NHeLP has launched a new weekly Timely Tips to Safeguard Medicaid series to help advocates navigate Medicaid work requirements and other implementation issues stemming from the One Big Beautiful Bill Act (OBBBA). As federal and state agencies move quickly to implement sweeping policy changes, advocates need timely, practical information to understand what is happening on the ground and how to respond.
This ongoing blog will be updated weekly with each new tip, which are designed to provide a quick snapshot of emerging issues, explain what they mean for Medicaid eligibility and enrollment, and highlight where implementation may put coverage and access to health care at risk.
January 29, 2026: Reviewing accuracy from electronic data sources on work requirement compliance
By Shandra Hartly
In line with existing ex parte requirements for Medicaid eligibility determinations, OBBBA requires states to verify compliance with (or exemption from) work requirements using already available “reliable information,” without requesting information from applicants and enrollees. States have Medicaid Eligibility Verification Plans, which describe the electronic data sources in use for ex parte eligibility determinations. Once work requirements take effect in January 2027, advocates should monitor verification activities for adherence to ex parte requirements and for potential accuracy issues with these or any new data sources.
Read more about common electronic data sources here.
January 22, 2026: State coverage for lawfully present children and pregnant people
By Katy DeBriere and Sarah Grusin
OBBBA changes a lot about immigrant eligibility for Medicaid, but what it does not change is a state’s option to cover lawfully residing children and pregnant people. The term “lawfully residing” is broad and encompasses immigrants who will otherwise become ineligible for Medicaid in October 2026, including asylees, refugees, parolees, survivors of trafficking, and others. Importantly, lawfully residing pregnant people are entitled to 12 months of postpartum coverage if their state has elected that option. Furthermore, all children eligible for Medicaid are entitled to one year of coverage regardless of a change in circumstance.
Read more about upcoming changes to immigrant eligibility under Medicaid and what state advocates can do now to respond here.
January 15, 2026: Increased barriers to care for lawfully present immigrants
By Alicia Emanuel
Effective January 1, 2026, OBBBA eliminates premium tax credits (PTCs) for lawfully present immigrants with incomes below 100% FPL who are ineligible for Medicaid due to immigration status. Although these individuals can still enroll in Marketplace coverage, the lack of financial assistance will likely make coverage prohibitively expensive. Advocates should help connect affected individuals to any available state and local health programs, and work with their Marketplace to monitor implementation of this provision. Read more about OBBBA’s immigration changes here.
