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Maryland health officials say HR 1 could shrink Medicaid rolls and cost the state if it backfills federal cuts

Health and Government Operations Committee · December 3, 2025
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Summary

Maryland Department of Health officials told the committee HR 1’s immigrant‑eligibility changes and new work and reporting requirements could put as many as 175,000 people at risk of losing Medicaid and threaten up to $2.7 billion in federal funding; agencies outlined IT, staffing and communications plans to limit churn.

Maryland Department of Health officials told a joint briefing that provisions of the federal HR 1 law could reduce Medicaid enrollment, increase administrative churn and expose the state to large financing changes unless the state takes mitigating actions.

"We are looking at potentially $2,700,000,000 in annual federal funding lost to Maryland," Perry Briskin, Medicaid director at the Maryland Department of Health, said during his presentation, describing the provisions as phasing in through 2030.

Briskin and MHPE representatives outlined three principal eligibility impacts: immigrant eligibility limits, community‑engagement (work) requirements and shortened redetermination and retroactive coverage windows. MDH estimated that immigrant eligibility changes could affect about 60,000 lawfully present noncitizens who currently receive coverage. For work requirements, Briskin said adults ages 19–64 will need to document either 80 hours of work a month or meet an income threshold beginning Jan. 1, 2027; he said about 320,000 adults are in the relevant coverage group and up to 115,000 could lose coverage because of churn or failure to comply with reporting.

“We are also...shortening what we call retroactive coverage opportunities,” Briskin said, noting retroactive eligibility will be reduced from three months for many people and that redeterminations for some groups will move from annually to every six months — changes the department expects to increase administrative churn.

MDH discussed technical and administrative mitigation steps: submitting advanced planning documents (APDs) to CMS to obtain enhanced federal IT match (90/10) for system work, building a work‑requirement verification system at the Maryland Health Benefit Exchange (MHPE) with internal testing planned by August 2026, leveraging existing state data sources to verify exemptions, and partnering with managed care organizations and community stakeholders to amplify communications.

Briskin said notices to affected individuals must be distributed by August under federal rules, and MDH plans county‑level and district dashboards with age and race breakdowns to help legislators and advocates prepare targeted outreach. Officials also emphasized using federall qualified health centers and behavioral health networks as safety nets for people who become uninsured.

During questions, legislators asked about the overlap between SNAP and Medicaid populations, the cost of backfilling coverage with state dollars, and where additional staffing and IT costs would fall. Briskin said agencies are working with the governor’s office on budget requests and that the state would prefer to invest up front rather than pay far higher costs later if systems fail. MDH and DHS said combined effects of immigrant eligibility changes, work requirements and more frequent checks could put about 175,000 Marylanders at risk of losing coverage, and lawmakers and staff asked the agencies to validate those estimates and return with precise figures and cost analyses.

MDH said it will continue stakeholder roundtables, release an "ACA deep dive" deck with county‑level data, and coordinate a communications campaign with MCOs and community partners.