The “One Big Beautiful Bill Act” (OBBBA), which was enacted in July 2025, includes several provisions that will impact state Medicaid agencies and correctional leaders who are working to strengthen access to services and continuity of care for people who are leaving prison and jail. HARP has previously provided expert analysis on the law, and now offers specific strategies for states to consider as they prepare to implement new requirements that go into effect next year.
Beginning January 1, 2027, under a new requirement established by the OBBBA, adults ages 19 to 64 who are Medicaid expansion beneficiaries must participate in 80 hours of “community engagement” activities in order to obtain or maintain Medicaid coverage. The law also establishes new requirements for Medicaid programs to conduct eligibility renewals at least every six months, rather than annually for Medicaid expansion beneficiaries.
For several years, states have been strengthening access to and continuity of care for Medicaid beneficiaries who are leaving incarceration. This work is taking place through new youth and young adult continuity of care policies, Medicaid section 1115 demonstrations, and requirements that states suspend rather than terminate Medicaid eligibility when someone enters incarceration. States can leverage these ongoing efforts to support effective OBBBA implementation. Doing this can be efficient and relatively low cost, because it builds upon approaches states have already put in place, or are in the process of implementing.
HARP has identified four specific strategies states can use to leverage reentry approaches to implement some aspects of OBBBA’s new community engagement requirements, including some exemptions from those requirements and more frequent Medicaid eligibility renewals. These strategies include:
Operationalize OBBBA’s Correctional Exemption from Community Engagement through Medicaid Suspension Requirements
Strengthen Case Management to Support Connections to Employment and Education and Inform Beneficiaries About Community Engagement Requirements
Leverage Screenings and Assessments to Facilitate Qualification for Medical Frailty and Other Community Engagement Exemptions
Facilitate Medicaid Enrollment and Renewal in Prisons and Jails
As states implement the new community engagement requirements and renewal periods under OBBBA, multiple opportunities exist for them to leverage the work states are already doing in conjunction with correctional partners. Within states, eligibility staff and staff leading reentry reforms can collaborate closely to achieve effective OBBBA implementation.
HARP offers technical assistance to help states and local governments effectively implement health and reentry policies. HARP also provides assistance to county health and correctional facilities and other organizations involved in the work of implementation. From translating Medicaid policy for public safety audiences to tackling the operational realities of correctional settings and building effective access to community services, HARP helps identify and operationalize the most effective strategies for successful implementation.
Email TA@healthandreentryproject.org to learn more.