Maryland’s health department projects that about 152,000 Medicaid expansion adults could lose coverage once federal work rules begin on January 1, 2027. The estimate comes from a September 9 department presentation and applies to a group of more than 320,000 adults, so close to half could be affected. The figure has moved up since the spring.
From 115,000 to 152,000 in four months
A May 18 presentation to the Maryland Health Benefit Exchange board put the number at about 115,000. The September deck carries a footnote saying the projection changed from the initial 115,000 because of H.R. 1 requirement changes. The department did not list which changes moved it.
Both estimates start from the same pool: ACA expansion adults ages 19 to 64, counted at more than 320,000 in November 2025 data. The September figure puts roughly 47% of them at risk of losing coverage.
The projection is not a count of people who will fail the rule. The department itself words the loss as something that “could” happen. Federal guidance from CMS was still pending when the May deck was presented.
Maryland Medicaid covers more than 1.5 million people, according to a joint state health and human services one-pager. Against that base, 152,000 is about one in ten of all Medicaid participants. The same one-pager lists up to about $2.7 billion a year in federal funding at risk.
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Where the affected adults live
The department’s public dashboard maps expansion adults as a share of each county’s adult population, using March 2026 data. Baltimore City tops the list at 17.4%, followed by Dorchester County at 15.7%, Allegany at 12.7%, and Caroline and Wicomico at 12.1% each.
The lowest shares are in Carroll County at 5.4%, Howard at 5.6%, Frederick at 5.7% and Queen Anne’s at 5.9%. A Baltimore City resident is about three times as likely as a Carroll County resident to be in the group. Which county a reader lives in changes how many neighbors face the same notices.
The deck also notes that many members do not know whether they count as ACA adults. A resident on Medicaid who is 19 to 64, not on Medicare and not caring for a young child may be in the group without realizing it.
The $580 test and who is exempt
Members must meet one of several monthly tests: income of at least $580, 80 hours of work, 80 hours in a SNAP work program, 80 hours of community service, at least half-time school or vocational training, or a combination totaling 80 hours. The $580 figure is the $7.25 federal minimum wage times 80 hours.
The department points out that a worker paid the state minimum wage could work fewer than 40 hours a month and still qualify. That makes the income route much easier than 80 hours for anyone with a paid job. Hours are the harder route for people looking for work or caring for a relative.
Exemptions include parents or caretakers of children or disabled people, medically frail people, pregnant or postpartum women, people in substance use treatment and people recently incarcerated. People entitled to Medicare Part A or enrolled in Part B, former foster youth under 26, American Indians and Alaska Natives and disabled veterans are also exempt. Short-term hardship exemptions cover recent acute care, travel for complex medical care, county disasters and high county unemployment.
What Maryland is telling members to do
The deck says focus groups found that many members fear Medicaid is being eliminated entirely, and the state wants its messages to say “some” and “may” rather than alarm anyone. The department is building a self-screener, dashboard alerts for ACA adults and chatbot updates on Maryland Health Connection. Its final slide asks partners to tell members to log in, try the screener and update contact information.
Two other changes land the same day. Expansion adults move to six-month renewals instead of annual ones, and retroactive coverage for them shrinks from three months to one. The deck’s timeline shows full six-month cycles combined with monthly work checks by July 2027.
The May presentation says Medicaid programs had to send work requirement notices to all ACA adults by September 2026. It gives an example: a member due to renew in February 2027 would get two mandatory notices before being disenrolled. Anyone who has not seen a letter by now has reason to check the account.
Costs follow later. The one-pager says expansion adults will face new cost-sharing starting October 1, 2028, capped at 5% of annual income. That is a separate change from the work rule, but it applies to the same group of adults.
For eligibility questions, the state’s one-pager lists Maryland Health Connection at 855-642-8572. The HealthChoice Helpline is 800-284-4510 for benefits and services. With notices going out, the question for a member is whether the account shows a current address.
Is a Maryland Medicaid account ready for January 1?
In a state where about 152,000 adults could lose coverage, many will lose it for missing steps rather than failing the rule. A member who has a paycheck but no record in the system, or whose notices go to an old address, is the person most exposed.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, along with a renewal and reporting calendar. Its Maryland state pack, one of 51, comes with a renewal document checklist for the paperwork a six-month cycle demands.
Plan Maryland’s six-month Medicaid renewals and work-hour records with the organizer kit →
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This article was produced with AI assistance and edited for accuracy against the sources linked above.
