NOTE: This page has been updated to reflect the July 21, 2025 Congressional Budget Office (CBO) projections.
The OBBB includes several provisions that focus on improving Medicaid for the most vulnerable. Historically, Medicaid was meant to serve the most vulnerable, but it has drastically expanded so that there are more Americans enrolled in Medicaid with income above the poverty level than there are Americans in poverty. In 2010, the ACA expanded Medicaid to able-bodied, working-age adults with income up to 138 percent of the federal poverty level (FPL). The Biden administration pursued an agenda aimed at maximizing enrollment in public programs regardless of eligibility. These policies resulted in high levels of improper enrollment. Paragon estimates that as many as 6.6 million Medicaid expansion enrollees are improperly enrolled, costing taxpayers billions and straining state resources, which hurts the most vulnerable.
With the passage of the OBBB, Congress is implementing many important measures to reduce improper enrollment and require able-bodied, working-age Medicaid expansion enrollees to work, volunteer, or engage in training to qualify for the program.
Sec. 71101 – Prohibition on implementation of Biden-era rule relating to eligibility and enrollment in Medicare savings programs. The section would delay implementation of the Biden administration’s misguided rule titled “Streamlining Medicaid; Medicare Savings Program Eligibility Determination and Enrollment” until September 30, 2034. The rule exacerbated improper enrollment with weakened verification standards and lack of coordination for dual enrollment in Medicare and Medicaid.
Section Effective Date: 7/4/2025. (CBO Estimated Ten-Year Savings : $66.0 billion)
Sec. 71102 – Prohibition on implementation of Biden-era rule relating to eligibility and enrollment for Medicaid and CHIP. This provision would delay implementation of the misguided Biden administration rule “Streamlining Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes” that made it more difficult for states to remove ineligible enrollees from Medicaid and perpetuated fraud and improper payments.
Section Effective Date: 7/4/2025. (CBO Estimated Ten-Year Savings: $53.6 billion)
Sec. 71103. Reducing duplicate enrollment under the Medicaid and CHIP programs. This provision aims to address the problems of individuals enrolled simultaneously in multiple state Medicaid programs. First, it would require states to use reliable, existing data sources—including address updates from managed care organizations—to track where beneficiaries live. Second, it would require that the Department of Health and Human Services (HHS) create, by 2029, a centralized system to flag individuals enrolled in Medicaid programs in multiple states at the same time. A recent Wall Street Journal report indicated that health insurers received $4.3 billion in duplicate payments for Medicaid enrollees enrolled in multiple states simultaneously from 2019 to 2021.
Section Effective Date: 10/1/2029. (CBO Estimated Ten-Year Savings: $17.4 billion)
Sec. 71104. Ensuring deceased individuals do not remain enrolled. This provision requires states to check the Death Master File quarterly and remove deceased individuals from the Medicaid rolls.
Section Effective Date: 1/1/2027. (Small impact on budget)
Sec. 71105. Ensuring deceased providers do not remain enrolled. This section requires states to check the Death Master File every quarter and remove deceased providers, codifying current Centers for Medicare and Medicaid Services (CMS) regulations.
Section Effective Date: 1/1/2028. (Small impact on budget)
Sec. 71106. Payment reduction related to certain erroneous excess payments under Medicaid. This provision aims to reduce improper payments in Medicaid by enabling the HHS Secretary to disallow federal payments to states with high improper payment rates. Currently, the Secretary is required to disallow federal monies if the improper payment rate exceeds 3 percent, but the Secretary can issue “good faith” waivers from such disallowances. To date, this disallowance requirement has been completely ineffective. The federal government has never recovered improper payments, even though Medicaid’s improper payment rate in some states exceeds 10 times the 3 percent threshold. This provision limits the Secretary’s ability to issue “good faith” waivers. This is a step toward accountability, reducing the risk that waivers become blanket exemptions for chronic state-level noncompliance with federal requirements, particularly around ensuring eligibility requirements are met prior to enrollment.
Section Effective Date: 10/1/2029. (CBO Estimated Ten-Year Savings: $7.2 billion)
Sec. 71107. Eligibility redeterminations. Medicaid enrollees—particularly the able-bodied, working-age adult expansion category—typically have frequent income changes. Many expansion enrollees will be low income for only a few months as they obtain jobs and earn higher income and offers of employer plans, either of which typically disqualify them for Medicaid. The Biden administration prevented states from doing eligibility reviews more than once a year for expansion enrollees, leading to billions in wasteful spending for people who lost eligibility, often due to obtaining new coverage. This provision strengthens program integrity by requiring states to check eligibility every six months.
