Oct 17, 2026
FQHCs need technology and investment to help patients complete the work to preserve coverage.
By Nima Roohi Sefidmazgi Ph.D., CEO and Co-Founder, Blooming Health; and Andy Mendenhall M.D., President and CEO, Central City Concern
In Oregon, the next major Medicaid implementation challenge is at our doorstep.
This September, Oregon began notifying people who may be subject to new federal Medicaid work and activity requirements. Beginning in 2027, many adults will need to demonstrate qualifying work, education, volunteering or another activity, or show that they qualify for an exemption. Later in 2027, many affected adults will also begin renewing their coverage every six months rather than on Oregon's previous every two-year schedule. Who is going to help people complete the work to preserve coverage for tens of millions of Americans?
That question should guide healthcare leaders preparing for Medicaid’s new eligibility requirements. A notice starts the process. Keeping an eligible person covered can require someone to explain it, identify an exemption, help gather documentation, resolve a barrier and follow up until the renewal is complete. The organizations best positioned to do that work are often the ones patients already trust: federally qualified health centers and community-based organizations.
But trust alone does not create capacity. Health plans, health systems and state agencies need to invest in these organizations and equip them with technology that extends their reach, removes routine administrative work and helps their teams stay with patients through resolution.
The Work Ahead is Bigger Than Outreach
In Oregon, the next major Medicaid implementation challenge is at our doorstep.
Under Public Law 119-21, the 2025 federal reconciliation law, affected adults will need to demonstrate 80 hours per month of qualifying activity, attend school at least half-time, meet an income threshold or establish an exemption. States will verify compliance at application and renewal.
The recent history of Medicaid shows why execution matters. When states restarted eligibility reviews after the pandemic in 2023, more than 25 million people were disenrolled. Sixty-nine percent of those disenrollments were procedural: coverage ended without an affirmative determination that the person was no longer eligible. Not everyone would ultimately have remained eligible, but the scale makes clear how strongly paperwork can determine access to care.
The Congressional Budget Office estimates that the law’s Medicaid provisions will increase the number of uninsured Americans by 7.5 million by 2034 relative to prior law. It separately estimated that community-engagement requirements account for 5.3 million additional uninsured people and six-month redeterminations for another 700,000.
Avoidable coverage loss will depend in part on how well the work gets done. The Urban Institute estimates that six-month redeterminations alone could reduce average Medicaid expansion enrollment in 2028 by about 3.1 million people under recent procedural disenrollment patterns, compared with about 2.0 million under stronger administrative performance. Its combined modeling of work requirements and more frequent redeterminations projects enrollment reductions ranging from 4.9 million to 10.1 million, depending in substantial part on implementation and efforts to mitigate avoidable losses.
Trusted Relationships are the Starting Point
Health plans and hospitals serve many of the people who will be affected by these policies.
Federally Qualified Health Centers (FQHCs) and CBO's know them differently. Health Centers are medical homes for millions of Americans, with relationships spanning primary care, behavioral health, dental care, substance-use treatment and support services. In 2025, HRSA-funded health centers cared for 32.7 million people through more than 144 million visits. Nearly half of their patients had Medicaid or CHIP, and about 90% of those with known incomes lived at or below 200% of the federal poverty level.
A 2026 U.S. study of clients receiving help from community health workers found high levels of trust and satisfaction, and greater frequency of interaction was associated with greater trust. The study was small and should not be treated as a national estimate, but it reinforces what many frontline organizations experience every day: relationships accumulate through repeated interaction.
That matters enormously when the question is not simply, “Did you receive a reminder?”
It is:
Do you understand the notice?
Does the requirement actually apply to you?
Are you already meeting it?
Are you exempt because of a medical condition, caregiving, pregnancy, disability or participation in substance-use treatment?
Where is your last pay stub?
Can your employer document your irregular work hours?
Can your volunteer program verify your participation?
Can you finish this treatment before coverage closes?
Those relationships matter when a patient needs help understanding whether a requirement applies, documenting irregular work hours or identifying an exemption related to a medical condition, caregiving, pregnancy, disability or substance-use treatment. CMS’s rules contain numerous exemptions and multiple ways to satisfy the requirement. For many beneficiaries, the work will involve identifying and documenting what is already true about their lives.
