March 2026
Meet Briljent's 2025 Adam Hayden Culture Award Winner
At Briljent, culture is not a slogan. It is how we show up for one another, our clients, and our communities. That is why we are proud to recognize Amber…
July 2025
What the One Big Beautiful Bill Means for State Agencies, Vendors, and Implementation Teams—Now Expanded and Updated
By Adam Hayden
Summary
This post has been updated to include the latest details on HR-1 (The One Big Beautiful Bill Act) work requirements, exemptions, implementation timelines, and compliance protections—plus insights from recent CMS guidance, APHSA analysis, and Briljent’s conference highlights.
What’s Changing Under the One Big Beautiful Bill Act
Now Expanded: Latest Updates, Key Details, and Actionable Insights -October 3, 2025
What’s New (October 2025 Update)
The OBBBA landscape is evolving rapidly. Since our original post, new federal guidance, APHSA analysis, and state implementation experiences have clarified timelines, exemptions, and compliance requirements. This expanded post includes:
- A program-by-program breakdown of work requirements and exemptions
- Updated implementation timelines and waiver options
- Notice and fair hearing protections for affected individuals
- Risks and opportunities for agencies and vendors
- Insights from recent conferences and CMS guidance
OBBBA: A Sweeping Shift for Public Benefits
The One Big Beautiful Bill Act (OBBBA) is reshaping Medicaid, SNAP, TANF, and ACA Marketplaces. Agencies and vendors face new operational, compliance, and technology challenges. Briljent is ready to help partners navigate these changes with clarity, care, and proven expertise.
Key Provisions & Timelines
- Medicaid: Biannual eligibility redeterminations begin December 31, 2026. New work requirements for adults 19–55 (80 hours/month) take effect January 1, 2027, with exemptions for disability, caregiving, education, and other state-defined good cause.
- SNAP: Expanded work requirements for adults 18–54, with detailed exemptions for disability, pregnancy, caregiving, and student status. ABAWDs face time-limited benefits unless meeting work or training requirements.
- TANF: Federal Work Participation Rate standards apply, with state-defined hours and exemptions.
- ACA Marketplaces: Stricter call center and enrollment reporting, enhanced identity verification, and phased changes to premium tax credits and subsidies.
Most changes take effect in 2026–2027, but states may opt in early via waivers. Final details depend on forthcoming CMS guidance.
Who’s Exempt & What’s Protected
Certain populations—such as people with disabilities, caregivers, and others—may be exempt from new work requirements. States must provide clear notice and fair hearing opportunities to individuals whose benefits are affected by these changes.
Program-by-Program Breakdown
| Program | Work Requirement | Exemptions | Certification Period | Compliance Tracking |
|---|---|---|---|---|
| Medicaid | 80 hrs/month (19–55) | Disability, caregiving, education, pregnancy, good cause | 6 months | Countable months; loss of eligibility for non-compliance |
| SNAP | Register/work/E&T (16–59); ABAWD: 80 hrs/month (18–54) | Disability, pregnancy, caregiving, student, others | 12 months (general); 3–4 months (ABAWD) | Countable months; time-limited benefits |
| TANF | State-defined hours; must meet federal WPR | Disability, caregiving, pregnancy, others | State-defined | Work Participation Rate (WPR) |
What’s at Stake: Risks & Opportunities
- Risks: Compressed timelines, risk of coverage loss, increased administrative burden, and heightened scrutiny.
- Opportunities: New funding for modernization, expanded training needs, and improved compliance and reporting.
Latest Updates
- CMS Guidance: New rulemaking and sub-regulatory guidance expected by December 2025.
- APHSA Analysis: Detailed crosswalks clarify work requirements, exemptions, and compliance mechanisms.
- Conference Highlights: MESC 2025 (Reflections from MESC 2025: Navigating Change, Technology, and Human-Centered Readiness)
and other events spotlight AI adoption, eligibility modernization, and best practices for implementation.
How Briljent Supports Partners
Briljent offers:
- AI-enabled training and microlearning for eligibility workers and call center staff
- Change management and technical assistance for agencies and vendors
- Staffing and surge capacity for periods of intense policy change
- Strategic planning and compliance consulting for system modernization
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