Timeline Of Effective Dates Of Health Care Provisions Of OBBBA Is Key To Understanding Impacts – Healthcare

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Over 35 health care provisions were included in the One Big Beautiful Bill Act of 2025. These provisions span Medicaid, the Children’s Health Insurance Program (CHIP), the Affordable Care Act (ACA) marketplaces, Medicare and commercial insurance

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Over 35 health care provisions were included in the One Big
Beautiful Bill Act of 2025. These provisions span Medicaid, the
Children’s Health Insurance Program (CHIP), the Affordable Care
Act (ACA) marketplaces, Medicare and commercial insurance. The
majority of provisions alter eligibility and spending for health
care coverage under Medicaid – and take effect over the next
three years. All health provisions of OBBBA will have notable
impacts on coverage and care delivery in the U.S. when they take
effect. The timeline of effective dates, presented in this Alert,
are essential to understanding the cost and coverage impacts.

To comply with the law, states will need to build and operate
numerous additional Medicaid and ACA eligibility checks and systems
by certain deadlines. Adults who live in states that have expanded
Medicaid coverage under the ACA will face narrowed eligibility for
Medicaid, and they may need to report monthly their hours of work
or community engagement to maintain Medicaid coverage when their
state implements this provision. Children of these adults could
retain Medicaid eligibility separately – and need to take
steps to remain enrolled. Providers will also be closely responding
to implementation of theOBBBA as health provisions will impact
funding, coverage for their patient populations and the amount of
uncompensated care delivered in their communities.

The following table shows the statute’s effective dates for
all health provisions. Dates are listed by federal program to show
the “waterfall” effect of implementation and expected
impacts of the OBBBA. The table can be printed
here.

Co-authored with Sophia Arnold (Intern)

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.