What Do We Know?
On a high level, we know that H.R. 1 brings the following changes to Medicaid operations, beginning in 2026 and rolling out into 2028:
- More frequent redetermination
- Shorter period for help with recent medical bills
- Work or activity requirements
- A small copay may apply for some healthcare services
- Changes to OHP for many immigrants
- Changes to state-directed payments
While the federal government has not released details about all these rules yet, you can stay up to date with the latest information on OHP’s federal changes webpage.
Most adults aged 19-64 will move from 2-year redetermination cycles to 6-months. Children and adults with certain conditions will redetermine every 12 months.
It is currently expected that this change will begin rolling out in October 2027, once Oregon’s current 1115 Waiver expires. However, it is not yet clear exactly how these changes will be applied to existing renewal dates for members. OHA is awaiting more guidance from CMS and will provide more details when available.
Regardless, it is expected that this change will lead to more “churn” for Medicaid membership nationwide due to the increased administrative burden for all involved.
Many adult members will now have to meet, or have an exemption for, work or activity requirements to maintain eligibility for OHP.
Who Does It Apply To?
- Adults 19-64
- Does not have Medicare
- Does not have OHP based on disability or pregnancy
- Does not include OHP Bridge members
Who Is Exempt?
- Caregivers for children under 14 or someone with a serious health condition
- Members who are, or were recently, pregnant
- Have SNAP/TANF and meet those work requirements
- American Indian & Alaskan Native members
- Members who are blind or have a serious/disabling health condition that significantly impairs their ability to work (i.e. medical frailty)*
- Have SUD diagnosis or are in treatment
- Aged out of foster care at 18, and are currently aged 19-26
- Are incarcerated
*While CMS has provided some guidance, it is not complete. OHA is developing a code list that will be used for 2027 while awaiting further clarity from CMS.
Temporary Exclusions
Current guidance is that these criteria will have a 1-month lookback for new applicants, or a 6-month lookback for renewals.
- Recently turned 19
- Spent at least one week away from home to get health care for self or dependent; missed time in work/school to help a dependent while traveling for care
- Overnight impatient admission or received critical care in another setting
- Were on certain other OHP programs before renewal
- Recently released from incarceration
- Lived in an area with a federally declared disaster or high unemployment
- Are entitled to or receiving Medicare Part A, or are enrolled in Medicare Part B
How are Exemptions Verified?
- Oregon must rely on automated verification to the extent possible, utilizing data already available in their systems (e.g. claims).
- When medical exemptions cannot be automatically verified:
- 2027: Members will be able to self-attest.
- 2028: Members can still potentially self-attest, but in most cases, they will need to provide supplemental evidence.
How Can Members Meet Activity Requirements?
- Have a gross household income of more than $580/month (less than 40 hours at Oregon minimum wage).
- Enrolled in high school, a GED program, or at least half-time in higher education.
- Complete at least 80 combined hours of monthly work, education training, or unpaid work.
What Is Unpaid Work?
- Volunteering, certain types of caregiving, and unpaid work traded for housing or other needs.
- Must be a structured program that benefits community, public or civic need.
- The program must have oversight and the ability to track the time completed by the individual.
- Cannot be tied to political parties, candidates or beliefs.
- OHA is working on more guidance and toolkits for nonprofits and community organizations who wish to support members with volunteer / unpaid work opportunities.
In October 2026, around 7,000 members statewide will move from standard OHP to the Healthier Oregon program. For the remainder of 2026, these members will continue to be served by their assigned CCO.
On January 1, 2027, all Healthier Oregon members (including those who were already in this program and those who joined in October 2026) will move from CCOs to Open Card / Fee for Service (FFS). OHA & CCOs are working together to ensure that the necessary steps are taken for transition of care.
As a provider, you can continue seeing these patients if you are enrolled with Open Card / FFS. To learn more about serving as an Open Card provider, visit OHA’s website.
Currently, new members can get help with up to 3 months of medical bills. Starting in 2027, most adults aged 19-64 will only be eligible for 1 month of past bills. All other members, including children, people over 65, and anyone pregnant or on OHP programs based on disability, will be eligible for up to 2 months of past bills.
These changes are not expected to roll out until October 2028. OHA has indicated that they will provide more details and guidance mid-2027. We will update this page when we have more to share.
This change is currently not expected to be implemented until 2028 or 2029, so more guidance will come later.
What Can You Do?
OHA is developing a toolkit to assist partners with member education and communication. Once this is available, Umpqua Health will also be evaluating ways to supplement the material with our own resources. This may include things like flyers/brochures and posters that you can display in your clinics & offices. We will share more about these resources in the coming months.
You can use this tool for a list of OHP-certified assisters in Douglas County.
For Providers
Providers already have access to member renewal dates via the member roster in the UHBI Provider Portal. This information can help prompt conversations with members about renewal assistance.
For CBOs
As you engage UHA members in the context of other programs, there may be opportunities to connect members with Community Assisters for application/renewal assistance.
The topic on which we’ve heard the most questions is medical exemption, and to what extent providers will be responsible for helping members submit evidence.
Here’s what we know:
- OHA will first rely on automated verification via claims. To help with this, providers can ensure that members with qualifying conditions are seen annually and that relevant claims are submitted.
- If OHA cannot verify automatically, members can self-attest. In 2027 this self-attestation will be sufficient, so it is not expected that providers will need to play a direct role. Starting in 2028, members will often need to provide supplemental documentation. OHA intends to create an (optional) standardized form that providers can use to assist members with these requests.
Members who are required to meet work or activity requirements may need assistance in finding suitable opportunities. We believe CBOs in Douglas County will be able to play a pivotal role in supporting these members.
Qualifying Activities
While OHA is still working on more guidance & resources related to volunteer opportunities, here’s what we know:
- Volunteering, certain types of caregiving, and unpaid work traded for housing or other needs.
- Must be a structured program that benefits community, public or civic need.
- The program must have oversight and the ability to track the time completed by the individual.
- Cannot be tied to political parties, candidates or beliefs.
If you represent a CBO and offer programs that may fit the criteria above, we’d love to hear from you at UHNProviderServices@umpquahealth.com.