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Policy Synthesis

Healthcare Legislation · Payment Models · Research Datasets
Healthcare Reference Materials
Legislation & Regulatory Intelligence
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Data current as of: August 2026  |  Sources: CMS, CMMI, Federal Register, ResDAC, AHRQ HCUP

Healthcare Policy Ontology Graph

Two complementary force-directed graphs: the Legislative Map traces how legislation flows through federal agencies to CMS programs and payment rules; the Payer & Company Map shows how those mandates connect to health plans, providers, digital health companies, pharma, and analytics vendors. Click a node to highlight neighbors. Scroll to zoom, drag to pan. Use the legend to filter by category.

⚠ For the full state-by-state coverage, cost, and litigation picture under the 2025 reconciliation law (H.R.1 / "One Big Beautiful Bill Act"), see Special Topics: Access & Cost under OBBBA →

Reimbursement & Value-Based Care Roadmap

Eligibility-based swimlane showing which CMMI innovation models apply to each healthcare service type, organized by the 6 official CMMI categories. Each model row shows the program's active date range. Use this to identify potential payment model overlaps and sequencing for any provider type. Scroll vertically to see all service types. Hover a bar for model details.

Healthcare Research Dataset Catalog

Searchable, filterable catalog of 20 major healthcare research datasets spanning Medicare claims, Medicaid enrollment, provider files, national surveys, and synthetic data. Click a row to expand the full description. Click column headers to sort. Keyboard shortcut: press 3 to switch to this tab.

Coding System Distinctions

How the five core Medicare coding and payment classification systems relate to each other — what they do, where they apply, and how they interact in bundling and value-based care contexts.

Feature DRG
Diagnosis-Related Group
HCPCS
Healthcare Common Procedure Coding System
HCC
Hierarchical Condition Category
ICD
International Classification of Diseases
APC
Ambulatory Payment Classification
Primary use Inpatient hospital payment under IPPS. Billing codes for procedures, supplies, drugs, and services (FFS). Level I = CPT; Level II = non-physician supplies/drugs/etc. Risk adjustment to predict annual expected cost (premiums/capitation and quality models). Clinical classification of diagnoses (ICD-10-CM) and inpatient procedures (ICD-10-PCS). Hospital outpatient payment under OPPS.
Care setting Acute inpatient stays. All settings (professional, outpatient, ASC, DME, ambulance, etc.). Population-level risk for Medicare Advantage/ACA and some Medicaid models. All settings; foundational clinical coding on every claim/record. Hospital outpatient departments (HOPDs); some ED/clinic/ancillary.
Payment model Episode-based: one payment per stay, adjusted by DRG weight, wage index, etc. Fee-for-service: line-item payment per code (subject to edits, bundling). Risk-adjusted: additive risk score applied to premiums/benchmarks. Not a payment system by itself; feeds DRG, HCC, quality, epi studies. Prospective: APC weight × conversion factor; packaging & multiple-procedure rules under OPPS.
Basis of grouping Groups from ICD-10-CM/PCS diagnoses & procedures, age/sex/discharge status; CC/MCC tiers. CPT/HCPCS codes describing the specific service/supply/drug; units and modifiers refine payment. Mapped from ICD-10-CM diagnosis codes recorded over a look-back year; disease hierarchies. ICD-10-CM (diagnoses) and ICD-10-PCS (inpatient procedures) with clinical rules/edits. Groups CPT/HCPCS codes into clinical/resource bundles (status indicators determine packaging).
Scope Single inpatient episode. Individual services and supplies. Annual view of chronic disease burden per member. Complete clinical picture across encounters (conditions & procedures). An outpatient visit/encounter; multiple APCs may apply.
Additivity / interaction Hierarchical: one DRG per stay; CC/MCC levels modify payment (not additive). Generally not additive across bundled edits; each line evaluated (NCCI edits, modifiers). Additive with hierarchies: most unrelated HCCs add; within a disease family, higher-severity HCC suppresses lower. Multiple diagnoses/procedures can be listed; downstream systems (DRG/HCC) impose hierarchy. Mixed: some APCs pay separately; many ancillary items are packaged into a primary APC; multiples discounted.
Typical inputs Principal diagnosis, OR/non-OR procedures, comorbidities (CC/MCC), demographics, discharge status. Procedure code + units + modifiers; sometimes drug strength (J-codes), DME details. All qualifying chronic/severe diagnoses from claims/encounters in the model year. Provider documentation abstracted to ICD codes; POA, laterality, encounter type, etc. Outpatient CPT/HCPCS codes, status indicators, units; sometimes device edits, composite logic.
Governing body CMS (Medicare IPPS; MS-DRGs). CMS (HCPCS Level II) and AMA (CPT = HCPCS Level I). CMS (MA/ACA risk models; state variations for Medicaid). WHO (ICD), with U.S. maintenance by NCHS (ICD-10-CM) and CMS (ICD-10-PCS). CMS (OPPS/APC program).
DRG
  • Creation (claim/part): Assigned by grouper to institutional inpatient (UB-04/837I) claims — Type of Bill 11x, paid under Medicare Part A (IPPS). Medicaid IP claims in TAF also use UB-04 (state policies vary). Inputs: principal DX, procedures, CC/MCC, age/sex, discharge status.
  • Input to bundling/VBC: Payment unit for IPPS (Part A); anchors episodes in DRG-based cost measures and readmissions programs (HRRP); state Medicaid programs may use DRG-based IP payment.
  • Used with other data: Wage index, case-mix, outlier thresholds, discharge/transfer status, transfer rules.
HCPCS (CPT Level I / Level II)
  • Creation (claim/part): Reported on professional (CMS-1500/837P) and hospital outpatient (UB-04/837I, TOB 13x) claims in Medicare Part B; also used in MA (C) encounters and Medicaid (TAF). Level I maintained by AMA (CPT); Level II by CMS.
  • Input to bundling/VBC: Drives OPPS/APC grouping (Part B), MPFS pricing (B), and episode/cost measures in value-based programs; similar logic in MA/Medicaid payment edits.
  • Used with other data: Status indicators (OPPS B), units, modifiers (25/59/JW/JZ), revenue codes, NDC for drugs (especially Part D contexts).
HCC — CMS Risk Adjustment
  • Creation (claim/part): Derived annually from ICD-10-CM diagnoses on institutional (UB-04/837I: A/B) and professional (1500/837P: B) claims across settings; computes RAF for Medicare Advantage (Part C); some Medicaid programs adopt HCC-like risk models.
  • Input to bundling/VBC: Adjusts MA (C) capitation and ACO benchmarks; used for risk stratification and performance attribution.
  • Used with other data: Demographics (age/sex/dual/disability), model interactions, encounter completeness rules to produce final RAF.
APC
  • Creation (claim/part): Assigned to hospital outpatient (UB-04/837I) claims — TOB 13x, paid under Medicare Part B (OPPS). State Medicaid programs may use OPPS-like rules. Built from CPT/HCPCS + status indicators (includes packaging and C-APC logic).
  • Input to bundling/VBC: Payment unit for OPPS (B); packaging creates de facto ambulatory bundles; used in outpatient episode/cost measures in VBP contexts.
  • Used with other data: OPPS conversion factor, wage index, multiple-procedure discounting, device/drug pass-through status, required modifiers.
Claim Forms & Type of Bill Codes
UB-04 / Form CMS-1450 → 837I Institutional claim form/transaction. Used for Medicare A/B facility billing to MACs and by many Medicaid State Agencies for institutional claims. Setting indicator: Type of Bill (TOB).
CMS-1500 → 837P Professional (non-institutional) claim form/transaction. Used for Medicare Part B physician/supplier claims and Medicaid professional billing. Stewarded by NUCC. Setting indicator: Place of Service (POS).
TOB 11x Hospital Inpatient (e.g., 111 = admit-through-discharge). Claims paid under Medicare Part A — IPPS, DRG-based payment. Medicaid institutional IP claims in TAF also carry TOB.
TOB 13x Hospital Outpatient (e.g., 131 = outpatient claim). Claims paid under Medicare Part B — OPPS; APC-based payment applies.
Place of Service (POS) 2-digit code on professional claims (CMS-1500/837P) identifying the care setting. Required for Medicare Part B; widely used by Medicaid and other payers.

