H.R. 1, now referred to as the Working Families Tax Cuts legislation (WFTCL), requires states to redetermine Medicaid eligibility more frequently for most of the Medicaid expansion population and individuals receiving coverage through a waiver of the plan. Beginning with renewals scheduled on or after January 1, 2027, states must redetermine that such individuals are eligible for Medicaid at least every six months. Federal law previously required such redeterminations to be conducted once per year.
On March 6, 2026, the Centers for Medicare & Medicaid Services (CMS) released guidance to assist states in transitioning from the current annual redetermination cadence to the new six-month cadence. Specifically, the guidance provides states with two options for transitioning already-enrolled beneficiaries to a six-month renewal cycle if their annual renewals are scheduled to occur in 2027:
- (1) States can shorten the prior eligibility period for affected beneficiaries to be as close to six months as possible by moving up their 2027 renewal date. States may not shorten a beneficiary’s prior eligibility period to be less than six months or schedule a new renewal date that is before January 1, 2027.
- (2) States can opt to leave already scheduled 2027 renewal dates in effect. If an affected beneficiary is found to be Medicaid eligible at that time, then they will be Medicaid eligible for a period of six months starting from their 2027 redetermination date.
Moreover, impacted states must submit a State Plan Amendment (SPA) attesting that they will conduct the statutorily required eligibility redeterminations every six months.
If you have any questions about how this guidance and the provisions of the WFTCL may impact you, please reach out to any Eyman Partners attorney to discuss.