H.R. 1, known as the One Big Beautiful Bill Act, will enact significant changes to Medicaid in January 2027, including work requirements for certain enrollees to maintain eligibility. It’s estimated that millions of people could lose coverage due to these work requirements.
But is it possible that there will be a slow implementation of these changes, in terms of removing people from coverage? One healthcare expert believes there may need to be.
“I really struggle to see the policy being launched in full form, in full effectiveness on January 1 in an enforceable way,” said Matt Salo, founder of Salo Health Strategies. “And I continue to believe that with all of the changes that need to happen from systems and government decisions and plan partnerships and member outreach and engagement and activation that we’re going to be seeing kind of like a soft opening of a restaurant on January 1.”
Salo made these comments during a Wednesday panel discussion at the AHIP Medicare, Medicaid, Duals & Commercial Markets Forum in Washington, D.C. He added that if there isn’t a slow rollout of the changes, it may look bad for the government. He said negative news stories are likely as coverage losses occur due to gaps in systems and insufficient member outreach.
“That is a very, very bad message,” Salo argued. “And I don’t think there’s a state in this country who wants to see that, and I don’t think the administration wants to see that either.”
Beyond the technical hurdles, Salo warned that reaching the right enrollees with the right information will be a challenge for states and health plans. He pointed to the unwinding of the Covid-19 public health emergency, when states ended continuous enrollment provisions that had allowed beneficiaries to remain covered during the pandemic without undergoing eligibility redeterminations. During this time, states just had to deliver one message to all enrollees: get redetermined in order to keep coverage.
But there isn’t a single message to deliver to all Medicaid recipients when it comes to H.R. 1 changes.
“It’s going to be a little bit different this time around, because we’re not going to be giving the same message to everybody in the Medicaid program,” Salo said. “There are some people we don’t want to communicate to necessarily — work requirements will not apply to them, and we don’t want to unnecessarily confuse them. … There will be different messages for the different populations that are impacted.” For example, work requirements generally don’t apply to pregnant individuals or people with disabilities.
The other panelists disagreed that there will be a slow implementation of H.R. 1 Medicaid changes. Kate McEvoy, executive director of the National Association of Medicaid Directors, noted that there is a “Herculean effort” going on between CMS and states around system functionality. For example, there has been a major focus on improving ex parte renewals, which verify Medicaid eligibility using existing data like income records without requiring paperwork from patients.
“I don’t subscribe to Matt’s version, where there’s going to be a soft rollout. We have no indication from the administration that that is going to be their approach,” McEvoy said.
Another panelist echoed McEvoy’s comments.
“I believe we will have made much more progress than I think we believe is possible in this period, [with] some of the new technology, some of the new outreach methods that I see,” said Darin Gordon, former director of TennCare, Tennessee’s Medicaid program. “I think we’re going to take another leap-forward moment here where we’re going to actually improve our overall eligibility process significantly, our member engagement significantly.”
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