Important Variables & Cross-Program Linkage

Core data elements that recur across Medicare and Medicaid research files, with notes on which Medicare Part or program each variable belongs to and how to use it for linkage, cost, utilization, and disease burden analysis.

Function Medicare FFS (A/B) MA Encounters (C) Professional (B) Part D (D) Medicaid (TAF)
Beneficiary key BENE_ID BENE_ID BENE_ID BENE_ID BENE_ID (in CCW-linked TAF)
Claim window CLM_FROM_DT / CLM_THRU_DT same names same names fill date / PDE date vars service dates in TAF
Diagnoses ICD-10-CM (principal/secondary) same fewer DX fields n/a (drug) ICD-10-CM
Procedures ICD-10-PCS (IP A) + HCPCS/CPT (OP B) HCPCS/CPT HCPCS/CPT NDC ICD-10-PCS/HCPCS/CPT parallels
Site / setting TOB (11x, 13x) on UB-04/837I encounter type mirrors POS on 1500/837P plan & pharmacy context UB-04/TOB & professional POS
Payment amounts CLM_PMT_AMT + REV_CNTR lines encounter pricing fields (when populated) allowed/paid at line/claim gross drug cost, plan paid, patient pay TAF paid/allowed fields by claim type

Note: BENE_ID is the CCW link key across Medicare and certain Medicaid data (when available via CCW) — not a general-purpose ID outside the CCW environment.

Elements by Analytic Domain
Cost (payment/pricing)
  • Institutional (UB-04/837I): claim-level CLM_PMT_AMT; sum of revenue-center payment/charge lines in Medicare A (IP) and B (OP). Medicaid TAF has analogous paid/allowed fields.
  • Professional (CMS-1500/837P): allowed/paid amounts under Medicare Part B (Carrier/DME), line-level and claim-level rollups; similar constructs in Medicaid TAF non-institutional.
  • Pharmacy (Part D PDE): gross drug cost, plan paid, patient pay, LIS, TrOOP contributors under Medicare Part D; Medicaid pharmacy has parallel elements in TAF.
  • Plan context: Part C/D plan characteristics (premiums/service area) for benchmarking; state/plan constructs in Medicaid.
Utilization (counts/intensity)
  • Units: HCPCS lines, revenue-center units (OP), E/M visits, admissions/stays (IP/SNF via MedPAR roll-ups under Medicare A), days supply (PDE Part D).
  • Dates: CLM_FROM/THRU, ADMSN/DSCHRG for LOS, readmissions, episode triggers — primarily Medicare A/B/C; fill date for D; analogous in Medicaid TAF.
  • Setting indicators: TOB 11x (IP/Part A), 13x (OP/Part B) for site-of-service splits; POS for B/C professional/encounter claims; Medicaid uses TOB/POS analogs in TAF.
Disease Burden (clinical severity/risk)
  • Diagnoses: ICD-10-CM across A/B/C (and Medicaid TAF) feed HCC risk models used for MA (C) and sometimes Medicaid.
  • Procedures: add clinical complexity — ICD-10-PCS in IP Part A, HCPCS/CPT in B/C.
  • Part D (D): contributes medication exposure and adherence metrics for chronic disease burden analysis.
Mini-Glossary
BENE_ID Encrypted CCW Beneficiary ID. Stable, linkable key across CCW files for Medicare FFS (A/B), MA encounters (C), Part D (D), and CCW-linked Medicaid (TAF). Use: link claims/encounters/PDEs to enrollment and each other; build denominators.
CLM_ID Claim header identifier. Revenue-center/line segments appear beneath the header. Exists in Medicare FFS (A/B), MA encounters (C), and analogous constructs in Medicaid TAF (institutional/professional).
CLM_FROM_DT / CLM_THRU_DT "Statement covers from/thru" dates. Present in Medicare FFS (A/B) and MA encounters (C). Part D uses fill date variables; TAF carries service dates for Medicaid.
CLM_PMT_AMT Claim-level Medicare payment amount on institutional (UB-04/837I) claims. Paired with revenue-center line amounts for granular cost analysis.
MedPAR Medicare Part A stay-level roll-up from inpatient hospital and SNF claims. Convenient for admissions/LOS analytics; not line-level.
RAF (Risk Adjustment Factor) The numeric risk score produced by the HCC model. Combines HCC scores and demographic factors (age/sex/dual/disability). Applied to MA capitation benchmarks and ACO financial benchmarks.
NDC (National Drug Code) 11-digit drug identifier on Part D Prescription Drug Events (PDEs) and Medicaid pharmacy claims. Identifies the specific drug, strength, and package size.
TAF (T-MSIS Analytic Files) Research-optimized Medicaid claims/encounters (institutional and non-institutional), eligibility, and provider files derived from T-MSIS. Access via ResDAC/CMS.
NPI (National Provider Identifier) 10-digit identifier for individual providers and organizations. Present in Medicare A/B/C/D contexts; Medicaid TAF has parallel provider keys. Use to link claims to POS file, HCRIS, and MIPS performance data.
Quick Starter List — Variables to Pull First
Linkage & scope
  • BENE_ID — A/B/C/D/TAF
  • CLM_ID — A/B/C/TAF
  • CLM_FROM_DT, CLM_THRU_DT — A/B/C/TAF
  • CLM_ADMSN_DT — IP Part A, some TAF
Clinical
  • Principal/secondary ICD-10-CM — A/B/C/TAF
  • ICD-10-PCS — A inpatient, some TAF
  • HCPCS/CPT — B/C/TAF
  • NDC — D, Medicaid pharmacy
Payment
  • CLM_PMT_AMT, REV_CNTR amounts — A/B
  • Carrier/DME allowed/paid — B
  • PDE gross/plan/patient pay — D
  • TAF paid/allowed fields — Medicaid
Context
  • TOB (11x = Part A, 13x = Part B) — A/B
  • POS — B/C/TAF
  • Provider NPI — A/B/C/D/TAF
  • Plan IDs — C/D; Medicaid plan IDs in TAF

