Starting January 1, 2027, many Oklahoma adults enrolled in SoonerCare will be subject to new federal “community engagement” requirements. The changes were included in H.R. 1, Pub. L. 119-21, the federal legislation signed into law on July 4, 2025.

The Oklahoma Health Care Authority (OHCA), which administers Oklahoma’s Medicaid program, estimates that approximately 126,000 Oklahomans will be impacted. Last week, more than 250,000 SoonerCare members received a yellow letter from OHCA notifying them that they may be affected. Receiving a yellow letter does not necessarily mean that you will have to meet the requirements; OHCA will determine who is exempt and who needs to demonstrate compliance.

The goal right now is simply to understand the changes and know what steps to take.

Who will be affected?

The new requirements generally apply to SoonerCare expansion adults ages 19 through 64 who do not qualify for an exemption. It is important to note that OHCA determines exemption eligibility. .

Not everyone in this age group will be subject to the requirements. OHCA has identified a number of exemptions, including people who:

  • Are enrolled in or entitled to Medicare
  • Are age 18 or younger or age 65 or older
  • Are current or former foster youth age 25 or younger
  • Are pregnant or postpartum
  • Are a parent or caretaker of a child age 13 or younger
  • Are a parent or caretaker of an individual with a disability
  • Are American Indian or Alaska Native
  • Are a veteran with a total (100%) disability rating
  • Are blind or disabled
  • Have a health condition that makes it difficult to meet the requirements
  • Have a substance use disorder or disabling mental disorder
  • Have a serious or complex medical condition
  • Participate in a qualifying addiction or alcohol treatment program
  • Meet certain Temporary Assistance for Needy Families (TANF) work requirements
  • Receive SNAP and are subject to SNAP work requirements
  • Are currently incarcerated or were incarcerated within the previous three months

OHCA also lists several circumstances in which a person may be eligible for a short-term hardship exception, including certain inpatient or outpatient medical treatment, extended travel for necessary medical treatment and certain federally recognized emergencies or periods of high unemployment. Some of these exceptions require federal approval before they can be used.

What does someone have to do if the requirement applies to them?

If you are subject to the new requirements, you must demonstrate at least 80 hours per month of qualifying activity.

Those 80 hours can come from:

  • Employment
  • Community service (volunteering)
  • Qualifying work programs
  • Specific education
  • A combination of these activities

Impacted individuals can also meet the requirement by having at least $580 in monthly income. Seasonal workers may qualify based on an average monthly income of at least $580 over the previous six months.

OHCA has outlined what parameters must be met with each of these qualifying activities.

Education can count when a person is actively enrolled at least half-time in an eligible educational program. Qualifying programs include higher education, career and technical education, high school and high-school-equivalency programs.

Community service can count as well, but it must be performed through a structured program managed by a public or nonprofit organization. Folks who are participating in community service should retain documentation of volunteer hours in case OHCA needs proof later.

Hours cannot be carried over from one month to another. If 80 hours are required, all 80 hours must be completed within the same calendar month.

When will people have to report their hours?

OHCA says it will first check whether a person meets the requirement or qualifies for an exemption using information it already has.

After that, OHCA will check compliance every six months when a member renews SoonerCare.

For someone applying for SoonerCare or completing their first renewal in 2027, OHCA will look at the month immediately before the application or renewal.

For subsequent renewals, OHCA will look at whether the member met the requirement (or had an exemption) during one of the six months before the renewal date.

If OHCA cannot verify compliance or an exemption using information it already has, the member will receive a notice explaining what documentation is needed. The member will then have 30 days to provide the requested proof.

What should SoonerCare members do right now?

OHCA recommends taking these steps now:

1) Make sure your contact information is current.

Log into your MySoonerCare account and make sure your mailing address, phone number and email address are correct.

This is especially important because OHCA may send additional information or requests for documentation in the future.

2) Watch your mail and email.

If OHCA needs additional information from you, it will send a separate notice explaining what is needed and when it must be submitted.

Don’t ignore correspondence from OHCA or assume that a yellow letter is the final decision about your eligibility.

3) Learn whether an exemption may apply to you.

OHCA has created a Work Requirements Screener to help members get a better idea of whether the new rules may apply to them.

The screener is informational only. It is not an application or a final eligibility determination. OHCA makes the final decision about whether a person is subject to the requirements or qualifies for an exemption.

4) Keep records of qualifying activities.

If you work, volunteer, attend school or participate in a qualifying work program, keep records that document your participation and hours. This can make it easier to respond if OHCA later asks for verification.

What if someone cannot meet the requirements?

There are numerous exemptions built into the new rules, including exemptions related to disability, health conditions, caregiving responsibilities and other circumstances.

If you believe an exemption applies to you or someone in your household. OHCA will determine whether an exemption applies and will provide instructions if additional documentation is needed.

Where can I get help?

The Oklahoma Health Care Authority is the best source for questions about an individual’s SoonerCare eligibility, exemptions and documentation requirements.

SoonerCare Helpline:
1-800-987-7767
Monday–Friday, 8 a.m. to 5 p.m.

Members can also use their MySoonerCare account to update information and manage their case.

OHCA has also created a dedicated Work Requirements webpage with the current rules, exemption information, a screening tool and resources related to employment, education and qualifying activities. Because implementation details may continue to be updated, this page is a good place to check for the most current information.

For now, the most helpful steps are simple:

Keep your contact information up to date.
Read every notice from OHCA.
Confirm with OHCA whether an exemption applies to you.
Keep documentation of qualifying activities if the requirements apply to you.
And ask for help if you’re unsure.

There is still time to understand the changes and prepare. You do not have to figure it out alone. Autism Oklahoma is working behind the scenes to help the people we serve meet these requirements. Watch for details via our website, newsletter and social media.