A trusted navigator can recognize why someone has stopped responding, explain a confusing notice and help the person take the next step. The challenge is making that support available to everyone who needs it, repeatedly, as renewal requirements become more frequent.
Technology Can Extend the Reach of Trusted Teams
The expected, and planned response is to give this work of documentation and data submission to community health workers, social workers, certified application counselors and benefits navigators.
The problem is that the existing workforce is already overloaded with tasks and demand. HRSA estimates that only about 2.6 million of the roughly 8.8 million health-center patients who could use enabling services are receiving them.
Asking the safety net to absorb millions of additional renewal conversations, document requests, exemption reviews and follow-ups without additional capacity will simply shift the administrative bottleneck from the state-level directly to service providers and the community.
Platforms like Blooming Health can help FQHCs amplify trusted relationships into consistent, scalable support. Automated, two-way outreach across voice, text and email can help teams reach patients in their preferred language, identify who needs assistance and maintain follow-up between staff conversations. The value comes from connecting each exchange to the next action: clarifying a notice, identifying missing information, surfacing a barrier or directing a complex need to a navigator.
Support can begin by voice or text after her shift. A technology-enabled workflow can help explain the next step, identify information that appears to be missing and continue the conversation when she is available again. It can organize what she shares and surface unresolved needs for a benefits counselor to review. If she cannot get a pay stub, does not understand an exemption or needs help accessing a service, the workflow can bring in a trained person with the context already gathered.
This changes how a team uses its time. Navigators can focus on patients who need judgment, advocacy or a trusted conversation, while the platform handles routine reminders, check-ins and follow-up. The relationship remains with the FQHC; technology gives the team a more persistent presence beyond office hours and across changing patient schedules.
The goal is to automate the administrative work around eligibility. States remain responsible for eligibility determinations, and trained professionals remain essential to interpreting complex situations and helping patients navigate them. Teams should be able to see who has responded, who is stalled, what barrier remains and whether the next step was completed. Sending a message is useful only if it moves the work forward.
Redetermination Support Must Connect Through Completion
Some patients will need more than documentation help. They may need employment support, a qualifying service opportunity, transportation or treatment before they can complete the process. FQHCs and community organizations can connect coverage support to those needs.
Central City Concern (CCC) is a community-based organization in Portland, Oregon. CCC combines an FQHC with housing, recovery and supportive employment infrastructure. In 2025, its Employment Access Center served more than 1,700 people and helped 570 secure employment. Its Community Volunteer Corps engaged 384 participants in more than 16,000 hours of service for nonprofit partners.
Oregon’s Medicaid guidance says organized volunteer service through a public agency or nonprofit can count toward the activity requirement when the organization tracks participation hours, subject to state verification rules. A trusted organization can help someone understand the requirement, assess whether an exemption may apply, connect them with appropriate support and help them return the necessary evidence.
CCC’s integrated model shows why those connections matter. In 2025, it maintained 2,433 affordable-housing units, delivered healthcare to nearly 12,000 people and served more than 7,000 through substance-use-disorder programs. Patients’ coverage, housing, recovery and employment needs often overlap. That creates an opportunity to connect systems that are usually separate.
A trusted community organization can help someone understand the requirement, determine whether an exemption applies, connect someone who wants work with employment support, connect someone who needs qualifying service with an appropriate local opportunity, document participation, and then help that person return the evidence required for coverage.
Technology can support follow-up across that process: whether a patient connected with an employment program, obtained documentation or still needs help. Platforms like Blooming Health can also help teams connect renewal support with appointment scheduling and social care referrals, so a coverage conversation becomes an opportunity to address the barriers keeping someone from care.
Technology can make that network searchable and executable at scale, while the relationship stays local.
Invest in Your Teams to Close the Care Loop
Technology cannot compensate for community services that do not exist or teams that lack the resources to help. Research from CMS’s Accountable Health Communities initiative found that even organized navigation encountered insufficient community resources. Screening and referral must be supported by investment in community capacity.