Commonly Conflated Concepts

Payment Models & Episodes
Conflated pair What each one actually is Distinctions
Episode window: TEAM vs BPCI-A / CJR TEAM uses a 30-day post-discharge window. BPCI Advanced and CJR use 90 days. All three share the same shape — a triggering hospitalization followed by an accountability period — so the window reads as a property of bundled payment generally. It is set per model, and TEAM's is the shortest of the three.
HHVBP: original model vs expanded program The CMMI model ran in 9 states and ended 2021-12-31. The expanded HHVBP is a separate nationwide program, permanent from 2023. Same name, same acronym, and the nationwide start falls just after the model's end — so the two read as one continuous program. One is a time-limited demonstration in 9 states; the other is permanent nationwide policy.
ACO REACH's predecessor REACH replaced Global and Professional Direct Contracting (GPDC). MSSP ran in parallel throughout and still exists. MSSP and GPDC were both accountable-care programs running at the same time, which makes either a plausible ancestor. REACH's lineage runs through the Direct Contracting family only; MSSP is a parallel track, not a predecessor.
DSH adjustment percentage vs Medicaid inpatient day share The 11.75% figure is the DSH adjustment percentage — a payment output of the formula. Medicaid inpatient days are an input to it. Both are percentages attached to the same hospital, and Medicaid volume is what drives the formula — so the output reads as though it were the volume measure. One is a payment adjustment; the other is patient days.
Metropolitan area vs CBSA TEAM's 188 geographies are Core-Based Statistical Areas, which include micropolitan as well as metropolitan areas. Most CBSAs are metropolitan and CBSA counts are usually reported in metropolitan contexts, so the term reads as a technical synonym. The set is strictly larger — micropolitan areas are CBSAs and are not metropolitan.
Policy, Coverage & Statute
Conflated pair What each one actually is Distinctions
OBBBA §71109 vs §71301 / §71302 §71109 narrows Medicaid eligibility (effective Oct 1, 2026). §71301/§71302 narrow marketplace premium tax credit eligibility. Both sit in the same statute, both restrict eligibility for overlapping immigrant populations, and both land in the same window — so they read as one provision. They act on different programs, reach different groups, and take effect on different dates.
Rule finalized vs rule in force The RADV extrapolation rule was finalized in January 2023. It was vacated by the Northern District of Texas on September 25, 2025; appeal pending. A finalized rule is normally an enforceable one, so the two states are ordinarily the same thing. Vacatur separates them: the rule exists in final form and cannot currently be applied.
Current Medicaid enrollment vs unwinding-era peak Roughly 73.5M as of May 2026. The widely-quoted ~94M is the continuous-enrollment peak, before the 2023–24 unwinding. Both are recent national Medicaid totals, and the peak is the more frequently circulated of the two. They describe different periods, on either side of the unwinding — roughly a 20M difference in any denominator built from them.
Georgia Pathways vs full-expansion population ~240,000–250,000 is the Pathways-specific estimate. ~447,000–536,000 is the full-expansion eligible population. Both answer "how many Georgians could gain coverage," and Pathways is the state's actual vehicle — so its population reads as the state's whole coverage gap. One counts people eligible under Pathways' conditions; the other counts everyone a full expansion would reach.
Waiver-dependent vs regulation-authorized Community Supports Under CalAIM, 12 of 14 Community Supports are authorized by 42 CFR §438.3(e)(2), independent of the waiver. Only 2 depend on it. All 14 are administered as one benefit under one program, so the set reads as sharing one legal basis. Authority splits between federal managed-care regulation and the waiver, and that split is what determines which services survive a non-renewal.
Draft vs final guidance FDA's PCCP draft guidance issued April 2023; the final guidance issued December 3, 2024. Both are FDA guidance documents with the same title and largely overlapping content, and drafts circulate widely enough to be cited as operative. Only the final document carries the date that governs submissions.
Partnership announced vs guidance issued Joint Commission and CHAI announced their partnership in June 2025; their first joint guidance followed September 17, 2025. Both events belong to one collaboration, fall within a single quarter, and coverage of the second usually recaps the first. One is an agreement to work together; the other is a published document organizations can act on.
QHIN designation vs CMS-Aligned Network pledge TEFCA QHIN designation is a formal ONC/ASTP status. The CMS-Aligned Network pledge is a separate voluntary commitment. Both are national interoperability credentials, both signal a commitment to data exchange, and many of the same organizations hold both. Neither implies the other — an organization can hold either, both, or neither, which is why they are tracked here as independent fields.
Data & Method
Conflated pair What each one actually is Distinctions
ICD-10-CM vs ICD-10-PCS CM codes diagnoses in every setting. PCS codes procedures on inpatient claims only. They share the ICD-10 name and sit side by side on the same inpatient claim, so "ICD-10" reads as one code set. CM spans every setting; PCS appears only on inpatient claims, while institutional outpatient (13x) carries HCPCS like professional claims.
MBI vs HICN The MBI replaced the HICN in 2018. Files spanning the transition may carry either. Both are the Medicare beneficiary identifier of their era and fill the same slot in a linkage plan. Which one is present is a property of the file's vintage, not a choice the analyst makes.
Wilson vs Clopper-Pearson interval For 2 of 5, Wilson gives roughly 12%–77%; Clopper-Pearson is wider, near 7%–85%. Both are standard binomial confidence intervals for the same proportion, and output often labels either one simply "binomial" or "exact." At small denominators they differ materially, so the method and the bounds have to be reported together.
Estimating propensity scores vs matching on them scikit-learn estimates the scores. econml does doubly-robust and heterogeneous-effect estimation. Neither performs the matching step. They are consecutive steps in a workflow usually named as a single procedure — "propensity score matching" — and the estimation library is the one most write-ups mention. Matching is a separate step requiring its own implementation.
HCC V28 vs V24 V28 moves from 86 to 115 categories, removes about 2,294 codes, and adds constraining. 2026 is the first 100% V28 year. Both are CMS HCC models scoring the same conditions for the same purpose, and the transition years blended the two, which makes them look interchangeable. The differences are structural, so a RAF is only comparable within one version.
IRF payment: CMG vs DRG Inpatient rehabilitation facilities are paid by Case-Mix Group via HIPPS codes. Acute inpatient hospitals are paid by MS-DRG. Both group an inpatient stay into a payment category from diagnosis and clinical detail, and an IRF is an inpatient facility — so acute-care logic reads as applying. They are different prospective payment systems with different groupers.

