H.R. 1 enacted numerous changes to the Medicaid program, many of which require guidance from the Centers for Medicare & Medicaid Services (CMS) to facilitate implementation of and compliance with these changes. Eyman Partners is closely monitoring CMS guidance and rulemaking related to H.R. 1 and is analyzing these agency communications as they are published.
As of October 2025, the Office of Management and Budget (OMB) was reviewing a proposed regulation that would modify the requirements for state directed payments (SDPs). CMS’s most recent regulatory agenda also indicates the agency is preparing to send a proposed rule to OMB that will update regulations related to state enrollment processes, SDPs, other payment and access requirements, and budget neutrality requirements for section 1115 demonstrations. We expect that both planned rules are intended to implement provisions of H.R. 1, although, CMS has indicated that the first rule will also include changes to certain targeted Medicaid practitioner payments in the Medicaid fee-for-service program not addressed in H.R. 1. At this time, the exact language of the proposed regulations is not public, and it is uncertain when the rules will be proposed for public comment.