Rubinstein Productions

Cross-State H.R. 1 Implementation Tracker

Updated 2026-06-12. First compiled 2026-05-25. Isaac Rubinstein, Rubinstein Productions.

H.R. 1 imposes 80-hour-per-month work requirements on Medicaid expansion adults, federally effective 2027-01-01. State implementations span 19 months across the early-implementer cohort. Each state generates its own dashboard, its own reporting process, its own first-cohort experience. The cross-state pattern, what is working and where it is breaking, is not visible from any single state's reporting.

This tracker captures what is publicly visible across eight early-implementer states and names what is opaque without member-level documentation.

The eight states

Nebraska. Live 2026-05-01.

DHHS Division of Medicaid & Long-Term Care. Director Drew Gonshorowski (Paragon Institute background, appointed Dec 2024).

VisibleImplementation dashboard at dhhs.ne.gov. First state to go live nationally, 42 days into operation as of this writing.
OpaqueFirst-cohort experience with the monthly reporting workflow. Exemption-pathway failure rates. Frontline FQHC staff observations. Behavioral-health carve-out functioning.

Montana. Live 2026-07-01 (19 days out).

DPHHS. Director Charlie Brereton. Deputy Medicaid Director Gene Hermanson. Implementation page at dphhs.mt.gov/medicaidchanges.

VisibleStatute, effective date, agency communications. Pre-launch is the only baseline window.
OpaqueFrontier and rural CHC absorption patterns. How urban-versus-rural disenrollment will diverge. SUD treatment continuity disruption (the most exemption-sensitive population).

Iowa. Live 2026-12-01. 146,000 affected.

Iowa HHS Medicaid. Director Lee Grossman (started Sept 2025, prior WY Medicaid Director, Iowa native).

VisiblePopulation estimate, effective date, work-requirements page at hhs.iowa.gov. Iowa just merged MH and SUD into one Behavioral Health Service System (July 2025).
OpaqueHow the BH-system reorganization interacts with work-requirement enforcement. CHC documentation burden across 146K monthly reporters. New-director posture toward external evaluation.

Arkansas. Soft launch 2026-07-01. Federal enforcement 2027-01-01.

Arkansas DHS Medicaid (ARHOME).

Visible2018 work-requirement experiment is the only U.S. precedent. 18,000 lost coverage in five months. ACHI produced the canonical quantitative evaluation.
OpaqueWhether 2026 design choices avoid the 2018 failure modes. Whether CHCs that absorbed 2018 churn still hold longitudinal memory. The qualitative companion to ACHI's quant work has never been written.

Georgia. Pathways extended through 2026-12-31.

Georgia DCH. Medicaid Director Stuart Portman (incoming NAMD president 2026-04-01).

VisibleGAO and ProPublica analyses of Pathways cost ratios. Enrollment numbers far below projection.
OpaqueWhether the second-half-2026 extension period gets framed as course-correction or defense. Member experience with the Pathways reporting interface, distinct from H.R. 1 federal design.

Idaho. Statutory adoption by 2026-12-31. Federal effective 2027.

Idaho DHW Division of Medicaid.

VisibleHB 913 signed April 2026. 34,000 at risk. 3-month lookback is the longest in the country.
OpaqueWhether the 3-month lookback protects or excludes. Frontier-rural CHC documentation burden under that design. The interaction between extended lookback and reporting-month verification cycles.

South Dakota. Implementation pending.

SD DSS Medicaid.

VisibleStatute trajectory. SD also received $189.4M Rural Health Transformation grant (separate but coincident funding stream).
OpaqueWhether the two funding streams get consolidated under one learning vehicle. Tribal-population exemption pathway functioning (Community HealthCare Association of the Dakotas covers ND and SD both).

Ohio. Implementation pending.

Ohio Department of Medicaid. OACHC (Ohio Association of Community Health Centers) covers 60+ CHCs across 200+ counties.

VisibleStatute trajectory. Geographic distribution of affected population is unusually broad.
OpaqueHow eligibility churn cascades across 200+ counties with varying CHC density. Multi-site narrative documentation across OACHC membership has not been attempted.

The cross-state question

The data dashboards each state will publish will tell you who fell off and when. They will not tell you why. They will not tell you what frontline FQHC staff observed during the first three reporting cycles. They will not tell you which exemption pathways failed and which held. They will not tell you whether the design choice that distinguishes Idaho from Arkansas mattered in practice.

Eight states implementing the same federal requirement on eight different timelines with seven different design variations is a natural cross-state experiment. The synthesis question, what worked and what did not, is the synthesis no single state agency can answer for itself.