Every deadline. What it means. What we do.
H.R.1 sets a compressed implementation schedule. Missing a milestone means members lose coverage — and plans lose revenue. Here's the full timeline and where hequity.ai fits.
DHCS issues final implementation guidance
DHCS releases final regulations and county implementation guidance for the work and community engagement requirement. Health plans and counties begin internal readiness assessments.
What changes
- Final exemption category definitions published
- County systems integration requirements issued
- Member notice templates released
- Reporting requirements finalized
hequity.ai
- Exemption Engine calibrated to final DHCS exemption definitions
- ADT and EHR integration onboarding begins for health plan partners
- Baseline member panel scans delivered to early partners
Work requirement takes effect
The H.R.1 work and community engagement requirement becomes effective for Medi-Cal expansion adults. Members must meet 80 hours per month of qualifying activity or qualify for an exemption. The first renewal cycle under the new rules begins.
What changes
- 80-hour monthly requirement active for expansion adults age 19–64
- Six-month renewal cycle begins — first renewals due June 2027
- Counties begin processing exemption claims and work documentation
- Members without documentation or exemption begin disenrollment process
- Estimated 1.1M members at immediate risk of disenrollment
hequity.ai
- Exemption Engine running live scans across partner member panels
- Retention Navigator work queues active — daily outreach begins
- Work Hours Record available to members without a clear exemption
- Contact Refresh running continuous address reconciliation
- Coverage Shield monitoring renewal pipeline for at-risk members
First renewal wave — highest disenrollment risk
The first cohort of expansion adults reaches their six-month renewal date under the new rules. Members who have not documented qualifying activity or secured an exemption face disenrollment. This is the highest-risk period in the implementation.
What changes
- First disenrollment notices issued to members without documentation
- Counties process first wave of exemption claims
- Plans report first-wave disenrollment data to DHCS
- Appeals process opens for members who believe they were wrongly disenrolled
hequity.ai
- Coverage Shield escalation workflows active for members approaching termination
- Retention Analytics delivers first-wave cohort analysis to plan partners
- Navigator teams surge capacity for emergency outreach
- Post-disenrollment re-enrollment support for members who qualify for late exemptions
Full steady-state — ongoing renewal cycle
The work requirement is fully operational. All expansion adults are in the six-month renewal cycle. Plans and counties have processed at least one full renewal wave. Ongoing compliance and retention work continues.
What changes
- All expansion adults in active six-month renewal cycle
- DHCS publishes first annual disenrollment report
- Federal waiver review period begins — potential rule modifications
- Plans submit first annual retention compliance reports
hequity.ai
- Retention Analytics year-one cohort reporting delivered to all partners
- Exemption Engine updated for any DHCS rule modifications
- Continuous improvement cycle: navigator outreach protocols refined from year-one data
Federal waiver review and potential rule changes
The federal government conducts its first formal review of the H.R.1 Medicaid work requirement waiver. Rule modifications, exemption category changes, or implementation adjustments may be issued. Plans and counties must be prepared to adapt.
What changes
- CMS publishes waiver review findings
- Potential changes to exemption categories or documentation requirements
- State-level implementation adjustments may be required
hequity.ai
- Exemption Engine updated within 30 days of any rule change
- Partner briefings issued on rule change implications
- Retention Analytics updated to reflect any new reporting requirements
Don't wait for January 2027.
Health plans and counties that start now have 90+ days to identify exemptions, refresh contact data, and train navigators before the first renewal wave. Plans that wait until January will be reacting — not preventing.
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