Policy Monitor

Tracked sources (15)

Change log

• 2026-09-03published

  Initial data layer built: 2026 FPL guidelines, OBBBA federal baseline (80 hrs/mo, 6-month redetermination, Jan 1 2027 backstop), 8 state profiles with official application portals and exemption notes.

• 2026-09-04published

  Immigrant eligibility hub (OBBBA Sec. 71109, Oct 1 2026) launched in English and Spanish with 8 immigration-category subpages; site-wide SEO foundation (sitemap, robots, per-page metadata).

• 2026-09-07published

  Expanded state coverage from 11 to 15 states (added Missouri, Florida, Texas, Tennessee); added $580/month income-alternative guide with 12-month averaging; Spanish exemption wizard; state-tracker open dataset page; enforcement-start dates added as a distinct field for active states (NE 2026-05-01, MT 2026-07-01, GA 2023-07-01); Indiana/Michigan/Louisiana lookback periods (3/1/1 months) marked verified; Arkansas soft launch (2026-07-01 monitoring, penalties from 2027-01-01) logged. All state files re-verified 2026-09-07.

• 2026-09-10published

  Medically frail verification rules corrected and expanded in the federal baseline, and a federal litigation tracker added. The previous note that 'most states will require provider documentation in 2027' was incomplete: the interim final rule makes self-attestation a state option for calendar year 2027 only, then limits it to once per enrollment period from January 1, 2028, with documentation required thereafter. Added the two-step 'significantly impairs' test, the bar on relying on diagnosis codes alone, the 12-month re-verification rule, and the 12-month adjudicated-claims lookback (91 Fed. Reg. 31698; 42 CFR 435.557(f)). New /timeline litigation section records the full docket for Massachusetts, et al. v. Oz: filed 2026-06-29 by 25 states plus DC; preliminary injunction denied 2026-08-05 (without prejudice, merits briefing continues); notice deadline 2026-08-31; federal deadline 2027-01-01; medical-frailty documentation transition 2028-01-01. Added Illinois as the 16th state profile: 3.4M enrollees, 770k+ ACA expansion adults, enforcement at first redetermination on or after 2027-01-01, six-month renewals, and HFS's official getmedicaidfacts.com hub. Added Illinois HFS and a court docket source to tracked sources.

• 2026-09-21published

  Weekly maintenance (2026-09-14 to 2026-09-21). Corrected the interim final rule citation across the data layer: the June 2026 IFR is CMS-2454-IFC, 91 Fed. Reg. 33348 (June 3, 2026), RIN 0938-AV98, corrected at 91 Fed. Reg. 39028 (June 29, 2026) — the previously cited 31698 was wrong. Added CMS's September 8, 2026 implementation guidance on the medical frailty exclusion (three-tier verification model: some diagnoses alone, others plus supplemental evidence, unresolved cases to individualized review; Louisiana cited as an example; state methodologies to be collected fall 2026), verified via State Health & Value Strategies. Added the mid-September 2026 70-organization amicus brief led by the National Health Law Program in support of the plaintiff states in Massachusetts, et al. v. Oz; no court order since the August 5 injunction denial. No in-window state-level changes across the 22 tracked states; Oklahoma member notices (2026-09-02) and Oregon OHA implementation outline (2026-09-09) fell before the window. Montana, Michigan (403), and Indiana (in.gov) could not be verified this week — manual confirmation items.

• 2026-09-28published

  Weekly maintenance (2026-09-21 to 2026-09-28). Added the second federal lawsuit over the work-requirement rule: Taylor et al. v. Kennedy Jr. et al. (D. Md., Case 1:26-cv-03705-GLR, Judge George Levi Russell III), filed 2026-09-18 by five Medicaid enrollees and medical organizations (National Health Law Program, Democracy Forward, Legal Aid of Western Missouri), challenging the IFR's medical-frailty provisions — the extra 'significantly impairs' step and the exclusion of people with SUD in stable recovery 5+ years. Updated litigation.json and the federal baseline litigation note; no court order in Massachusetts, et al. v. Oz since the August 5 denial. Added KFF's 2026-09-22 analysis of Sec. 71109 implementation: states must submit updated SPAs by December 31, 2026 (revised templates forthcoming), T-MSIS immigration-status reporting guidance is in progress, and state-funded coverage via managed care requires a separate contract/payment system. Immigrant eligibility (Oct 1, 2026) is three days out with no CMS final SPA template yet — flagged as a watch item, no state-level detail changes made. KFF's updated Waiver Tracker (2026-09-24) re-confirmed the early-SPA states (NE 2026-05-01, MT 2026-07-01, AR soft launch 2026-07-01, IA 2026-12-01) and that Georgia's waiver expires 2026-12-31 — all already reflected in state files; no in-window state-level changes across the 16 tracked states, all pending state-implementation fields remain pending. Accuracy spot-checks on src/lib/rules.ts all passed (138% x FPL / 12 for HH1/HH4/HH9, $580 = 80 x $7.25, arbitrageCalc hours-to-target, timeline rows for NE/GA/IA/TX). Not written to data (pre-window or unverified): the 2026-09-01 APTC prohibition for people terminated for work-requirement noncompliance (healthlaw.org) needs primary-source confirmation; Montana/Michigan/Indiana manual-confirmation items from last week remain open.

• 2026-09-30published

  OBBBA Section 71109 takes effect 2026-10-01. Ahead of the National Day holiday freeze, the immigrant eligibility hub (all 8 EN/ES category pages) switched from future-tense copy to effective-date framing ('effective October 1, 2026' / past tense) in both languages — framing only, no numbers or status scopes altered. One factual correction accompanied it: the EN TPS page FAQ had stated that refugees and asylees 'keep federal eligibility for their first 5-7 years', contradicting the site's position that both categories lost federal eligibility on October 1, 2026; the sentence now matches the other pages. lastVerified bumped to 2026-09-30 on the two immigrant data files.

Data layer last verified 2026-09-30. Substantive changes to any tracked rule are reflected in the shared dataset — and therefore in every calculator and state page — within 48 hours.