Analytical Stacks

Reference map of 14 analysis types — tech stack, statistical method, data volume, entity grain, healthcare use cases, and common mistakes. Click a card to expand. Filter by build status. Keyboard shortcut: press 4 to switch to this tab.

Special Topics: Access & Cost under OBBBA

A standalone deep-dive on the One Big Beautiful Bill Act (H.R. 1 / P.L. 119-21, signed July 4, 2025) and its 2026+ coverage and cost implications — national provisions, five state impact categories, individual mandate variation, a state-by-state drill-down, and a topic-organized reading guide. Static reference content, edited in place like the Data Taxonomy reference sections. Keyboard shortcut: press 5 to switch to this tab.

Table of Contents

  1. Introduction & National Context: OBBBA's Core Provisions
  2. Categories of Impact: Five State Response Patterns
  3. Individual Mandate Variation: State Penalty Rules for 2026
  4. Disproportionately Affected Populations
  5. The 2026–2030 Landscape: Coverage Loss Amid Accelerating Cost Growth
  6. State Drill-Down: California, Montana, Georgia — plus any-state lookup
    1. Any-State Drill-Down (all 50 states + DC)
    2. The Bay Area as Bellwether
  7. Works Cited by Topic: A Reading Guide
  8. Static/Dynamic Refresh Protocol
  9. Limitations & Caveats

Throughline across every section below: OBBBA's federal savings are consistently smaller than the state, county, and provider costs it shifts downstream — and no reconciliation event (a follow-on bill, a court injunction that sticks, or a funding backstop) has yet closed that gap.

How estimates are handled on this page. Where a range exists, this page leads with the most conservative credible figure — normally the issuing agency's own central estimate — and names the higher-end scenario separately rather than blending the two or headlining the larger number. Where no state- or organization-specific figure is traceable to a named source, the page says so plainly instead of extrapolating one from a national average. Every headline figure carries the source it came from; if a number here has no attribution, treat it as unverified.

National Context: OBBBA's Core Provisions

P.L. 119-21 (H.R. 1) is a budget reconciliation law, not healthcare-specific legislation — its healthcare provisions are four of many titles. Two of the biggest compounding factors in 2026 (the expired enhanced ACA premium tax credits and the broader MA risk-adjustment/RADV litigation) are not OBBBA provisions; they are separate, coincidentally-timed policy events. This section covers OBBBA's actual text first, then flags what compounds it.

Medicaid Work Requirements
  • What it requires: 80 hrs/month of work, work/education program, or community service (or a $580+/month income equivalent in some state implementations) as a condition of Medicaid eligibility for the ACA expansion population, ages 19-64.
  • Effective: By January 1, 2027 nationally, across the 40 expansion states + DC. CMS published the implementing interim final rule (CMS-2454-IFC, "Community Engagement Requirement for Certain Individuals") June 1, 2026. Self-declaration of exemptions is permitted for 2027; supporting documentation is required starting 2028. Applicable enrollees move to 6-month (from annual) redeterminations.
  • Early movers: Nebraska, Montana, Iowa, and Arkansas are enforcing ahead of the federal deadline on their own state timelines — CMS's own interim final rule names all four (detail in Categories of Impact, below).
  • CBO estimate: ~10M combined coverage loss by 2034 across OBBBA's Medicaid and marketplace provisions — see Affected Populations for sourcing caveats.
Immigrant Eligibility Changes
  • §71109 — narrows Medicaid eligibility for lawfully present immigrants: The Medicaid-side companion to §71301/§71302 below — effective October 1, 2026, it restricts federal Medicaid reimbursement to citizens, lawful permanent residents, Cuban/Haitian entrants and COFA migrants — ending federal eligibility for refugees, asylees, parolees and trafficking victims. UC Berkeley Labor Center attributes ~200,000 Californians losing federally-funded full-scope Medi-Cal specifically to the refugee and asylee categories. This is the provision that drives FQHC/safety-net revenue exposure for immigrant-heavy caseloads, distinct from the marketplace-subsidy provisions below.
  • §71302 — five-year rule (marketplace, not Medicaid): Eliminates ACA premium tax credit (PTC) eligibility for lawfully present immigrants below 100% FPL who are ineligible for Medicaid because of immigration status (including those in their first 5 years in the U.S.). Effective for tax years after December 31, 2025 — already in effect. Affects Covered California marketplace subsidies, not Medi-Cal.
  • §71301 — narrowed "eligible alien" definition (marketplace, not Medicaid): Restricts PTC-eligible immigration categories to lawful permanent residents, Cuban/Haitian entrants, and COFA migrants. Refugees, asylees, and Temporary Protected Status holders lose PTC eligibility entirely. Effective January 1, 2027.
Premium Tax Credit Repayment Caps Eliminated
  • §71305: Repeals the repayment caps in §36B(f)(2)(B) that, through 2025, limited how much excess advance PTC a household under 400% FPL had to repay if their actual income came in higher than estimated (caps varied by income tier and filing status, from $375 up to $1,625 single / $3,250 other filers at the highest tier below 400% FPL).
  • Effective: Tax year 2026 onward. Any marketplace enrollee whose actual income exceeds their estimate — for any reason, at any income level — now owes back the full excess credit, dollar for dollar. This is the "uncapped clawback" risk referenced throughout this tab.
Provider Tax / SDP Caps & Rural Health Transformation Fund
  • Provider tax freeze, then phase-down: A nationwide freeze effective October 1, 2026 locks all states' provider-tax rates at their July 4, 2025 levels; from FFY2028 (Oct 2027) the allowable ceiling then phases down from 6% to 3.5% in expansion states specifically, through 2032.
  • State-directed payment (SDP) caps: Limits SDPs to 100% of Medicare rates in expansion states, 110% in non-expansion states, phasing down starting January 1, 2028 — reducing a major supplemental-financing lever hospitals and states have used since 2021. Note the revenue-impact window for SDPs runs mainly 2028-2032, not 2026-2028 — later than the provider-tax freeze/phase-down above. Nursing facilities and ICF/IDD provider taxes are exempt from the 6%-to-3.5% phase-down and keep the 6% safe harbor.
  • Rural Health Transformation Fund: $50B, distributed FY2026-2030 via CMS-approved state transformation blueprints. Widely expected by rural-health analysts (National Rural Health Association, hospital associations) not to fully offset the combined revenue loss from coverage attrition and the provider-tax/SDP caps above.

What compounds OBBBA (not part of the law itself): The IRA-era enhanced ACA premium tax credits expired December 31, 2025 without congressional renewal — subsidized marketplace enrollees' average annual premium roughly doubled, from $888 to $1,904, and the "subsidy cliff" at 400% FPL returned for everyone. Separately, MA risk-adjustment (HCC V28) and RADV litigation is compressing plan margins for reasons unrelated to OBBBA (see Top Shifts, Ontology tab). Both land in the same 2026-2027 window as OBBBA's provisions and are treated as compounding catalysts throughout this tab, not attributed to OBBBA itself.

