Most people probably never think about Medicaid renewals until a letter shows up reminding them of the cumbersome task. Now, however, H.R. 1 changes how often that letter may come, what it asks for, and how easy it is to keep coverage you already qualify for. For many adults, renewals will now happen twice a year; work reporting will be required (adding new paperwork); and the federal audit rules that measure “errors” will tighten. That’s a lot of moving parts for both busy families and county workers.
Here’s what that looks like in practice:
Beginning Dec. 31, 2026, H.R. 1 will require some adults in the expansion (MAGI) group to renew every six months instead of annually. Medicaid eligibility is determined on a per-person basis, not per household. So in one family, a mom might renew in January and July, her partner in April and October, and their child on Medicaid only once a year in February. Mail, texts, and portals now fire on different clocks for each person. That means more chances to miss a notice, send a form late, or have one person fall off coverage while others stay on. It’s confusing for families and doubles the touchpoints for county workers who must open, verify, and close out twice as many renewal actions for those adults. The Centers for Medicare & Medicaid Services (CMS) has stressed that ex parte (automatic) checks should be used whenever possible–but six-month cycles still create more traffic, which increases churn even when people remain eligible. In Colorado, the state projects about 375,000 Coloradans will be on the six-month renewal cycle starting January 2027.
States use ex parte renewals to check trusted data (such as SNAP, wage, and tax records) and automatically keep eligible people covered without needing additional forms. Ex parte is a proven way to cut red tape, decrease churn, and reduce call-center backlogs. However, once eligibility depends on work reporting starting January 2027, automation breaks down. Weekly schedules, shift changes, and caregiving hours don’t live in clean, statewide databases. States can’t passively verify every hour worked, so instead of smooth auto-renewals, families get more requests for pay stubs and portal uploads; caseworkers get more calls and follow-ups; and people who are already working can still lose coverage over missed paperwork. That churn is costly for families and strains the frontline staff who must process all the extra paperwork.
Once implementation begins in earnest, states will have to decide how to use or modify existing processes, such as ex parte renewals. Under federal rules, states must attempt ex parte first at the individual level before asking a person for anything–that baseline expectation still applies under H.R. 1. What changes is the logic states run and the data they check. Therefore, two key considerations for preparing for implementation would be, one, to update ex parte renewal logic by adding modifications, such as compliance and exemption checks, and two, to broaden the data sources the system can tap, albeit carefully (and that caution cannot be overstated).
Whether it’s preparing for implementation with options like those listed above or with any number of other solutions, all states, especially those like Colorado that did not already have work requirements prior to H.R. 1, should be prepared to design guardrails that keep ex parte renewals workable. Two practical choices could lower friction right away: accept self-attestation for exemptions when allowable (verification can happen later if needed), and keep proofs broad (such as pay stubs or employer or school letters) with reasonable grace periods, especially at the onset of implementation. A well-designed and well-maintained ex parte renewal process benefits everyone. Every case that can be resolved via ex parte is one that county offices don’t have to open, pend, deny for failure to provide, or reinstate later. As a result, the state would have less churn and see reduced error exposure.
PERM–CMS’s program that estimates improper-payment error rates (not fraud)–is tightened by H.R. 1, which changes how findings can trigger federal penalties for eligibility errors and broadens the scope of audits that can be counted. PERM eligibility error rates over 3% incur a reduction in federal funds. Prior to H.R. 1, the HHS secretary had discretion to waive that reduction based on the state’s good-faith effort and, thus, it had never been applied in practice. Now, effective fiscal year 2030, H.R. 1 restricts when the secretary can waive penalties, expands which audits can be used to calculate a state’s error rate, and specifies that any case lacking required documentation is automatically counted as an eligibility error.
For context, PERM measures paperwork and process compliance and is primarily concerned with whether the state followed its own rules and documented its decisions. Improper payments are often due to missing or mismatched paperwork rather than fraud. When states react by adding more verification steps “just to be safe,” they paradoxically raise PERM exposure because complex, high-traffic processes are where documentation breaks down and errors occur. The smarter policy play is to keep rules simple, automate data checks whenever possible, and design forms that people can easily complete, such as on their mobile phones.
Simply put, H.R. 1 didn’t just add inconsequential rules, but more clocks for families to track and more places where paperwork can go sideways. However, these changes coming down the federal pike should not be an excuse for states to pursue further bad policies. It should be an opportunity to slow down and make decisions on implementation strategies based on evidence, sustainability, and the goal of avoiding another unwinding by keeping people insured. And the way to keep eligible people covered is simple, not fancy: maximize and re-engineer ex parte, build self-attestation into that flow, keep proofs broad with short grace periods, and use PERM as a reason to simplify–not stack on steps to ensure we trip. While there are many other considerations beyond the renewal process, these remain viable options as we consider how to cut churn, ease the load on county workers, and keep care within reach for Colorado families in the coming years.
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