Timing of State Implementation of H.R. 1’s Medicaid Policies, Including Those Taking Coverage Away for Not Meeting Work Requirements
The 2025 Republican megabill (H.R. 1) will take Medicaid coverage away from millions of people for not meeting rigid work requirements. Many will actually be Medicaid-eligible — because they either worked the required hours or were exempt (such as caregivers or people with serious medical conditions) — but will lose coverage due to reporting burdens or red tape. Exacerbating this problem is a rushed rollout, lack of federal guidance, and limited state capacities to handle such a massive change.
This resource outlines key dates as states implement eligibility changes mandated by H.R. 1, including the Medicaid work requirement, immigration-related restrictions to federal Medicaid funding, limitations on retroactive coverage, and the transition to six-month renewals for certain populations. Specific to the work requirement, this timeline shows key dates, including when people will begin losing coverage, depending on a state’s implementation date and renewal timeframes. Note that these scenarios highlight the first and last cohorts of enrollees that will be subject to the work requirements for the first time, but the changes are permanent for all subsequent cohorts under current law.
Scenarios 1-2: The first two scenarios cover Nebraska and Montana, states that are implementing the Medicaid work requirement early. Nebraska went live on May 1, and Montana’s implementation date was July 1 (though it plans to implement a “hold harmless” provision that will delay coverage loss for current enrollees until January 1, 2027).
Scenarios 3-5: These scenarios cover states implementing the Medicaid work requirement on January 1, 2027, the deadline set in H.R. 1. States will apply the work requirement to renewals “initiated” this month, meaning when the state begins the renewal process by attempting an ex parte renewal. (Ex parte renewal attempts are automatic and based on information available to the agency from the case file or data sources.) States typically initiate the renewal process in either the second, third, or fourth month before the eligibility period ends, and this impacts when coverage losses will take effect. Take, for example, a state that initiates the renewal in the third month before the end of the eligibility period. It will first apply work requirements to the March 2027 renewal cohort — enrollees whose eligibility ends on March 31, 2027 — in January 2027. The first coverage loss for the state’s enrollees due to the work requirement will be April 1, 2027.
Variations in state application and renewal process actions also exist depending on state decisions around applicable lookback periods (the period of time that applicants or enrollees have to verify they are compliant with or exempt from the work requirement prior to the month of application or renewal). And, outreach notice deadlines vary depending on whether a state elects a one-, two-, or three-month application lookback period.
These scenarios all assume that states are implementing the new requirements for six-month renewals for Medicaid expansion enrollees at individuals’ next regularly scheduled renewal, beginning with renewals initiated in January 2027. (The Centers for Medicare & Medicaid Services, or CMS, gave states another option to implement the new requirement, which would involve rescheduling 2027 renewals to shorten eligibility periods to closer to six months, as long as the individual will have had six months of eligibility by the time their next renewal is completed.)
The timeline also includes key eligibility and enrollment deadlines and policy change effective dates that apply to all states and scenarios (denoted in green).