H.R.1, explained
H.R.1's Medicaid community engagement requirement, in plain language.
What states must do by January 1, 2027.
Updated June 2026
On June 3, 2026, CMS published the interim final rule implementing H.R.1's Medicaid community engagement requirement (CMS-2454-IFC). Beginning January 1, 2027, certain adults ages 19–64 must complete 80 hours per month of qualifying work, education, training, or volunteer activity to keep Medicaid coverage, unless they qualify for an exemption.
The requirement itself is one sentence. The work it creates for states is not. States must determine who is subject; verify compliance from available data before asking anyone for paperwork; identify exempt members, including people who are medically frail, pregnant or postpartum, caregiving, or already meeting SNAP or TANF requirements; run outreach and cure workflows for people at risk of losing coverage; and keep an auditable record of every determination. All of it on eligibility systems that were built for none of it.
Who is subject, and who is exempt?
The requirement applies to certain Medicaid adults ages 19–64, with statutory exemptions and deemed-compliance pathways. Identifying who falls where, from data, before notices go out, is most of the operational work.
| Group | Status | What it means |
|---|---|---|
| Adults ages 19–64 in the affected Medicaid population | Subject | Must complete at least 80 hours per month of qualifying work, education, training, or volunteer activity. That covers roughly 20 million adults, per CMS estimates. |
| People already meeting SNAP or TANF work requirements | Deemed compliant | Compliance with those programs' requirements counts; no separate showing needed. |
| Medically frail individuals | Exempt | The exemption that turns on functional-status evidence, not just diagnosis codes. |
| Pregnant and postpartum women | Exempt | Statutory exclusion. |
| Certain caregivers | Exempt | Caregiving status must be identified and documented. |
| Tribal members | Exempt | Statutory exclusion. |
| Veterans with a total disability rating | Exempt | Statutory exclusion. |
What does “verify from available data” require?
Ex parte verification means confirming a person's status from reliable data the state or plan already holds (payroll records, income data, prior determinations) before asking them to submit documents. The rule directs states to attempt it first, and the stakes of doing it well are large: for renewals alone, CMS expects 44% of applicable individuals, 8.8 million people, to have to provide information when ex parte verification falls short, creating an estimated 35.2 million hours and $454.8 million in annual member burden, with another 3.75 million new applicants adding 7.5 million hours and $96.9 million. Every percentage point of ex parte coverage is burden that never lands on a member, and a disenrollment risk that never materializes.
What are the outreach and cure-period obligations?
When available data can't establish compliance or an exemption, states must notify the member, request the missing information, and run a 30-day satisfactory-showing (cure) process before any loss of coverage, including noncompliance procedures, coordination with managed care plans, and ongoing monitoring and reporting. Operationally this means tracked notices, reminders and follow-ups in the member's language and channel, and a record of every touch, because an unanswered letter is not evidence of ineligibility.
What can existing eligibility systems do, and not do?
State E&E systems are built to determine eligibility from application data and run scheduled renewals. They are generally not built to verify monthly activity hours from payroll or gig-platform data, surface functional-status evidence for medical-frailty exemptions from clinical documentation, orchestrate cure-period outreach across channels, or produce member-level audit records of every determination. That gap, between what the rule requires and what installed systems do, is the implementation problem of 2026, and it is a layering problem, not a rip-and-replace problem.
What does the timeline look like, working backward from January 1, 2027?
- TodayJune 2026
- Acquisitionvehicle · APD · sole-source
- Integration~8 weeks · data agreements
- Outreach & cure livebefore first determinations
- Jan 1, 2027requirement effective
Working backward from January 1: states that start acquisition this quarter run outreach and cure workflows before the first determinations are due.
Where does Mirza fit?
Mirza is the verification, exception, and compliance layer that attaches to the systems states, plans, and integrators already run. It makes ex parte the default order of operations, brings work-activity and medical-frailty evidence into the check, runs the outreach and cure workflows the rule requires, and delivers an audit-ready record of every determination to your system of record, deployed in about eight weeks.
Sources
- Medicaid Program; Community Engagement Requirement for Certain Individuals (CMS-2454-IFC), Federal Register doc. 2026-11094, published June 3, 2026.
- CMS fact sheet accompanying the interim final rule, June 2026.