Oklahoma Policy Institute urges safeguards to protect SoonerCare coverage as state prepares for work requirements

During the Nov. 2 public hearing on proposed SoonerCare (Medicaid) work requirements, the Oklahoma Policy Institute urged the Oklahoma Health Care Authority (OHCA) to prioritize protecting eligible Oklahomans from unnecessary coverage losses as the state prepares to implement new federal requirements.

Under the federal changes, certain adults enrolled in SoonerCare will be required to demonstrate that they meet work or other qualifying activity requirements to maintain their health coverage. While these requirements are federally mandated, Oklahoma has opportunities to reduce administrative barriers that could cause eligible individuals to lose coverage.

"Experience in other states has shown that Medicaid work requirements can create significant administrative barriers, putting eligible individuals at risk of losing coverage simply because they struggle to navigate reporting requirements," said OK Policy's Kati Malicoate during the public hearing. "With nearly 250,000 Oklahomans enrolled through Medicaid expansion, the state must take every available step to prevent unnecessary coverage losses."

OK Policy called on OHCA to maximize automatic eligibility verification using existing state data, establish clear and accessible exemption processes, and provide meaningful outreach and assistance to affected members. We also urged OHCA to publicly report coverage losses, procedural terminations, and exemption determinations to help policymakers identify implementation challenges.

"Meeting federal deadlines is only one part of successful implementation," Malicoate said. "The true measure of success will be whether Oklahoma can meet these requirements without creating unnecessary barriers to health care for the people who depend on it.

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OK Policy's public testimony regarding SoonerCare (Medicaid) work requirements, Nov. 2, 2026

Good afternoon. My name is Kati Malicoate, and I'm speaking on behalf of the Oklahoma Policy Institute, a nonpartisan organization dedicated to advancing equitable and fiscally responsible policies that improve the lives of Oklahomans.

We appreciate the opportunity to comment on the proposed rules for SoonerCare work requirements. While these requirements are federally mandated, Oklahoma has a responsibility to implement them in ways that minimize unnecessary coverage losses and protect access to health care.

Experience in other states has shown that work requirements can create significant administrative barriers, putting eligible individuals at risk of losing coverage simply because they struggle to navigate reporting requirements. With nearly 250,000 Oklahomans enrolled through Medicaid expansion, the state must take every available step to prevent unnecessary coverage losses.

We urge the Oklahoma Health Care Authority to prioritize three things.

First, maximize automatic verification. While we appreciate that OHCA has already identified this as a priority, it is critical that all administrative system changes are in place before work requirements take effect. Doing so will help minimize unnecessary paperwork and prevent eligible Oklahomans from experiencing avoidable disruptions in coverage.

Second, make exemptions accessible. Individuals with disabilities, chronic health conditions, caregiving responsibilities, and other qualifying circumstances must have clear, straightforward ways to establish their exemptions without burdensome documentation requirements.

Third, prioritize meaningful outreach and transparency. Notices should be easy to understand, available through multiple communication channels, and accompanied by accessible assistance. OHCA should also publicly report coverage losses, procedural terminations, and exemption determinations so policymakers can identify and address implementation problems.

We recognize the challenges OHCA faces in implementing these federal requirements, but urge the agency to prioritize policies and systems that minimize administrative burdens and prevent eligible Oklahomans from losing coverage. Meeting federal deadlines is only one part of successful implementation. The true measure of success will be whether Oklahoma can meet these requirements without creating unnecessary barriers to health care for the people who depend on it.

Thank you for your time and consideration.