H.R.1 Overview: Work and Redetermination Requirements 

H.R.1, the federal 2025 budget reconciliation bill, implemented a comprehensive overhaul to financing, eligibility, and other aspects of the Medicaid program, among many other changes beyond Medicaid. While much has been written about the impact of the changes on the Medicaid program and coverage, this article offers key considerations for states as they navigate implementation of two provisions in particular – the Medicaid Community Engagement Requirements and the change to the Medicaid redetermination.

Considerations for States 

While these changes go into effect in 2027, most states began planning for and undertaking the significant work of implementation even before the law’s passage. As a result, key considerations and best practices are beginning to emerge. 

Communications 

Not surprisingly, most Medicaid members are unaware of the upcoming changes to their coverage, putting a huge responsibility on states and providers to outreach about the changes with not only information but also actionable guidance. One of the most pressing needs is to inform and educate patients if and how they will be impacted by the new community engagement requirements and redetermination cadence.  Providing clear communication that considers the literacy level and potential language barriers of the targeted population and that provides the details of the changes and instructions for submitting the correct paperwork is critical.   

Many states are also mindful of the opportunity to inform individuals not just of the community engagement requirements but also of the resources available to help them fulfill those requirements. That could include information about job programs in the state and community organizations that have volunteer opportunities. 

The mode of communication also matters. State Medicaid offices often communicate with patients via mail. However, many Medicaid enrollees are not receiving their mail for various reasons – including having moved or being housing insecure – so they often miss important deadlines and notices. In addition to leveraging new and duplicative methods for notices, Medicaid agencies will need to target their general outreach efforts to meet people where they are, such as health care providers, social media, grocery stores, community organizations and events, other social service agencies, large employers, and schools. 

Data Management 

In order to verify monthly activities for Medicaid members, State Medicaid agencies must update or build IT systems; such systems can also help to ease the workforce burden of the required more frequent redetermination. The unwinding process of the Medicaid continuous enrollment provision that occurred in 2023-2024 post-pandemic provides best practices that can help states as they consider IT and data needs for both of these processes. That experience demonstrated that streamlined renewal processes and automated renewals are critical to maintain enrollment for eligible populations. Some states have reported that sharing data between programs significantly improved the automation process and reduced the burden on staff who were already experiencing shortages and high turnover. 

States now must consider how they can streamline data sharing and integration across systems. For example, in order for providers to notify Medicaid patients of upcoming redetermination dates, that information must be in their registration systems or accessible from the state Medicaid agency. This example illustrates the broader administrative and technological adaptations that multiple organizations may need to undertake to comply with the new requirements. 

States also need to determine how to leverage Health Information Exchange systems to support determinations of exemptions from community engagement requirements based on medical frailty. Similarly, states adopting the short-term hardship exemptions must consider how to leverage data from other agencies to determine which counties have unemployment rates that will enable them to seek a hardship waiver. 

Enhanced Staffing Needs 

The accelerated timeline for implementing H.R. 1 changes creates significant administrative challenges for states. Meeting new federal requirements will require investments in technology, system upgrades, testing, public communications, and workforce expansion and training. However, many states are already experiencing staffing shortages and capacity constraints, limiting their ability to manage the substantial administrative burden these changes impose. As noted above, states are thinking about how they can leverage technology to automate systems, leverage existing information and systems, and enhance efficiency. They also are following best practices from Exchanges and Navigators on how to reach hard-to-reach populations with limited capacity, such as leveraging community partners. States are developing sharable documents and toolkits to make it as easy as possible for those partners to help and share consistent information to enhance the echo chamber.