Each September, National Recovery Month celebrates the strength of people in recovery and recognizes the treatment, services and community supports that make recovery possible. This year, that observance carries added urgency.
The One Big Beautiful Bill Act makes significant changes to Medicaid eligibility that could affect people seeking treatment for substance use disorders and co-occurring mental illness. Although the law includes protections for certain individuals, those protections will succeed only if patients understand them, providers can document them and state systems recognize them before healthcare coverage — and the treatment supporting recovery — is interrupted.
Beginning in 2027, many adults covered through Medicaid expansion will be required to demonstrate at least 80 hours per month of employment, community service, participation in a qualifying work program or a combination of approved activities. Half-time enrollment in an educational program may also satisfy the requirement. Applicants may have to demonstrate compliance before enrolling, while beneficiaries will be evaluated during eligibility renewals.
For someone living with a substance use disorder, however, the path to employment is rarely a straight line. Early recovery may involve frequent counseling, medication appointments, drug testing, peer support, court obligations and treatment for serious mental or physical conditions. Housing instability, transportation barriers and an inconsistent employment history can make both work and Medicaid reporting requirements difficult to manage.
The law recognizes some of these realities. People participating in certain drug or alcohol treatment and rehabilitation programs are excluded from the work requirement. Individuals who are medically frail or have special medical needs may also qualify for exclusion when their condition significantly impairs their ability to satisfy community engagement requirements.
But qualifying for an exclusion does not guarantee that the state will identify it automatically. Patients may still need to provide documentation, respond to notices or obtain clinical verification, all while managing the symptoms that support their need for an exclusion.
Federal and state policymakers must also establish clear guardrails around the federal definition of “stable recovery.” Under federal regulations, a person considered to be in recovery from a substance use disorder for five years or longer is no longer included in the substance use disorder category for purposes of the medical frailty exclusion.
Many people in sustained recovery can work and satisfy community engagement requirements. But the passage of five years alone does not establish that a substance use disorder, or a co-occurring mental or physical condition, no longer limits a person’s ability to do so. Recovery is individualized, and opioid use disorder is a chronic condition. A person may remain vulnerable to recurrence while also living with depression, anxiety, trauma, chronic pain or another disabling condition.
A current clinical diagnosis and the individual’s functional limitations should carry greater weight than an arbitrary timeline. Qualified providers should be permitted to attest when a patient’s substance use disorder and co-occurring conditions are sufficiently disabling to warrant exclusion from the requirements.
Continuity of care is essential to sustaining recovery and preventing recurrence, overdose, psychiatric crisis and hospitalization. Without appropriate safeguards, a procedural loss of Medicaid could interrupt medication, counseling, psychiatric treatment and trusted provider relationships that may have taken years to establish. Such an interruption could destabilize the very recovery that the five-year definition assumes is secure.
The risk is especially serious for people with co-occurring mental illness. Symptoms of depression, post-traumatic stress disorder, bipolar disorder, schizophrenia or severe anxiety may interfere with a person’s ability to maintain employment, open and understand notices, obtain documentation or complete a renewal form. The same symptoms that justify a medical-frailty determination may prevent the person from navigating the process required to receive that protection.
These changes will also affect treatment providers. Providers may face increased administrative burdens as they help patients document treatment participation, establish medical frailty and respond to eligibility notices. Coverage disruptions can interfere with care planning and leave providers responsible for the uncompensated care cost of medically necessary services delivered during eligibility gaps.
Every hour spent resolving an avoidable coverage problem is an hour that cannot be devoted to counseling, recovery support, care coordination or crisis prevention. When coverage is terminated for procedural reasons, providers face an unacceptable choice: interrupt care during a medically vulnerable period or continue treatment without assurance of reimbursement. Neither outcome advances recovery.
New Hampshire must implement these requirements with a clear commitment to continuity of care. The state should use reliable Medicaid claims and treatment information to identify exclusions automatically whenever possible. Patients should receive understandable notices, meaningful assistance and sufficient opportunity to provide documentation. Providers need clear standards, practical verification procedures and a direct process for resolving eligibility problems before coverage is terminated.
Medicaid is not merely a payment mechanism for people in recovery. It is often the foundation supporting medication, counseling, psychiatric care, crisis intervention and treatment for co-occurring conditions. These services help people stabilize, reconnect with their families and ultimately return to employment and community life.
Accountability and recovery do not have to be competing goals. But implementation must reflect a fundamental clinical reality: treatment is frequently what makes employment possible. Medicaid policy should protect that pathway — not interrupt it.
Bill Sutton serves as the general counsel for New Season Treatment Center which provides compassionate opioid addiction treatment throughout New Hampshire.