Tracking Federal Guidance on H.R.1
NACHC developed the below tracker outlining federal guidance from the Department of Health & Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) on Medicaid/CHIP changes specific to H.R.1 that impact CHCs. This page will continue to be updated as new federal guidance is released.
(Last updated April 2026)
- Interim Final Rule: Medicaid Program; Community Engagement Requirement for Certain Individuals (Released 6/3/2026)
Summary: This interim final rule outlines the expectations for states that are required to implement community engagement as a condition of Medicaid eligibility by January 1, 2027. This IFC specifies the requirements of the types of qualifying activities, the criteria to meet an exception or exclusion from the requirement and the verification and outreach to impacted individuals.
- Guidance on Medicaid and CHIP Funding for Certain Noncitizens (State Medicaid Director Letter) (Released 4/8/2026)
Summary: By October 1, 2026, states will have to limit their federal Medicaid and CHIP funding for certain non-citizens.
- Explaining New Eligibility Redetermination Requirements (State Medicaid Director Letter) (Released 3/6/2026)
Summary: States must reassess eligibility every 6 months for most adults covered under Medicaid expansion beginning January 1, 2027. The guidance outlines which populations are exempted and operational steps states must take—including maintaining existing renewal procedures, updating eligibility systems, and submitting state plan amendments to comply with the new rule.
- Medicaid Work Requirements (CMCS Informational Bulletin) (Released 12/8/2025)
Summary: Provides an overview of the “community engagement” (work, education, volunteerism requirement) provision under H.R.1, requiring certain Medicaid expansion adults to demonstrate activities like work, education, or community service as a condition of eligibility. A timeline for outreach and compliance pathways before terminating coverage is also shared. Additional CMS guidance and rulemaking will follow.