NCSL expert: federal OB3 will require big system changes and could cause coverage churn without careful state planning

Mar 4, 2026

Catherine Costanza of the National Conference of State Legislatures told a Minnesota House committee that the 2026 federal law (referred to in the hearing as OB3/HR1) shortens retroactive eligibility, requires more frequent redeterminations and adds work/community engagement rules for expansion enrollees; she urged stronger data connections, noted federal grants and a 90% match for system upgrades, and warned of implementation challenges and potential coverage losses.

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Catherine Costanza, a fellow with the National Conference of State Legislatures' health program, told the Minnesota House Health Finance and Policy Committee that OB3 (also discussed in the hearing as HR1 or OB3) changes Medicaid eligibility rules nationwide and creates a fast implementation schedule for states.

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