Categories of Impact: Five State Response Patterns

States are not implementing OBBBA uniformly. Grouping by exposure type — rather than by region or party — is more predictive of operational outcome. Evidence grade follows each row's sourcing quality: confirmed (official agency data or GAO/auditor report), modeled (advocacy/research-org projection), insufficient (qualitative reporting only, no verified figure as of this pass).

CategoryStatesExposure TypeAction PlanProjected Coverage LossCost ImpactEvidence
Early Adopters NE, MT, IA, AR Rapid, state-initiated timeline ahead of the Jan 2027 federal deadline Mass beneficiary notification campaigns; state-run online resource hubs NE: ~200 in the first disenrollment round (July 31, 2026) — the state Medicaid director's own figure, used here as the headline; advocacy groups separately project 20,000-40,000 eventually, which this page does not adopt as the expected outcome. MT: ~13,000 adults (~18% of expansion population) by the 2027 enforcement completion. IA: enforcement begins Dec 1, 2026; ~32,000 estimated coverage loss (analyst projection). AR: began July 1, 2026, with enforcement delayed until January 2027 (per CMS's own IFR, which names all four states as early movers) — a non-enforcement grace period matching Montana's. Rural hospitals, FQHCs absorb uncompensated care first Confirmed (NE, MT, AR) / Modeled (IA)
Waiver-Only / Non-Expansion GA (verified); TN, WI (cited in prior tracking, not independently re-verified this pass) Non-expansion states running (or considering) standalone work-requirement waivers Vendor-heavy eligibility-system spending over direct care GA: ~7,400-9,175 enrolled vs. a Pathways-eligible population commonly cited at ~240,000-250,000 (missed its own ~25,000 first-year target, per GAO) GA: $54.2M administrative vs. $26.1M care spending since 2021 (GAO, Sept 2025) Confirmed (GA) / Modeled (TN, WI)
Expansion+Waiver Intersection HI, MA, NY, OR, UT Dual-track compliance — existing state waiver terms plus the new federal work requirement State call centers; dual-eligibility-system rebuilds Qualitative reports of administrative strain and call-center wait times; no state-specific figure independently verified in this pass Public hospitals in expansion states with high dual-eligible share Insufficient
Administratively Overwhelmed ND Capacity failure — eligibility-system backlog builds before work-requirement enforcement even begins "Good faith"/self-declaration workarounds; emergency eligibility-office staffing (Missouri improved after a staffing increase) ND: pending-renewal share rose from 11.2% (Q4 2025) to 24.8% (Q1 2026, its highest on record); 69.3% of applicants waited >30 days. ND HHS estimates only 5,000-7,000 of ~23,000 expansion members will actually be affected once its own work-requirement deadline (Jan 1, 2027) arrives — nearly half pre-qualify for exemption. Nationally: median share of pending Medicaid renewals rose from 4.3% (Q2 2025) to 7.0% (Q1 2026); share of new applications taking >30 days to process rose to 21.9% in Q1 2026. State budgets absorb overtime/temp staffing first, then rural providers absorb the access impact Confirmed
Litigants 25 states + DC (23 states via AG + 2 via governor: KY, PA), incl. MA (lead), CA, NY, OR Compliance-under-protest — must implement while suing Multi-state coalition litigation: Commonwealth of Massachusetts et al. v. Oz (filed June 2026; MA is the named lead plaintiff, CA a co-plaintiff) challenges the interim final rule's narrowed "medically frail" exemption; a separate 21-AG + 1-governor coalition (filed N.D. Cal.) challenges the 2027 Notice of Benefit and Payment Parameters' expanded catastrophic-plan eligibility (HHS's own estimate: 2M lose coverage in 2027, 5M by 2030) A federal judge denied the preliminary injunction in Massachusetts v. Oz on July 29, 2026 — the rule stays in effect nationwide while litigation continues (a motion to reconsider was filed Aug 26, 2026; outcome not yet resolved as of this pass) — deferred, not avoided Same downstream cost pattern as the state's underlying category (e.g., CA is also Expansion+Litigant) Confirmed

Texas was removed from the Administratively Overwhelmed category above: Texas never adopted ACA Medicaid expansion, so it has no expansion population subject to the work requirement, and its confirmed application backlog (~1,600 → 210,000+ applications, Jan-Aug 2026; on-time processing fell from >90% to 62%) is attributed by advocates primarily to new SNAP accuracy requirements and the shift to 6-month redeterminations, not work-requirement enforcement. It's still a real and useful finding — cross-program eligibility-system strain (SNAP verification changes compounding with Medicaid redetermination cycles) is straining state capacity in both non-expansion states like Texas and expansion states like North Dakota, independent of whether work requirements are the direct cause.

Individual Mandate Variation: State Penalty Rules for 2026

The federal individual mandate penalty was zeroed out by the 2017 Tax Cuts and Jobs Act; five jurisdictions have since enacted their own. As the federal enhanced-subsidy expiration raises marketplace premiums nationally, these state penalties interact directly with affordability in the states that have them — going uninsured now carries both a higher unsubsidized premium risk and, in five places, a direct tax penalty.

State Mandate Type2026 PenaltyStates
Income + flat-fee floorGreater of 2.5% of income or a per-adult/per-child flat fee: CA ~$950/adult, ~$475/child, max ~$2,850; NJ ~$695/adult + 2.5% income, capped at the statewide average Bronze-plan premium; RI $695/adult (~$57.92/mo), $347.50/child, flat-dollar cap $2,085, also capped at Bronze-plan cost; DC is higher — $795/adult, $397.50/child, $2,385 family cap (DC's 2026 figure was not yet published as of this pass; the 2025 amount is shown)CA, NJ, RI, DC
Income/age sliding scaleIncome-tiered by multiple brackets (% of FPL) rather than one flat maximum; sources conflict on the top-tier figure — one aggregator cites ~$135/mo (~$1,620/yr), this project has also used ~$182/mo (~$2,184/yr). Not independently confirmed against MA's own TIR 26-1 guidance in this pass — verify directly with Mass.gov before citing a specific number.MA
Reporting onlyNo financial penalty — coverage status reporting requiredVT
No mandateNo penalty, no reporting requirementRemaining ~44 states

Note: the flat-fee amounts above are 2026 figures (DC's is 2025, pending 2026 publication) and differ meaningfully by state within the "income + flat fee" category — DC's floor runs roughly $100/adult higher than NJ/RI's; CA's is highest of the four. Treat the bracket as directionally consistent, not identical, across jurisdictions.

