When aspects of H.R.1 take effect in 2026, it will mark the beginning of significant cuts to Medicaid, totaling $1 trillion over the next 10 years, as we reported previously. That means that as many as 10 million people over the next decade will lose healthcare coverage for doctor visits, medicine, and other necessary healthcare services as states adapt their programs to comply with the new law.

Other changes, such as new administrative requirements, are more technical but equally important. In this post, we will focus on one vital aspect of the program that will impact many affordable and supportive housing residents: More Frequent Eligibility Determinations.

These new government-imposed legal requirements affect those who have only proven a low income to the state and are called the “expansion population.” This Medicaid expansion population includes many people experiencing homelessness or housing instability, as well as formerly homeless people. People who are young (under 18), older adults (over 65), or considered disabled by federal determination will not be impacted by this particular change.

Why Eligibility Determinations Impact People Experiencing Homelessness or Housing Instability

The new “Eligibility Determination” rule assumes consistent access to communication from the state and access to technology, which are resources that many people experiencing homelessness or housing instability lack. Without a permanent address, reliable internet, or transportation, they may miss notices, be unable to submit documents, or struggle with online forms and in-person interviews. These barriers mean even fully eligible individuals will risk losing coverage, jeopardizing critical health care and supportive services.

Millions are expected to lose health care coverage not because they are ineligible, but because they will face additional administrative burdens under the new law. The increased frequency of eligibility verification creates a more onerous bureaucratic process, which will likely result in many otherwise eligible individuals losing coverage. This will have a cascading effect on the supportive services that are essential in helping people prevent or end their homelessness.

Those who lose health insurance coverage will also likely lose access to other critical services, including case management, behavioral health services, medications, and specialty care. As a result, more people may rely on short-term emergency room visits or inpatient care, which have limited long-term impact but may become their only option.

Medicaid programs differ from state to state. Each state sets its own rules for eligibility, benefits, and access. Common categories of eligible populations include:

• Children (under age 18)
• Pregnant and postpartum women
• Elderly, blind, and disabled individuals
• Expansion population (adults ages 19–64 qualifying based on low income)

Among these groups, H.R.1 requires that only the expansion population must now prove Medicaid eligibility every six months instead of once annually. All other groups will continue with annual eligibility checks.

Each state Medicaid program has its own “redetermination process” to verify eligibility. Most states offer an online process, while some still require in-person interviews.

The law requires CMS to issue guidance for states by the end of 2025, with implementation required by January 2027. Congress has allocated $75 million nationally to support implementation.

Given the importance of continuous health insurance coverage, we recommend the following three strategies:

1. Influence Your State’s Implementation Process

Over the next 18+ months, states will develop systems to implement H.R.1. You can influence this process through advocacy and by sharing real stories of those you serve. Personal narratives can help policymakers understand the critical role Medicaid plays in people’s lives.

Most states have coalitions focused on expanding healthcare access. Join these coalitions and elevate the voices of people experiencing homelessness or housing instability. Existing briefs and toolkits from organizations like CSH and the National Health Care for the Homeless Council offer practical strategies to limit coverage loss.

2. Data Is Power: Track Health Insurance Coverage

Agencies providing housing or shelter services should track health insurance coverage among those they serve. This includes understanding how individuals obtain coverage and whether they are part of the expansion population.

• Does the individual have health insurance?
• What type of coverage do they have? (Medicaid, Medicare, VA, Marketplace, CHIP, private)
• Are they part of the expansion population?
• If covered by Medicaid, which Managed Care Organization (MCO) provides coverage?

Aggregating and sharing this data with coalitions, state officials, and MCOs can help secure resources and support to maintain continuous coverage.

3. Helping Hands: Build Training and Operational Supports

Many states have roles such as navigators or application assisters who help individuals manage their Medicaid accounts and complete eligibility processes.

These individuals may:

• Receive notifications about redetermination requirements
• Upload documents (e.g., income verification)
• Assist with maintaining coverage

Agencies should prepare by:

• Researching state-specific requirements for application assisters
• Training staff to fulfill this role
• Familiarizing teams with Medicaid enrollment and renewal systems

State coalitions and organizations like Homebase provide toolkits and training resources that can support these efforts.

The Ultimate Goal: Continuous Coverage

Continuous health insurance coverage is essential for individuals to access the services they need to remain stable and thrive in their communities. Supporting individuals through new six-month eligibility checks beginning January 1, 2027, will help protect their access to care, services, and housing stability.