The “One Big Beautiful Bill (OBBB)” ushered in sweeping reforms that will upend how states provide an array of social services. Chief among these are changes to the Medicaid program that will directly impact how millions of patients access healthcare services. Below are recommendations for state policymakers, health center leaders, and advocates for implementing these new policies.
State implementation of Medicaid work requirements
The OBBB enacted new Medicaid work requirements that mandate able-bodied adults, age 19-64, without dependents, enrolled through the Medicaid expansion prove they are meeting the following:
- At least 80 hours per month of work, or a monthly income of equivalent to at least minimum wage for 80 hours;
- At least 80 hours per month of community service or a work program;
- Part-time enrollment in an educational program; or,
- At least 80 combined hours of qualifying activities.
While the new law exempts certain populations (e.g., parents, guardians, caretakers for a disabled individual, or family caregivers of a dependent child age 13 or younger; members of a tribe; pregnant or postpartum women; individuals who are medically frail), it is unclear how states will verify income, addresses, immigration status, and qualifying work requirement activities for those subject to this new policy. States must adopt the necessary procedures by December 31, 2026, which will require establishing new bureaucracies dedicated to evaluating and confirming each application (pending guidance from CMS via an interim final rule expected to be published by June 2026). Some estimates project the costs to administer Medicaid work requirement programs will range from millions to hundreds of millions of dollars per state.
To ensure patients are properly educated, states should partner with health centers to maintain coverage for the individuals who must now complete the work requirement activities, or those who qualify for an exemption. According to HRSA, health centers employed 7,000 outreach and enrollment personnel (e.g., patient navigators, health educators, community health workers, eligibility assistance workers, etc.) in 2023. By leveraging their expertise, states can work to safeguard Medicaid for the patients who rely on the life-saving services – including for millions of CHC patients. NACHC urges states to partner directly with health centers and state Primary Care Associations, and adopt the following policies to minimize coverage losses for vulnerable patients:
- Invest in and train health centers to educate patients and providers about Medicaid work requirements, and the resources available for individuals subject to this new policy. Investing in and training health center outreach and enrollment staff will build on their expertise and leverage the partnerships they already have with patients across the nation. Health centers across the country were heavily involved with Medicaid redeterminations, and established outstation locations to assist individuals (re)enroll in Medicaid. This expertise will be invaluable as states establish new eligibility and enrollment protocols.
- Facilitate partnerships between health centers and local and state-based job training and educational programs. Health centers staff work diligently to assist patients in enrolling for SNAP, WIC, and other vital benefits for which they qualify. Assisting health centers partner with employers, job training programs, and educational programs, will ensure they are equipped to connect patients with resources to fulfill these new requirements.
- Permit patients to volunteer at health centers to fulfill the qualifying activities requirement of the new Medicaid work requirement. Health centers serve as key anchor institutions in their community, providing key services and programs that promote nutrition, safety, and community engagement. By permitting health centers to serve as a volunteer site, states can maximize a health center’s impact and position them as leaders in helping patients meet the Medicaid work requirements.
Shifting costs of administering Medicaid and other programs to states
The OBBB sought to increase states’ responsibility in financing and administering programs like Medicaid, the Affordable Care Act insurance marketplaces, SNAP, and more. Amidst challenging budget deficits, several states have defunded state-funded coverage programs for immigrant patients, and one state has opted to defund a federal Medicaid waiver program that authorized services that addressed the nonclinical health needs of patients.
As states grapple with significant projected increases in costs for these programs, health centers and Primary Care Associations must advocate for their state to preserve funding for health center services and resist pressure to reduce reimbursement rates. The federal statute governing health center services and reimbursement remain unchanged; however, states have exercised considerable discretion in interpreting how these services are defined and how health centers are reimbursed. Recently, some health centers have received landmark budget appropriations from their state. These investments must be preserved and increased if states are to weather the disruptions to coverage and care for patients and providers directly impacted by OBBB. Moreover, in recent years, states have made significant investments to expand continuous eligibility for children and young adults in Medicaid and CHIP, additional SUD services, and increases in maternal and child health providers, such as doulas. Reducing these services would have a disproportionately negative impact on health centers and their patients. Given the expected increases in uncompensated care costs from the projected losses in coverage, any reduction in funding and/or services would be devastating to health centers. To protect against these impacts, NACHC urges states to strengthen partnerships with health centers via the following:
- Increase state appropriations to fund health center services and providers: Health centers serve as the backbone to the nation’s healthcare safety net. Increasing their funding would bolster their role as critical care providers and ensure their services are available to patients navigating the turbulent changes in the healthcare system. Moreover, it would allow them to recruit, train, and retain the health workforce they need to administer care to patients in need.
- Establish a minimum primary care state spending threshold: Dedicating annual appropriations to fund primary care across all states will ensure health centers and other primary care providers remain supported amidst mass disruptions to the nation’s healthcare system and economy. At a time when the nation projects massive churn in healthcare enrollment and amidst continued disease outbreaks, it is vital states reinforce their commitment to healthcare especially for vulnerable populations.
- Partner with health centers to fulfill the purpose of programs like Medicaid, SNAP, and the ACA marketplaces. States must work closely with health centers to ensure these programs reach the populations they were intended to serve. Health centers provide critical eligibility assistance for health coverage and a wide array of social services. By leveraging and are secured for the people who rely on these programs.
Next steps for the health center movement
As the nation prepares to adopt these new policies, health centers will continue to strive to the provider, partner, and employer of choice for the communities they serve. NACHC urges health center leaders to partner with NACHC and their state PCA to strengthen our advocacy at the local state and federal level. Below are recommendations to help health centers be more effective advocates:
- Become an Advocacy Center of Excellence (ACE): ACEs actively partner with NACHC on federal policy issues, as well as their state PCA on key local-level policy issues impacting health centers and their patients to meaningfully engage elected officials at all levels of government.
- Participate in NACHC advocacy fly-ins and PCA state advocacy days: NACHC hosts regular “fly-ins” that allow health center leaders to directly advocate on behalf of their patients and staff for policy solutions that address the urgent challenges they face.
- Mobilize patients to advocate on behalf of health centers: By mobilizing their patients to participate in state and federal advocacy, health centers can champion their patients’ experiences to protect the funding and services that patients rely on.
- Foster partnerships with foundations, local government agencies, and other philanthropic entities to maintain funding for vital healthcare services: Health centers should work with their state PCA and NACHC to foster partnerships with private foundations, or local and state government agencies to secure the revenue needed to maintain the services they provide.
Over the next 15 months, states will play a central role in determining whether patients continue to have access to life-saving healthcare services, and health centers must champion their patients in that fight. NACHC is honored to be a part of this movement with the 1,500+ health centers across the nation and look forward to continuing our work to serve as the provider, partner, and employer of choice for every community in the country.



