Under H.R. 1, Medicaid expansion adults move from annual to six-month eligibility renewals for renewals on or after December 31, 2026. Traditional Medicaid populations (children, pregnant women, elderly and disabled enrollees) remain on annual cycles. The provision cannot be waived under Section 1115.
For behavioral health providers and FQHCs, this doubles the number of times each year a patient can fall out of coverage because a form did not get returned. The population least equipped to manage recurring paperwork is the population you serve.
Implementation timing and state rules vary. Some states began early enforcement during 2026. Others delayed portions to January 2027. Several, including Indiana and West Virginia, have proposed applying six-month redeterminations beyond the federally required expansion group. We build against your state’s actual rules, not the federal floor.
Sources: H.R. 1 (Working Families Tax Cuts legislation) §71107; CMS State Medicaid Director letter SMD #26-001 (March 6, 2026).