Section Effective Date: 1/1/2027. (CBO Estimated Ten-Year Savings: $58 billion)
Sec. 71109. Alien Medicaid eligibility. This provision would better ensure that Medicaid funds are reserved for eligible individuals by ending federal funding when an individual’s citizenship or immigration status has not been verified. This provision would only allow the following groups to access public benefits as qualified aliens: (1) lawful permanent residents, (2) certain Cuban and Haitian immigrants, and (3) individuals living in the United States through a Compact of Free Association.
Section Effective Date: 10/1/2026. (CBO Estimated Ten-Year Savings: $6.2 billion)
Sec. 71110. Expansion FMAP for emergency Medicaid. This section would reduce the federal medical assistance percentage (FMAP)—or the share of Medicaid spending paid by the federal government—for emergency services for unlawfully present aliens from 90 percent to the state’s normal FMAP. This would apply to Medicaid expansion states that provide emergency Medicaid coverage for illegal immigrants.
Section Effective Date: 10/1/2026. (CBO Estimated Ten-Year Savings: $28.0 billion)
Sec. 71112. Reducing State Medicaid costs. Currently, most people can enroll in Medicaid when they need medical services and the program will pay for any medical bills they incurred in the prior three months. This policy is referred to as Medicaid’s retroactive coverage. This provision would limit Medicaid retroactive coverage to one month for ACA expansion enrollees and two months for traditional enrollees, counting back from the date of application.
Section Effective Date: 1/1/2027. (CBO Estimated Ten-Year Savings: $4.2 billion)
Sec. 71114. Sunsetting increased FMAP incentive. The American Rescue Plan Act contained a temporary five percentage point FMAP bonus for states that had not yet expanded Medicaid under the ACA if they adopted the expansion. Paragon research has shown that Medicaid expansion worsens Medicaid’s structural problems and diverts resources from the most vulnerable. Although current expansion states would retain their bonuses until they end after two years, this change would prevent further use of federal dollars to incentivize expansion in states that have not yet expanded and have decided to prioritize Medicaid for the most vulnerable.
Section Effective Date: 1/1/2026. (CBO Estimated Ten-Year Savings: $12.8 billion)
Sec. 71119. Requirement for States to establish Medicaid community engagement requirements for certain individuals. This provision would require states to implement community engagement requirements for able-bodied adults without dependents younger than 14—a reform Paragon has long supported. Individuals meet the requirement by working, studying, volunteering, or participating in job training for 80 hours per month. This reform prioritizes work over welfare for able-bodied, working-age adults. It preserves resources for the most vulnerable while promoting work, education, and community service. The provision would take effect on January 1, 2027, with flexibility for states that wish to implement the requirements sooner or later, but no later than December 31, 2028. The provision would also create Government Efficiency Development Grants to help states implement the requirements. The provision includes exemptions from community engagement requirements to ensure the policy only targets able-bodied adults without dependents younger than 14. It exempts pregnant women, children, seniors, medically frail individuals, parents with children younger than 14, caregivers, certain seasonal workers, and those already meeting work requirements under Temporary Assistance for Needy Families or the Supplemental Nutritional Assistance Program.
Section Effective Date: No Later Than 1/1/2027. (CBO Estimated Ten-Year Savings: $317.0 billion)
Sec. 71120. Modifying cost sharing requirements for certain expansion individuals under the Medicaid program. This provision would require states to implement modest cost-sharing for Medicaid expansion adults with incomes above 100 percent FPL, with exemptions for certain services, including primary care, prenatal care, pediatric services, substance use disorder services, and services from Federally qualified health centers, certified community behavioral health clinics, rural health clinics, and emergency services. It also provides $15 million to CMS for implementation funding. Modest copayments can help reduce low-value care and fraud, and this flexibility allows states to learn from each other. The ACA requires cost-sharing in exchange plans for enrollees above 100 percent FPL, so this provision would better align cost-sharing requirements for individuals with incomes above 100 percent FPL in the Medicaid program with those in exchanges in the same income bracket.
Section Effective Date: 10/1/2028. (CBO Estimated Ten-Year Savings: $7.4 billion)