Disproportionately Affected Populations

Medicaid / Marketplace Coverage Loss
  • CBO's cumulative scoring across OBBBA's Medicaid and marketplace provisions estimates roughly 10 million more people uninsured by 2034. Component estimates vary by provision and by which CBO score vintage is cited — treat 10M as an order-of-magnitude anchor, not a precise figure, and check for updated CBO scoring each refresh cycle.
Subsidy Clawback Exposure
  • OBBBA §71305 eliminated repayment caps starting tax year 2026 (see National Context). Anyone whose actual income exceeds their marketplace estimate — a raise, a spouse's new job, a good freelance year — now owes back the full advance premium tax credit with no cap, at any income level. This is a new, uncapped downside risk distinct from the separate 400% FPL subsidy-cliff issue.
ESRD & Disability Dual-Eligibles
  • CMS's dual-enrollment data brief shows disability-based Medicare eligibility present in roughly 38-43% of dual-eligible (Medicare-Medicaid) beneficiaries (2006-2015 series). A second independent verification pass could not locate a directly comparable, CMS-sourced Medicare-only-beneficiary figure to compute a disparity ratio — treat any specific multiplier (this project has used both "2x" and "4.7x" in different drafts) as unverified until a single CMS source with both figures is located. What is confirmed: dual-eligibles carry a materially higher disability-based eligibility share and are simultaneously exposed to Medicaid work-requirement and eligibility churn on the Medicaid side of their coverage.
Immigrant Eligibility Narrowing
  • Lawfully present immigrants under 100% FPL in their first 5 years in the U.S. lose PTC eligibility for tax years after 2025 (already in effect). Refugees, asylees, and TPS holders lose PTC-eligible "alien" status entirely starting Jan 1, 2027 — a population previously treated as marketplace-eligible under ACA rules since 2014.

The 2026–2030 Landscape: Coverage Loss Amid Accelerating Cost Growth

OBBBA is not an isolated event — it compounds an existing cost trend. PwC's 2027 medical cost trend survey (published June 11, 2026) puts Group at 9% and Individual at 8.5% — the highest commercial trend in 17 years, independent of anything in OBBBA. Aon's "9.5%" figure needs a year caveat: this project has two differently-dated Aon sources — one from Sept 2025 headlined "9.5% in 2026" and one from Aug 2026 headlined "9.5% in 2027" — and could not resolve in this pass whether that's a genuine coincidence across two separate annual reports or a citation mix-up; verify against Aon's original report before citing a specific year. Mercer's 8.2% and WTW's 11.1% figures circulate widely for this period but were not independently re-verified against each firm's own published report in this pass; cite with that caveat. The chart below plots each catalyst on two axes — its effect on access (horizontal) against its effect on cost (vertical) — while marker shape and colour preserve the catalyst's root: an OBBBA provision, another federal law or policy, a market/structural force, a state action, or litigation. Reading those two dimensions together is the point: it shows not just how much pressure exists but where it originates, and therefore which lever could relieve it.

Each catalyst is placed by its access effect (horizontal) against its cost effect (vertical); marker shape and colour carry its root. Hover any marker for the full detail.

Access lost, cost up Access gained, cost up Access lost, cost down Access gained, cost down Access impact  ←  loss   |   gain  → Cost impact  ←  down  |  up  → 2027 medical cost trend — PwC's confirmed figure is 9% (Group) / 8.5% (Individual), the highest commercial trend in 17 years, with GLP-1s and specialty drug utilization the major drivers. Pure cost pressure, largely independent of access. GLP-1 & specialty drug trend OBBBA Medicaid work requirements — 80 hrs/month for the ACA expansion population, effective by January 1, 2027 nationally across 40 expansion states + DC. The single largest access-loss catalyst on this chart. Work requirements Provider-tax freeze (Oct 1, 2026) and phase-down from 6% to 3.5% in expansion states (FFY2028-2032); state-directed payment caps phase down from January 1, 2028. Nursing facilities and ICF/IDD are exempt from the phase-down. Provider tax & SDP caps Enhanced ACA premium tax credits expired December 31, 2025 without congressional renewal. NOT an OBBBA provision — an IRA-era credit lapsing on its own schedule, which happens to compound OBBBA's effects in the same window. Enhanced PTC expiration MA risk adjustment (HCC V28) plus RADV litigation. Separate from OBBBA: RADV extrapolation authority was vacated by the N.D. Texas in September 2025 and is on appeal at the Fifth Circuit. MA risk adjustment / RADV Uncompensated care cost-shift onto safety-net hospitals and FQHCs. California's LAO projects statewide hospital uncompensated care rising from roughly $2B (2024) toward $4B by 2030, attributing about 90% of the increase to H.R. 1. Uncompensated care shift OBBBA immigrant eligibility narrowing — §71109 narrows Medicaid eligibility for lawfully present immigrants (the FQHC-revenue driver); §71301/§71302 narrow marketplace premium tax credit eligibility. Immigrant eligibility cuts Employer coverage erosion as premium growth outpaces wage growth — a structural trend independent of OBBBA that compounds its coverage effects. Employer coverage erosion State eligibility-system administrative strain — documented in Texas (~1,600 to 210,000+ pending applications, Jan-Aug 2026) and North Dakota (pending-renewal share 11.2% to 24.8%, Q4 2025 to Q1 2026). Admin capacity strain Vendor-heavy work-requirement administrative spend. Georgia precedent: GAO found $54.2M administrative vs. $26.1M care spending (2021-June 2025) — though that ratio is front-loaded, falling from 96.5% of spend in FY2023 to 58.8% in FY2024. Vendor / admin spend Applicable enrollees move from annual to 6-month redeterminations. Lands on the full applicable population regardless of how the work test itself performs — an administrative access risk more than a policy one. 6-month redeterminations OBBBA §71305 repeals the PTC repayment caps from tax year 2026 — any marketplace enrollee whose actual income exceeds their estimate repays the full excess credit, uncapped, at any income level. A household cost risk that also deters enrollment. Uncapped PTC clawback Commonwealth of Massachusetts et al. v. Oz — 25 states + DC challenging the interim final rule's narrowed "medically frail" exemption. A federal judge denied the preliminary injunction July 29, 2026, so the rule stays in effect; access upside is contingent and unresolved. Litigation (Mass. v. Oz) State individual mandate variation — 5 jurisdictions (CA, NJ, RI, DC, MA) impose a penalty, VT requires reporting only, and the remaining ~44 states have no mandate at all. A modest access support where it exists. State mandate variation Rural Health Transformation Fund — $50B distributed FY2026-2030 via CMS-approved state blueprints. An OBBBA provision working in the opposite direction to the rest: a partial offset, though rural-health analysts widely expect it not to fully cover the losses. Rural Health Transformation Fund Medicaid value-based care and housing-health integration (CalAIM Community Supports and equivalents) — state-led programs pushing access up and total cost down, though several depend on 1115 waiver authority that expires December 31, 2026 in California. Medicaid VBC & housing-health integration IRA Medicare drug price negotiation — Cycle 1 prices took effect January 2026 with 38-79% discounts. A separate law pushing access up and cost down, included to show the full catalyst field rather than only the downside ones. IRA drug price negotiation
OBBBA provision Other federal law / policy Market / structural State action Litigation

Positions are qualitative judgements about direction and rough magnitude, not measured coordinates — the chart is a way to see which catalysts pull against each other, not a quantitative model. Note that the two quadrants doing most of the work are opposite corners: nearly everything OBBBA does directly sits in access lost, cost up, while the offsets that might pull the other way (its own Rural Health Fund, state value-based-care programs, IRA drug pricing) are fewer, smaller, and in several cases depend on authority that expires or is still in litigation.

