01REQUIREMENTS:
By September 30, 2026: Billing and eligibility teams must (1) audit current patient roster to identify noncitizen Medicaid beneficiaries, particularly refugees, asylees, humanitarian parolees, and survivors of domestic violence/human trafficking who will lose coverage on October 1, 2026; (2) update eligibility verification systems to flag and terminate coverage for ineligible noncitizens effective October 1, 2026; (3) create patient notification process to inform affected beneficiaries of coverage loss and alternative programs (HBIS, AATV, etc.); (4) train front desk and billing staff on remaining eligible noncitizen groups (green card holders, Cuba/Haiti entrants, COFA migrants, children under 19, pregnant women).
02Before January 1, 2027: Billing and clinical teams must (1) identify all ACA Adult patients subject to work requirements; (2) implement documentation system to capture and track work requirement exemption status (medically frail, caregiver status, TANF receipt, etc.) for each ACA Adult patient; (3) establish process for providers to document medical necessity for exemptions related to special medical needs, with emphasis on keeping records of appointments and Medicaid claims data; (4) create encounter form additions or EMR templates to capture work requirement exemption information at each visit; (5) train clinical staff on exemption categories and encourage patients to establish Manage My Case accounts; (6) coordinate with state HFS regarding provider role in exemption documentation process once CMS clarifies expectations.
03Immediate: Contact HFS Federal Resource Center for supplemental guidance on noncitizen coverage loss notices, work requirement reporting procedures, and documentation standards.
04Monitor HFS website for forthcoming clarifications on provider role in work requirement exemption determination and required documentation.