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Texas — Medicaid Coverage Retention

Largely N/A Last updated 2026-06-03 · confidence: confirmed

Texas is subject to federal Medicaid community-engagement/work-requirement implementation beginning January 1, 2027, unless modified by future federal or state guidance.

Latest detail

Texas is one of ten non-expansion states (with AL, FL, GA, KS, MS, SC, TN, WI, WY). The H.R.1/OBBBA Medicaid community engagement ("work") requirement, effective Jan 1, 2027, applies only to adults 19-64 in the ACA Medicaid expansion group or in an 1115 waiver providing minimum essential coverage. Because Texas never expanded Medicaid and does not operate an expansion-equivalent MEC waiver, the requirement is effectively inapplicable, and KFF's work-requirement trackers (both SPA and 1115-waiver) do not list Texas as implementing. HHSC stated (as of April 2026) it is still assessing OBBBA's overall impact; the only relevant 2026 HHSC solicitation is the routine Enrollment Broker Operations RFP HHS0016867 (forecast July 2026) for general client enrollment/outreach, not tied to work requirements, and Accenture remains the incumbent TMHP business-operations/enrollment-outreach vendor.

Medicaid expansion status	Non-expansion
Implementation status	Not applicable — Texas has not adopted ACA Medicaid expansion, so there is no expansion group subject to the H.R.1 community-engagement requirement. No state implementation is required or planned for the expansion group as of June 2026. (Indirect fiscal effects from H.R.1 SNAP/ACA/financing provisions still expected, but no work-requirement program.)
Who may be affected	Effectively none for the H.R.1 work requirement. The federal requirement applies only to ACA Medicaid expansion adults (and partial-expansion waiver enrollees in GA/WI). Because Texas never expanded Medicaid, there is no expansion population (adults 19-64 at/below 138% FPL) to which the requirement attaches. Texas adults without dependent children generally cannot qualify for Medicaid at all regardless of income, so no subject group exists.
Reporting frequency	Not applicable (no subject group). Federal default for expansion states is verification at application and at least once between redeterminations (i.e., at minimum semi-annually).
Reporting method	Not applicable — Pending state guidance (no work-requirement reporting system needed in a non-expansion state).
Renewal cadence	Not applicable to a Texas expansion group (none exists). Federal H.R.1 default for expansion adults in expansion states is redetermination every 6 months.
Notice timing	Not applicable — no expansion-group member notices required in Texas. (Federal interim final rule window CMS-2454-IFC issued ~June 2026; member-notice activity in expansion states is in the Jun 30-Aug 31, 2026 range.) Pending state guidance.
Self-attestation allowed?	Not applicable / Pending state guidance — no Texas work-requirement program exists to define self-attestation policy.
State system / vendor	Texas Integrated Eligibility Redesign System (TIERS) / YourTexasBenefits, administered by Texas HHSC (system integration historically Accenture/Deloitte-era; claims administrator TMHP operated by Accenture). Pending precise current vendor confirmation. Not relevant to a work-requirement program (none exists).
Major Medicaid MCOs	Superior HealthPlan (Centene) — incl. statewide STAR Health (foster care), UnitedHealthcare Community Plan, Molina Healthcare of Texas, Wellpoint (formerly Amerigroup, Elevance), Blue Cross and Blue Shield of Texas (HCSC), Aetna Better Health of Texas (CVS), Community First Health Plans, El Paso Health, FirstCare (Baylor Scott & White), Driscoll Health Plan, Texas Children's Health Plan, Cook Children's Health Plan, Parkland Community Health Plan
Languages likely needed	Spanish, Vietnamese, Chinese (Mandarin/Cantonese), Korean, Arabic, Tagalog, Urdu, Hindi

Key exemption categories to monitor

• 80 hours/month of work, job training, education, or community service — or qualifying monthly income.
• Targets many ACA Medicaid expansion adults (19–64); non-expansion states largely have no such group.
• Federal enforcement: January 1, 2027 (states implement; some earlier).
• New: expansion adults redetermine every 6 months (not annually).
• Commonly-defined exemptions: pregnancy/postpartum; medically frail; primary caregiver; disability; SUD treatment; certain students; tribe (AIAN); short-term hardship. Exact definitions set by CMS rule and each state.

Short-term hardship exemptions to track

Not applicable — no expansion group in Texas, so the state has no obligation to adopt H.R.1 short-term hardship exceptions for a work-requirement program. Federal framework permits states to grant short-term hardship exceptions for extenuating circumstances, but this is moot for Texas absent an expansion population. Pending state guidance if Texas were ever to expand.

Member communication risk

Low procedural-disenrollment risk specifically from H.R.1 work requirements, because Texas has no expansion group subject to them — no semi-annual work-reporting churn will be created. Note: separate (non-work-requirement) procedural-disenrollment risk persists in Texas from its general renewal processes and any H.R.1 financing/eligibility ripple effects, but that is outside the work-requirement scope.

What MCOs & state partners should do now

• Treat Texas as out-of-scope for H.R.1 community-engagement outreach campaigns — do NOT build or sell a Texas work-requirement member-engagement program; there is no subject population. Reallocate that capacity to confirmed expansion states (e.g., NE/MT/IA early implementers, AZ).
• Monitor Texas Legislature (next regular session 2027) and any expansion bills (e.g., HB807-type proposals); only if Texas were to expand would a subject group and work-requirement obligations arise.
• Track indirect H.R.1 impacts on Texas Medicaid financing (provider rate, optional-benefit, and HCBS pressure) that could affect MCO contracts and member benefits, even without work requirements.
• If positioning a Medicaid engagement-layer offering nationally, footnote Texas explicitly as non-applicable to avoid mis-scoped proposals or compliance claims.
• Verify against the KFF Work Requirements Tracker before any Texas-specific assertion, since status flips would change applicability.

Frequently asked

Sources

• https://www.kff.org/medicaid/status-of-state-medicaid-expansion-decisions/
• https://www.kff.org/medicaid/a-closer-look-at-the-work-requirement-provisions-in-the-2025-federal-budget-reconciliation-law/
• https://covertexasnow.org/posts/2026/2/27/new-resource-explains-how-hr-1-will-impact-states-that-dont-have-medicaid-expansion
• https://www.kff.org/medicaid/medicaid-work-requirements-tracker-overview/
• https://www.kff.org/medicaid/medicaid-work-requirements-tracker-1115-waivers/
• https://www.chcs.org/resource/a-summary-of-national-medicaid-work-requirements/
• https://www.aapd.com/work-requirements-update/
• https://apps.hhs.texas.gov/procurement-calendar/procurement-forecast.pdf

This page tracks publicly available implementation information and is updated as Texas publishes guidance. State-specific rules are evolving. Not legal or eligibility advice.