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HR1 -Changes Coming to NYS Medicaid under the "One Big Beautiful Bill" Law - CMS Issues Work Requirement Regulations June 1, 2026
1 Jun, 2026
The Budget Reconciliation law known as HR1 enacted the One Big Beautiful Bill Act, signed into law July 4, 2025. The law imposes massive cuts in Medicaid, Medicare, SNAP, and immigrant eligibilty for these and other public programs. The strategically delayed implementation of many of the worst cuts until after the mid-term elections that will be held in November 2026. But some changes are happening sooner. This article provides links to some of the many explanations of the law and its impact by national organizations, and gathers information about implementation in NYS.
IN THIS ARTICLE
June 1, 2026 - CMS Issues Work Requirement "Interim Final Rule" for States. See here - including info on webinars on the new regulations and the July 31, 2026 deadline to submit comments to CMS about the Interim Final Rule.
May 2026 NYS Budget Enacted without PROTECTing Health Care for 480,000 New Yorkers who are Losing Essential Plan July 1, 2026!
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Click here for info about saving health coverage for 480,000 New Yorkers who are losing coverage under the Essential Plan - and how to contact your elected officials to take action in the State budget!
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Please click here to view the sign-on letter, led by NYS Legislature Health Committee Chairs, Senator Rivera and Assemblywoman Paulin, that was submitted to Governor Hochul.urging her to provide coverage in the budget for those losing Essential Plan coverage.
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For more info click here
Impact of HR 1 in New York State
June 1st - CMS Issued a Proposed Regulation on the Work Requirements that will Take Effect January 1, 2027. See more here.
July 1, 2026 - 12-Month Continuous Eligibility Ends for Adults on MAGI Medicaid
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Adults with Medicaid coverage will no longer receive 12 months of continuous coverage. Please note:
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Newly Medicaid eligible adults (above age 19) will no longer have continuous coverage language included in their eligibility determination notice details. New language was introduced into NY State of Health screens and notices sent in May 2026. A screenshot of this language is below.
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Existing Medicaid consumers reporting changes that make them ineligible for Medicaid will result in the consumer’s current coverage ending and their new eligibility for a different program, if applicable, taking effect according to regular enrollment timeframes.
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This policy does not apply to consumers who are pregnant or in their postpartum period. These consumers will remain eligible for Medicaid with continuous through the end of their 12-month postpartum period.
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NY State of Health will revert to 12 months of continuous eligibility for children from birth through age six. Language was included in the enacted fiscal year 2027 budget to repeal Continuous Eligibility for children under age six.
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If a child currently enrolled in Medicaid or subsidized CHPlus is no longer eligible for their respective program but was previously given continuous eligibility through the end of the month of their sixth birthday, NY State of Health redetermined their eligibility beginning in May 2026. If NY State of Health was unable to administratively renew the child, a manual renewal notice was sent with a completion due date of June 15, 2026.
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If the renewal is completed and the child is no longer eligible for any program, coverage will be terminated effective June 30, 2026.
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If the child was enrolled in Medicaid and is re-determined eligible for CHPlus, they may also be auto-enrolled in a CHPlus plan if the plan participates in Medicaid Managed Care and CHPlus in the child’s service area. If overlap does not exist, a new plan must be selected. Please review the account carefully and help the family to take action if needed.
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If the manual renewal is not completed, the child will be terminated from their current Medicaid or CHPlus coverage effective June 30, 2026.
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If a child is currently enrolled in Medicaid or subsidized CHPlus and they are in their 12-month continuous eligibility period, they will remain enrolled and be pulled into their regularly scheduled annual renewal.
- The federal government reimburses NYS for about 50% of the cost of Medicaid services for citizens and certain legal immigrants. The definition of who is a "legal immigrant" for piurposes of qualifying for federal reimbursement for Medicaid costs will be retricted on Oct. 1. 2026. After that date, the only immigrants whose Medicaid qualifies for federal reimbursement are:
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people with Lawful Permanent Residence status (Green Card holders) for more than five years;
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Cuban and Haitian entrants; and
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people from the Compacts of Free Association States (citizens of Micronesia, Palau, and the Marshall Islands).
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Many lawful immigrants who previously qualified for federally funded Medicaid will no longer qualify for FEDERAL Medicaid but they should still qualify for STATE-funded Medicaid. This is thanks to a NYS Court of Appeals decision Aliessa v. Novello, 730 N.Y.S.2d 1 (2001). Aliessa held that the NYS Constitution provision requiring care for the needy required coverage of Medicaid for legal immigrants, including those permanently residing under color of law (PRUCOL). See this article about PRUCOL eligibility New York State Medicaid should still cover lawful immigrants who, until Oct. 1, 2026 have been covered by Federal Medicaid including:
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Refugees and Asylees
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Victims of domestic violence (Violence against Women's Act) and trafficking
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People with Temporary Protected Status (TPS)
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other legal statuses listed in this Public Benefits Chart as eligible for Federal Medicaid (updated May 2026). This chart does NOT reflect the changes coming on Oct. 1, 2026. (Chart by NY Immigration Coalition, Empire Justice Center & Legal Aid Society).
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See CSS recommendations for how NYS can cover many of the immigrants who no longer qualify for the Essential Plan coverage - and whose income is too high for Medicaid. Unfortunately the NYS Budget passed in April 2026 without enacting any protections for those losing Essential Plan coverage.
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CMS Informational Bulletin, DHS Terminations of Parole Programs for Cubans, Haitians, Nicaraguans, and Venezuelans: Implications for Medicaid and CHIP Eligibility and Verification Process, issued July 14, 2026 instructing States to redetermine eligibity for recipients whose legal status under Temporary Protected Status or other parole status ends.