Fills a gap in the existing Top Shifts cascade (Ontology tab): MA risk-adjustment litigation and the Rural Health Transformation Fund were previously untracked in this project's OBBBA-adjacent content; both are now cross-referenced here and in the Payer & Company Map (rhtf_prog node).

State Drill-Down: California, Montana, Georgia — plus any-state lookup

Three distinct categories, chosen for contrast: CA (Expansion + Litigant, largest Medicaid program in the U.S.), MT (Early Adopter, rapid state-initiated rollout), GA (Waiver-Only/Non-Expansion, the only state with a multi-year work-requirement track record). Each card covers exposure, action plan, strengths/weaknesses, tipping point, cost-shift cascade, and incentive structure.

California — Expansion + Litigant
  • Exposure: Largest Medicaid program in the U.S. (Medi-Cal). Three distinct, non-conflicting DHCS/LAO estimates, not competing numbers: DHCS puts 4.8M enrollees subject to the work requirement (2.2M expected exempt), with 1.1M as its own central estimate of coverage loss and up to 3.4M as a higher-end/worst-case scenario (modeled on other states' early work-requirement experience); the LAO separately projects ~2M more Californians uninsured by end of 2030 from OBBBA plus state policy changes combined (a broader net figure spanning Medi-Cal, marketplace, and immigrant-eligibility effects, netting out those who find other coverage — LAO attributes roughly 90% of it to OBBBA — LAO report). Effective Jan 1, 2027; 6-month redeterminations from March 2027; $580/month income accepted as an alternative to 80 hrs/month.
  • Action plan: DHCS "Tracking Federal Impact" public hub; CA is a co-plaintiff (not lead) in Commonwealth of Massachusetts et al. v. Oz (MA is the named lead plaintiff; 25 states + DC total, filed June 2026) over the medically-frail exemption rule — a federal judge denied the coalition's preliminary injunction on July 29, 2026, so the rule remains in effect while litigation continues — and co-leads a separate 21-AG + 1-governor suit (filed N.D. Cal.) against the 2027 Notice of Benefit and Payment Parameters. CHCF publishes provider/plan implementation guidance.
  • Strengths vs. weaknesses: Mature statewide MCO infrastructure and existing CalAIM 1115-waiver social-needs screening could double as an exemption-documentation rail (strength) — but CA faces its own concurrent state budget shortfalls even as DHCS's own reporting flags implementation capacity risk (weakness), and CA's sheer population size means even a small procedural-failure rate produces large absolute coverage-loss numbers.
  • Tipping point: Whether paperwork/documentation failure — rather than actual non-work — ends up driving most disenrollment, as it did in early-adopter states. The figure this page uses is DHCS's own central estimate of ~1.1M; the 3.4M number is a high-end scenario modeled on other states' early experience and should not be treated as the expected outcome. If procedural failure dominates, the realized number moves toward the upper end of that span rather than past it. (CHCF, citing DHCS)
  • Cost-shift cascade: Federal Medicaid match reductions shift onto the state general fund, county eligibility offices, and public/safety-net hospitals (e.g. Zuckerberg SF General, LAC+USC, Highland Hospital) as the ultimate backstop.
  • Incentive structure: Counties and MCOs are financially incentivized to minimize procedural disenrollment — counties to avoid downstream uncompensated-care cost, MCOs because capitation revenue depends on retained enrollment.
Montana — Early Adopter
  • Exposure: Enforcement begins July 1, 2026 — six months ahead of the federal deadline. A 3-month non-enforcement grace period (Jul-Oct 2026) precedes actual disenrollment risk.
  • Action plan: DPHHS launched a public online resource hub (March 2026) and is "moving forward... despite questions" (per its own framing in state press coverage) about system readiness.
  • Strengths vs. weaknesses: Early move gives MT (and CMS) real operational data before most states reach their 2027 deadline (strength) — but the Montana Budget & Policy Center and Montana Hospital Association have both publicly flagged eligibility-system readiness gaps (weakness).
  • Tipping point: First disenrollment wave, December 31, 2026. DPHHS's own estimate is ~13,000 adults (~18% of the expansion population) losing coverage by the 2027 enforcement completion (Montana Free Press, citing DPHHS). This page uses DPHHS's own number rather than the wider 10,000-30,000 span that circulates in advocacy estimates.
  • Cost-shift cascade: Rural Montana hospitals, already thin-margin, absorb uncompensated care first; the state general fund backstops eligibility-system costs.
  • Incentive structure: Moving early lets Montana shape its own implementation terms ahead of a one-size-fits-all federal framework, per its budget-policy-center reporting.
Georgia — Waiver-Only / Non-Expansion
  • Exposure: Pathways to Coverage has run since July 2023 — two-plus years before OBBBA's national requirement — and was extended through Dec 31, 2026 despite its own cost findings.
  • Action plan: State and federal government (the Trump administration extended the program in Sept 2025) have doubled down rather than restructured, despite the GAO's admin-cost findings.
  • Strengths vs. weaknesses: GA is the only state with real multi-year operational data on a Medicaid work-requirement program — genuinely useful evidence as CMS designs the national rollout (strength) — but GAO documented a 2:1 admin-to-care spending ratio (GAO-25-108160: $54.2M vs. $26.2M, FY2021 through Q2 FY2025 (ending March 2025), ~88% federally funded) and enrollment has run far below target (7,400-9,175 vs. a Pathways-eligible population commonly cited at ~240,000-250,000, missing even its own ~25,000 first-year goal per GAO) (weakness). Deloitte's $27M Pathways marketing contract (grown from an initial $10.7M award) produced enrollment still under 3% of the a Pathways-eligible population commonly cited at ~240,000-250,000 even after the campaign ran.
  • Tipping point: The Dec 31, 2026 extension deadline — if Pathways is folded into the 2027 national framework rather than renewed standalone, GA's cost structure becomes either the template CMS exports or the cautionary tale other states cite to avoid it.
  • Cost-shift cascade: The federal government has covered ~88% of Pathways' administrative spend to date, so the "vendor spending > care" pattern has so far been a federal cost, not a Georgia one — that changes if OBBBA's national framework shifts more administrative burden onto states. The 2:1 admin-to-care ratio is also front-loaded, not a steady state: the administrative share fell from 96.5% of spend in FY2023 to 58.8% in FY2024 as the initial system buildout cost was absorbed — a caution against extrapolating GA's early ratio flatly onto the national rollout's steady-state cost.
  • Incentive structure: State political incentive to preserve Pathways as proof-of-concept for work requirements nationally, even as its own numbers argue against the model's cost-effectiveness.
Any-State Drill-Down

The three cards above are the deep-dive states. Select any other state or DC below for its category assignment, expansion status, work-requirement timeline, litigation posture, and whichever coverage-loss figure is actually verifiable for it. Most states have no verified state-specific coverage-loss estimate yet — where that is the case this says so plainly rather than extrapolating one, and points at the tracker to check.

