, becoming the first state in the country to enforce Medicaid work requirements under the federal One Big Beautiful Bill Act. If you are enrolled in or applying for Nebraska's Medicaid expansion program, known as Heritage Health Adult, the rules have changed. This guide explains exactly who must meet the new requirements, who is exempt, how to report your hours, and what happens if you do not comply.
What Are Nebraska's Medicaid Work Requirements?
Nebraska's work requirements apply to able-bodied adults aged 19 to 64 who receive Medicaid through the state's expansion program, Heritage Health Adult. Starting May 1, 2026, these individuals must complete at least 80 hours per month of qualifying activities to maintain coverage.
The 80-hour threshold can be met through any combination of:
- Paid employment (any job, full-time or part-time)
- Participation in a job training or apprenticeship program (at least half-time)
- Enrollment in an educational program (at least half-time)
- Volunteering at a qualified organization
- Participation in a state-approved work program
There is also an income-based shortcut. If you earn at least $580 in a calendar month, DHHS treats you as meeting the requirement automatically. At Nebraska's minimum wage, that works out to roughly 80 hours at the state minimum wage rate, so the income threshold and hour threshold are designed to align.
Who Is Exempt From Nebraska's Work Requirements?
A significant portion of Heritage Health Adult enrollees will qualify for an exemption. Nebraska DHHS estimates that roughly 60 to 72 percent of expansion members already meet requirements or qualify for an exemption without additional action.
You are exempt from the work requirements if you fall into any of the following categories:
Automatic exemptions:
- Pregnant or up to 12 months postpartum
- Under age 26 and aged out of foster care
- A parent or caretaker of a child age 13 or younger
- Caring for a person with a disability who lives in your home
- A veteran with a total disability rating
- A member of a federally recognized Native American tribe, or receiving services through the Indian Health Service
- Within 90 days of release from incarceration
Medical exemptions (medically frail):
- Diagnosed with a disabling mental health condition
- Blind or have a physical disability that limits daily activities
- Have a serious or complex medical condition
- Have a developmental or intellectual disability
- Enrolled in a substance use disorder (SUD) treatment program
Temporary hardship exemptions:
- Currently hospitalized
- Experiencing a medical emergency or required travel for medical care
- Living in a county or area with federally designated high unemployment
DHHS reviews your medical claims data approximately 90 days before your eligibility renewal date. If your claims data shows qualifying diagnoses or treatment codes, the state will flag you as exempt without requiring you to do anything. If your records do not capture your condition, you can submit a self-declaration. You do not need to provide medical records; self-attestation is accepted for most exemptions.
How Many Nebraskans Are Affected?
Approximately 112,600 Nebraskans are enrolled in the Heritage Health Adult expansion program. Of those, Nebraska Appleseed and other advocacy organizations estimate that between 28,000 and 41,000 could be at risk of losing coverage if they do not comply or successfully claim an exemption. DHHS disputes the higher end of that range, arguing that most members already satisfy the requirements through existing employment or will qualify for exemptions.
Implementation Timeline and Renewal Schedule
Nebraska did not apply the requirements all at once. The rollout follows a phased renewal schedule:
| Renewal Date | When Work Requirement Check Applies |
|---|
| May 2026 or June 2026 | Not checked until 2027 renewal |
| July 31, 2026 | First group required to demonstrate compliance |
| August through December 2026 | Phased in as renewal dates occur |
| January 2027 and beyond | Full implementation across all members |
If your Medicaid eligibility period ends in May or June 2026, you will not face a work requirement check at that renewal. Your first check will come at your next renewal in 2027. If your coverage period ends July 31, 2026 or later, you must be prepared to show compliance at that renewal.
How to Report Your Hours
DHHS uses existing data sources first. Before contacting you, the state checks your employment records, tax data, and Medicaid claims to see if you already meet the threshold. If the state cannot verify compliance automatically, you will receive a notice and have 30 days to respond.
You can report qualifying activities or document an exemption through the following channels:
- Online: iServe Nebraska portal at iServe.ne.gov
- Phone: (855) 632-7633
- Mail: Your local Nebraska DHHS office
- In person: Any Nebraska DHHS county office
When reporting, document your activities monthly even if you are not asked, because it is easier to provide existing records than to reconstruct them after a notice arrives.
What Happens If You Do Not Meet the Requirements?
If DHHS determines you have not met the 80-hour requirement and you do not qualify for an exemption, your Heritage Health Adult Medicaid coverage will be terminated. You will have 30 days from the date of notice to respond before a final decision is made.
If your coverage is terminated, you can reapply. However, you must be able to demonstrate compliance going forward. Re-enrollment is not automatic; you will need to actively apply and show you meet the work requirement or qualify for an exemption at the time of application.
How Nebraska Got Here: The Legal Path
Nebraska's work requirements stem from the One Big Beautiful Bill Act (H.R. 1), signed into federal law in July 2025. The law gives states the option to implement Medicaid work requirements before the national January 1, 2027 deadline using a state plan amendment rather than a Section 1115 waiver.