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NYS Dept. of Health Webpage announcing work requirements - with information about WHO must comply, WHAT activities comply, and more.
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June 1, 2026 - CMS issued Interim Final Regulations on Work Requirements.
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The National Health Law Program hosted a 3-part webinar series on Medicaid work requirements, where experts will break down the rule's key provisions, implications, and potential impact on Medicaid enrollees and state programs. The webinar series equips advocates with practical strategies, clear guidance, and actionable steps for engaging with their states on implementation. Watch the recordings )Posted on their Medicaid Defense webpage
- The new requirements do NOT apply to these "mandatory excluded categories"
- people who have or are entitled to enroll in Medicare,
- People age 65 and older and those who are age 18 or under,
- Was in a prison within the 3 months before the current month, or
- "Specified excluded individuals" These include:
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Former foster care children (only under age 26)
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American Indian or eligible for Indian Health Services – permanent exclusion
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Veteran with total 100% disability rating – may be permanent or temporary disability, but temporary disability must be reverified every 12 months (6 months at state option). Permanent is not reverified. Will be connected to VA data hub (when???)
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In compliance with TANF requirements OR live In a household that receives SNAP and is not exempt from SNAP work requirement (but do not have to be complying with SNAP work requirement), Verification from govt. agency.
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Pregnant or entitled to postpartum services (12 months in NYS and 47 other states) (state must use info reported on app, renewal, may use other data)
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Participating in drug addiction or alcoholic treatment program - States may establish minimum time commitments for participation, consistent with appropriate clinical guideline
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Parent or legal guardian or caregiver of dependent child under 14 or a disabled individual – (using ADA definition of “disabled” at 28 C.F.R. § 35.108). Family caregiver does not necessarily have to be living with or related to the child or disabled indivdual.
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Medically frail or special medical need -- before the issuance of the Interim Final Rule (IFR) , states were told that being on Social Security Disability or that they could designate certain diagnoses as sufficient (ie cancer). But the IFR is much more stringent -- says that this criterion requires BOTH:
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Being in one of 5 categories -- including:
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is eligible for Social Security Disability
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has a Substance Abuse Disorder (but not exempt if 5+ years of stable recovery),
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has a disability that significantly impairs ≥1 activity of daily living (ADL)(note IADLs do NOT count),
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has a disabling mental disorder, OR
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jas a "Serious or complex medical condition." (States may designate non-exclusive diagnoses that qualify for this, but must still meet the 2nd prong below) AND
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AND the above condition must significantly impair their ability to comply with the work requirement .
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Most people who must comply with these new requirements have Medicaid administered on the NYSofHealth website, not with the local county Medicaid office or HRA. Some people who receive Cash Assistance and Medicaid administered by the local Medicaid office or HRA will have to comply - their Medicaid will be transferred to NYSofHealth in order to administer the work requirements there.
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Medicaid Matters NY Statement on the June 1st Interim Final Regulations
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ADVOCACY and MORE INFO on Work Requirements:
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Administration’s Last-Minute Restrictions Likely to Worsen Impact of Medicaid Work Requirement (Center on Budget & Policy Priorities)(June 3, 2026)
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New Medicaid Work Requirements Rule Threatens Access to Care for People with Chronic Conditions (Harvard Center on Health Law & Policy Innovation)(June 4, 2026)
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Medicaid Work Reporting Requirements: Implementation Update after CMS’ Interim Final Rule (Families USA June 2, 2026)
(chart comparing language in HR1 statute, previous CMS guidance, and the Interim Final Review section by section)
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Medicaid Work Requirements & Due Process Q&A Series — Notice (National Health Law Program)
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State Choices in Medical Frailty Work Requirement Exemption Can Keep Eligible People Covered (Center on Budget & Policy Priorities)(Feb/ 2026 - warning - some of these choices may be prohibited under the CMS IFR issued in June 2026)
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Implementing Medical Frailty Exemptions Under HR 1 Clinical Considerations From Medicaid Medical Directors (JAMA Health Forum, May 15, 2026)
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The Power of Transparency: How States Can Use Data Dashboards to Effectively Monitor H.R. 1 (Robert Wood Johnson - Princeton -State Health and Value Strategies (SHVS) (May 22, 2026) and more resources on HR 1 here)
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Mitigating the Harms of Medicaid Work Requirements for Older Adults: Tools for State Advocates (Justice in Aging - March 2026)
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Implementing Costly Medicaid Work Reporting Requirements: Who Will Foot the Bill? (Georgetown School of Public Policy)(Feb. 11, 2026)
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EXPLAINER in plain language by the Autistic Self-Advocacy Network (ASAN)(July 13, 2026)
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Insights Blog - Inside the Work Reporting Requirement Implementation Guidance: How CMS’s New Rule Decimates Health Care Access for Millions - Families USA (June 11, 2026)
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Medicare eligibility will be limited to immigrants who are Lawful Permanent Residents (green card), Cuban/Haitian immigrants and COFA migrants
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Formerly eligible immigrants will LOSE MEDICARE on Jan. 1, 2027, including
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People granted Temporary Protected Status
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Refugees and people granted asylum
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People granted withholding of removal
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Trafficking and domestic violence survivors
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Persons granted humanitarian parole.
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These immigrants will lose their Medicare Part D drug coverage along with Medicare Parts A and B.
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Those who are poor enough for Medicaid can be covered by state-funded Medicaid. Those whose income or assets are above the Medicaid level will be uninsured.
See Justice in Aging brief and Justice in Aging - Immigrants and Medicare
Check back on this webpage for more information.
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