The Bay Area as Bellwether

Within California, the Bay Area's dense MCO/FQHC safety-net infrastructure diverges sharply from Central Valley and rural CA, where thinner provider networks and longer travel distances likely translate the same paperwork-failure rate into a higher effective coverage-loss rate. A standalone page maps potential navigation-network options to explore and ranked at-risk and resilient organization tables for healthcare-and-housing navigation networks in the region, limited to organizations with direct fiscal exposure to OBBBA-related cuts:

→ Open: Bay Area Navigation Networks — Potential Actionable Insights (standalone page)

Notable people & entities shaping this conversation: Michelle Baass (Director, CA Dept. of Health Care Services); Rob Bonta (CA Attorney General, co-plaintiff counsel in Commonwealth of Massachusetts et al. v. Oz — Massachusetts is the named lead plaintiff); California Health Care Foundation (CHCF, implementation-guidance publisher); San Francisco Health Plan, Alameda Alliance for Health, Santa Clara Family Health Plan, Contra Costa Health Plan, Health Plan of San Mateo (regional Medi-Cal MCOs — not Partnership HealthPlan of CA, which serves Northern California counties outside this footprint). Statewide advocacy organizations (California Pan-Ethnic Health Network, Western Center on Law & Poverty, California Primary Care Association) are active on this issue nationally but their specific Bay Area positions were not independently verified in this research pass — treat as directionally relevant, confirm before citing specifics.

Works Cited by Topic: A Reading Guide

Organized by topic rather than as one flat list, so this doubles as a reading guide into the underlying sources — separate from the main repo's Data Freshness sources list (README) to keep this deep-dive self-contained.

OBBBA Text & Overview
H.R. 1 / P.L. 119-21 full textcongress.gov/bill/119th-congress/house-bill/1
Signing & provision summaryPwC — President Trump signs H.R. 1
Medicaid Work Requirements — National Tracking
1115-waiver implementation trackerKFF
National implementation frameworkCMS Newsroom
Implementation guidance for statesCBPP
State Early Adopters (NE, MT, IA, AR)
Montana rollout & system gapsMontana Free Press · Montana Budget & Policy Center
Nebraska first-in-nation rolloutNebraska Public Media · CBPP
Iowa Dec 2026 rollout & coverage-loss estimateIowa Legislative Services Agency (LSA) projection, via Becker's Payer Issues
Arkansas early-adopter statusHolland & Knight — CMS IFR summary
North Dakota readiness strainGeorgetown CCF Readiness Tracker · ND HHS
Georgia Pathways to Coverage
GAO admin-cost findingsThe Current GA · KFF Health News
Two-year program trackingGeorgia Budget & Policy Institute
Immigrant Eligibility & Premium Tax Credits
§71301/§71302 summaryGeorgetown CHIR
Enhanced-subsidy expiration (separate from OBBBA)CBPP · KFF calculator
§71305 clawback cap repealDisability Belongs
Provider Tax / Rural Health Transformation Fund
Provider-tax phase-down mechanicsBDO
RHTF distribution & blueprint processNational Rural Health Association
California / Bay Area
CA implementation policy briefCalifornia Health Care Foundation
DHCS federal-impact tracking hubCA DHCS
Litigation filingsCA DOJ
Massachusetts v. Oz docket & PI rulingGeorgetown Litigation Tracker · AJMC
Cost Trend & Dual-Eligible Context
2027 employer cost trend surveysAon · PwC
Dual-eligible disability prevalenceCMS

Static/Dynamic Refresh Protocol

This entire tab is static HTML with no backing JSON (same pattern as the Data Taxonomy reference sections) — edited in place. It is not automatically refreshed by the standard "update all tabs" workflow; see CLAUDE.md Step 10 for the explicit check-and-update triggers added for this tab.

ElementSource to check each refresh cycle
CBO coverage-loss projectionsCBO.gov new scores on OBBBA-related legislation
KFF / Georgetown CCF tracking dataKFF work-requirements tracker; Georgetown CCF H.R. 1 Readiness Tracker
State case-study numbers (NE, MT, GA, TX)State Medicaid agency releases; GAO/state auditor reports
Litigation statusCA DOJ federal-accountability healthcare page
Individual mandate penalty amountsState revenue department guidance (annual, calendar-year change)

Limitations & Caveats

  • State case-study numbers are mostly projections, not realized outcomes — evidence grade varies by row (see Categories of Impact table): confirmed for NE, MT, GA (GAO), and ND (all independently re-verified against state-agency/GAO/tracker sources across multiple research passes); modeled for IA (state Legislative Services Agency projection); insufficient for the Expansion+Waiver category (HI/MA/NY/OR/UT) pending a verified state-specific figure. Texas's confirmed application-backlog figure is real but was removed from the Categories of Impact table itself, since Texas is a non-expansion state with no work-requirement population — see the note below the Categories of Impact table.
  • Threading state individual-mandate penalty interactions with the federal enhanced-subsidy expiration (Individual Mandate Variation section) is original synthesis for this repo, not a claim mirrored from any single cited source — treat it as an analytical framing, not an established consensus finding.
  • The Georgia Pathways-to-national-rollout comparison (Case Studies) is illustrative of work-requirement administrative-cost mechanics, but GA's waiver program and OBBBA's national requirement are legally distinct instruments — GA's numbers are a preview, not a direct prediction, of national-rollout costs.
  • This research pass could not independently verify: the spec's original Hawaii 193-minute call-center wait-time figure, or Bay Area advocacy organizations' specific published positions on OBBBA. Both are flagged inline rather than asserted as fact. (Iowa's and North Dakota's figures, previously flagged as unverified here, were confirmed in a later independent verification pass — see Categories of Impact table. North Dakota was reinstated to that table after initially being dropped in error.)
  • The specific ESRD/disability dual-eligible disparity ratio (this project has at different points used both "2x" and "4.7x") could not be confirmed against a single CMS source pairing both a dual-eligible and a Medicare-only figure — treat any such multiplier as unverified until re-sourced.
  • The CBO ~10M coverage-loss figure is a combined, cross-provision estimate that varies by score vintage and methodology across CBO, KFF, and Georgetown CCF — used here as an order-of-magnitude anchor, not a precise number.
  • Litigation status is a snapshot as of this pass (early September 2026): a preliminary injunction was denied in Massachusetts v. Oz on July 29, 2026, and a motion to reconsider filed Aug 26, 2026 was still pending as of this update — check current docket status before citing "depends on injunction outcome" as the live state of play.