What Medicaid Changes Mean for Your Patients
The “One Big Beautiful Bill Act” was signed on July 4, 2025, and its Medicaid provisions are now rolling out on a tight timeline. The first major cutoff takes effect October 1, three weeks away. A second wave follows January 1, 2027. Statewide, up to 175,000 Marylanders are projected to lose coverage. At last week's MCMS Executive Board meeting, Dr. Kisha Davis, Montgomery County's Chief Health Officer and MCMS board member, walked through the local picture. Here is what she shared, and what it means for your practice.
October 1, 2026: Asylees and Refugees Lose Coverage
Starting October 1, H.R. 1 removes federal Medicaid funding for non-citizen residents without permanent immigration status. That includes refugees, asylees, and parolees, regardless of how long they have lived or worked in the United States.
Dr. Davis put the Montgomery County number at approximately 4,000 people. There is no pathway for them to re-enroll without a change in immigration status. At least 60,000 non-citizen residents statewide are in the same position. The County and state are working to assemble HSCRC funding to help cover the newly uninsured, and Montgomery CARES is being explored as a bridge option, but those conversations are still in progress.
One detail Dr. Davis emphasized: do not tell patients their coverage is already gone. It has not lapsed yet. Patients who hear that and skip appointments or stop filling prescriptions before October 1 will have coverage gaps that did not have to happen.
A related pattern is already showing up in Montgomery County. Dr. Davis noted that fewer people are coming to county clinics for vaccines, not because of hesitancy but because of immigration-related fear of engaging with public institutions. School enrollment is down for the same reason.That same dynamic will likely shape how the October 1 cutoff lands in practice: some patients will disengage from care before they have to.
Make sure your care team is not telling patients their coverage is already gone — it is not yet. For patients who will lose coverage October 1, Montgomery CARES clinics serve patients regardless of immigration status on a sliding-fee scale. Have that referral pathway ready before the end of the month.
January 1, 2027: Work Requirements and Faster Renewals
The second wave targets Maryland's ACA Medicaid expansion population, approximately 331,000 adults statewide who qualified under the Affordable Care Act. Beginning January 1, two new requirements apply to all of them.
First, eligibility must be verified every six months instead of annually. More frequent renewals mean more opportunities for patients to fall off coverage through missed notices, address changes, or delays in processing, even when they remain eligible.
Second, adults ages 19 to 64 must document at least 80 hours per month of qualifying activity: employment, education, job training, or volunteering. Maryland projects 56,000 adults will lose coverage because of the work requirements. A RAND analysis confirms that most of those losses will fall on people who are working but cannot document it, not people who are not working at all.
Dr. Davis noted that the state is working on auto-verification options, including checking employer tax records and allowing medical frailty self-attestation, to reduce the paperwork burden. Those processes are not finalized, so the operational picture in January is still taking shape.
For Montgomery County, the total projected coverage loss across both the October and January changes is estimated between 23,500 and 26,500 residents.
Patients with chronic conditions on ACA expansion Medicaid are at elevated risk of coverage gaps starting in January. Maryland Health Connection is the enrollment resource for patients who need help with renewals or appeals. A Medicaid toolkit will also be distributed through MCMS — Dr. Davis specifically encouraged physicians to post it in their offices and noted that specialists in particular may be the only physicians many of these patients see.
What This Means for Uncompensated Care
Maryland's projected $2.7 billion reduction in federal Medicaid funding will affect practices as well as patients. When patients lose coverage mid-treatment or delay care until they are sick enough to use the emergency department, the costs land somewhere. For hospital systems and practices that absorb uncompensated care, the October 1 cutoff is the more acute problem precisely because it arrives before most practices have had time to identify which patients are affected.
Consider whether your billing and front-desk staff know about the October 1 change. Patients presenting with Medicaid cards after that date may have coverage that is no longer federally matched, depending on their status. Your practice administrator is the right person to sort through the operational implications.
Maryland Vaccine Program: A Resource for Uninsured Patients
On a related note, Dr. Davis highlighted a resource that is worth having in your referral toolkit. The Maryland Vaccine Program provides state-funded vaccines for uninsured adults, including COVID, flu, measles, shingles, and pneumovax. Montgomery County received more than double last year's funding, approximately $130,000 this year. Community Clinic Inc. (CCI) is participating, with expansion to additional FQHCs planned.
For uninsured adult patients, including parents of pediatric patients, the Maryland Vaccine Program is a concrete resource. Dr. Davis encouraged referrals directly.
MCMS Is Monitoring
MCMS is tracking H.R. 1 implementation as it unfolds and will share updates as Maryland finalizes guidance on the January 2027 requirements. Questions or concerns? Reach us at info@montgomerymedicine.org.
