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ABH's H.R. 1 Watch Center

Navigating H.R. 1 Together​

In July 2025, President Trump signed H.R.1, sometimes called “the One Big Beautiful Bill Act (OB3)” or the Working Families Tax Cut Act into law.  ABH and many advocacy groups refer to the law as H.R. 1.

 

This law includes major changes to Medicaid across the country. MassHealth, our state’s Medicaid program, must implement these changes.

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The changes are significant and the federal and state governments will need to publish guidance to implement these changes.  This page for Association for Behavioral Healthcare members brings together important state information and limited critical federal updates together in one place. 

In the coming year, Medicaid agencies across the country are preparing for mandatory changes to the Medicaid program.  ​

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MassHealth will be required:

  1. to check eligibility for some members every six months

  2. to require “community engagement,” which includes work, education, or volunteering, for some members.

  3. To limit retroactive coverage and eligibility for a limited group of non-citizens.

 

In addition, the law substantially limits MassHealth’s access to essential federal funds that have support community health centers, hospitals, nursing facilities, vaccine programs, and more. As a result, there likely will be significant funding reductions in health care and across the Massachusetts state budget.

UPDATES

CMS releases interim final rule

On June 1, the Centers for Medicare and Medicaid Services (CMS) released its interim final rule on implementing community engagement requirements (commonly referred to as “work requirements”) as provided under H.R.1. Additional information on the proposal can be found in the press release and fact sheet.

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The rule will be effective July 31, 2026, with an opportunity for public comment, due July 31, 2026.

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Who does this effect? H.R.1 requires expansion enrollees, non-pregnant adult Medicaid beneficiaries aged 19-64 who typically meet a higher income threshold than in traditional Medicaid and receive coverage in their state as a result of Medicaid expansion or waiver, complete at least 80 hours of work or qualifying activities per month. Other qualifying activities can include community service, work programs, educational programs, or a combination of these activities.

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Who is exempt?  Those who are “medically frail,” which includes individuals with a substance use disorder, disabling mental disorder, or those participating in a Drug Addiction or Alcoholic Treatment or Rehabilitation Program. The Interim Final Rule seeks to provide further implementation guidance on these exemptions.

 

Unless the Secretary grants an extension, states are required to implement work requirements by Jan. 1, 2027.

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Frequently Asked Questions

What is H.R. 1?

H.R. 1, sometimes known as the “One Big Beautiful Bill Act”, OB3, or “Working Families Tax Cuts Act” is a federal law that passed in 2025. It includes major changes to the Medicaid program that will take effect over several years. There are also major changes to SNAP and other federal programs that will not be featured on this page. 

What major healthcare-related changes does H.R. 1 require?

Major changes include:

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  • New community engagement (“work”) requirements for some adults

  • More frequent eligibility verification for some adults

  • Reductions in retroactive coverage periods

  • Substantial changes to Medicaid state financing arrangements

  • Significant changes to error rate penalties

  • Reduction or elimination of subsidies and/or eligibility for some Connector coverage

When will the H.R. 1 changes take effect?

  • Some of the Medicaid requirements have begun already.  More frequent redeterminations and work requirements begin in January 2027. 

  • MassHealth has a high-level implementation timeline graphic on its federal updates page. 

  • The National Council for Mental Wellbeing has developed a timeline called their H.R. 1 Implementation Journey Map.

How will MassHealth renewals change?

  • Beginning in January 2027, Massachusetts will be required to conduct eligibility reviews every six months for some adult members. Today, most of these members are reviewed annually.

  • ABH encourages member organizations to ensure their client/patient eligibility and enrollment verification processes are up to date and comply with MassHealth administrative and program regulations at 130 CMR 450.231(D) which require “verifying a member’s eligibility status on a daily basis…A provider’s failure to verify a member’s MassHealth status before providing services to the member may result in nonpayment of such services.”

What are Medicaid community engagement or work requirements?

Beginning in January 2027, certain adult MassHealth members (generally, those in the expansion population) must work, participate in a work program, perform community service, attend school half-time, or do a combination of these activities for a specified number of hours each month to maintain eligibility, unless they meet the requirements for exemption.

What challenges might MassHealth members encounter during implementation?

MassHealth members may experience:

  • Confusion about new requirements, exemptions and timelines.

  • Difficulty with application and renewal processes and related documentation. 

  • Additional documentation requests than in the past.

  • More limited retroactive eligibility.

 

Note: Connector enrollees may lose coverage if they are unable to make premium payments due to loss of subsidies. 

How might H.R. 1 implementation impact behavioral health providers?

 

  • Administrative burden will likely increase.

  • Reimbursement rates, structures, and/or services may change, depending on new requirements and the Commonwealth’s response to significant budget reductions.

  • Coverage, particularly for adults, may shift because of eligibility changes, which may lead to increases in uncompensated care.

How should behavioral health providers prepare for H.R.1 implementation?

 

  • Monitor federal and state guidance. ABH will continue to provide state updates.  The National Council for Mental Wellbeing will provide federal updates.

  • Develop internal policies and protocols in response to program requirement changes.

  • Educate affected individuals about new work requirements and eligibility redeterminations.

  • Update internal eligibility and enrollment verification systems and processes.  Where it makes sense, strengthen organizational supports for MassHealth members relating to applications and renewals.

  • Train staff on new policies and procedures.

  • Consider opportunities for funding diversification.

  • Establish systems to collect impact data.

  • Respond to Association for Behavioral Healthcare and National Council for Mental Wellbeing surveys about impact.

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