Nebraska was the first state to take that early path. Governor Jim Pillen and CMS Administrator Dr. Mehmet Oz jointly announced the plan in December 2025. Two other states are also moving ahead before the national deadline: Montana plans to begin July 1, 2026, and Iowa plans to begin December 1, 2026.
Using a state plan amendment rather than a waiver was significant because it bypassed the lengthier federal approval process and public comment period typically required for 1115 waivers. Critics raised concerns about the expedited process and the lack of new state staffing or funding to support the added administrative burden.
Income Limits for Heritage Health Adult (Medicaid Expansion) in 2026
Work requirements do not change who is financially eligible for Heritage Health Adult. Nebraska expanded Medicaid in 2020, and the income limit remains 138 percent of the Federal Poverty Level (FPL).
| Household Size | Annual Income Limit (138% FPL) | Monthly Income Limit |
|---|
| 1 | approximately $20,783 | approximately $1,732 |
| 2 | approximately $28,208 | approximately $2,351 |
| 3 | approximately $35,632 | approximately $2,969 |
| 4 | approximately $43,056 | approximately $3,588 |
These figures are approximate and based on 2026 federal poverty guidelines. The actual limits are adjusted annually. Use the free eligibility screener at benefitsusa.org/screener to check your current eligibility based on your household size and income.
What Advocates Are Saying
Legal Aid of Nebraska and Nebraska Appleseed have been vocal about implementation concerns. Their primary worries:
- Many eligible Nebraskans do not know about the requirements because outreach has been uneven in rural areas
- DHHS is not hiring additional staff to support the increased verification workload
- No new state funding was allocated, meaning the administrative burden falls on a system already under strain
- People with qualifying exemptions may lose coverage simply due to paperwork gaps rather than ineligibility
DHHS conducted a pre-launch outreach effort that included more than 75,000 mailed letters and 38,000 text messages. Whether that reaches the most vulnerable populations, including those without stable internet or phone access, remains a question advocates are watching closely.
What To Do Right Now If You Are On Heritage Health Adult
Follow these steps to protect your Medicaid coverage:
- Check your renewal date. Log in to iServe Nebraska or call (855) 632-7633 to find out when your eligibility period ends.
- Determine if you are exempt. Review the exemption list above. If you have a medical condition, care for a child under 14, or fall into another exempt category, start documenting it now.
- Start tracking your hours. If you work, volunteer, or attend school, keep a simple log. Employers can provide pay stubs and letters confirming hours.
- Watch your mail and iServe messages. DHHS will contact you before any termination decision. You have 30 days to respond to any notice.
- Respond to DHHS notices within 30 days. Missing the deadline can result in coverage loss even if you qualify.
- Get free legal help if needed. Legal Aid of Nebraska has published guidance on work requirements and can assist with appeals. Visit legalaidofnebraska.org.
Frequently Asked Questions
Does working less than 80 hours in one month automatically cancel my Medicaid?
Not necessarily. DHHS checks compliance at your renewal, not month to month. If you had one slow month but meet the requirement most months, you may still pass your renewal check. However, it is safest to aim for 80 hours every month or to document an exemption.
Do I have to work 80 hours at a single job, or can I combine activities?
You can combine any mix of qualifying activities. If you work 40 hours and volunteer 40 hours in a month, that counts as 80 hours.
I am in a substance use disorder treatment program. Do I have to comply?
No. Active participation in a drug or alcohol treatment program is an exempt category under the medically frail definition. You will need to document your enrollment in a treatment program, but self-attestation is accepted.
I take care of my elderly parent who has a disability. Am I exempt?
Yes. If you are the primary caregiver for a person with a disability who lives in your household, you qualify for an exemption.
What if I live in a rural area and cannot find work?
If your county has federally designated high unemployment, a temporary hardship exemption may apply. Contact DHHS to ask whether your county qualifies. The exemption is not automatic; you need to request it.
Can I lose coverage before my renewal date?
Not under the standard rollout. DHHS is checking compliance at renewal, not on a rolling monthly basis. Your risk point is at your eligibility renewal date.
Nebraska expanded Medicaid in 2020. Does expansion status still matter?
Yes. Work requirements only apply to the expansion population, meaning adults aged 19 to 64 who qualified under the 138 percent FPL expansion. Traditional Medicaid populations, including people who are elderly, disabled, pregnant, or children, are not subject to work requirements.
Where do I apply or check my status?
Go to iServe Nebraska at iServe.ne.gov or call the Nebraska DHHS Medicaid line at (855) 632-7633. You can also visit the Nebraska benefits overview page on this site for more details on programs available in the state.
How do I check if I qualify for Medicaid or other benefits?
Use the free Benefits Navigator screener at benefitsusa.org/screener. It checks eligibility for Medicaid, SNAP, CHIP, LIHEAP, and more based on your ZIP code, income, and household size.