There is evidence that this investment can support better care. CMS’s final evaluation of the Accountable Health Communities Model reported more than $200 million in net savings after screening more than 1.1 million Medicare and Medicaid beneficiaries and navigating higher-risk people toward community resources, with savings driven primarily by reduced hospital utilization. A community-health-worker intervention at Kaiser Permanente Northwest also found fewer hospital days at six months and greater primary-care engagement. Not every outcome improved, and those findings do not establish that every intervention pays for itself. They do reinforce the community workforce’s role in continuity of care.
Health plans, health systems and state agencies should fund that workforce alongside the technology and coordination needed to complete renewal support. Shared workflows need clear responsibilities for outreach, escalation, documentation and follow-up. Success should be measured through completed renewals, confirmed coverage, resolved barriers and staff capacity gained.
We come to this issue from different vantage points: one of us leads an organization that has spent decades connecting healthcare, housing, recovery and employment; the other works with healthcare and community organizations to use technology to complete the repetitive work that limits their reach. We arrive at the same conclusion. We arrive at the same conclusion. The Last Mile is Where Policy Becomes Reality
The next phase of Medicaid implementation cannot be solved by human effort to navigate eligibility systems, alone.
States need accurate systems and good data. Health plans need outreach strategies. Health systems need to understand which patients are at risk. But ultimately, many of the most difficult navigation will be resolved through a conversation with someone the person trusts—supported by technology capable of doing the administrative work before and after that conversation.
That should lead to a simple policy and investment principle:
Fund the last mile. Equip it. Connect it. Do not bury it in more administrative work.
If health plans, health systems and state agencies invest in FQHCs and community organizations as genuine partners—and give their frontline teams scaled technology access that removes routine work rather than creates it—we have a chance to make the coming transition more accurate, more efficient and more equitable.
And that infrastructure will still be valuable long after the next Medicaid renewal is complete.
Because Medicaid redetermination is only one version of the same problem.
The real challenge is connecting people to what they need—and staying with them until the work is done.
Sources
[1] Leadership and Governance - Central City Concern
https://centralcityconcern.org/impact/leadership-and-governance/?utm_source=chatgpt.com
[2] [6] [25] Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule with Comment Period (CMS-2454-IFC) | CMS
[3] An Examination of Medicaid Renewal Outcomes and Enrollment Changes at the End of the Unwinding | KFF
[4] OBBBA's Six‑Month Redetermination Could Reduce Medicaid Expansion Enrollment by 2.0 to 3.1 Million in 2028 | Urban Institute
[5] Health Provisions in the 2025 Federal Budget Reconciliation Law | KFF
[7] [20] [23] [28] Our Impact - Central City Concern
https://centralcityconcern.org/impact/?utm_source=chatgpt.com
[8] [24] Oregon Health Authority : OHP Work or Activity Rules and Federal Changes to Oregon Health Plan : Oregon Health Plan : State of Oregon
https://www.oregon.gov/oha/hsd/ohp/pages/federal-changes.aspx?utm_source=chatgpt.com
[9] Oregon Health Authority : OHP Work or Activity Rules and Federal Changes to Oregon Health Plan : Oregon Health Plan : State of Oregon
https://www.oregon.gov/oha/hsd/ohp/pages/federal-changes.aspx
[10] Community Volunteer Corps - Employment Center - Central City Concern
https://centralcityconcern.org/jobs-location/community-volunteer-corps/?utm_source=chatgpt.com
[11] Impact of the Health Center Program | Bureau of Primary Health Care
[12] Measuring Clients’ Satisfaction and Trust in Community Health Workers: Results From a Cross-Sectional Survey - PMC
https://pmc.ncbi.nlm.nih.gov/articles/PMC13121484/?utm_source=chatgpt.com
[13] Eligibility Assistance Increases Insurance Enrollment Within Community Health Centers But Not At The State Level | Health Affairs
https://www.healthaffairs.org/doi/10.1377/hlthaff.2024.01311
[14] Up to 2.3 Million Young Adults Ages 19 to 24 Could Lose Medicaid Under OBBBA’s Work Requirements and More-Frequent Redeterminations | Urban Institute
