New administrative changes to Medicaid could significantly affect access to life-saving care and medicine for those who need it most.
As outlined in our previous post, the funding bill signed into law in July, H.R.1 (also known as One Big Beautiful Bill) makes significant changes to Medicaid that will require states to adapt their programs in order to remain in compliance with the law. The changes will be influenced by almost $1 trillion in cuts to states over the next 10 years, as well as new administrative requirements.
In this installment, we will focus on an aspect of the program that is receiving less attention but is expected to have a significant impact on affordable and supportive housing residents, those who are actively experiencing or formerly experienced homelessness and those experiencing any type of housing instability: Address verification.
Under H.R.1, states must design and implement a federally approved address verification process. State plans are due to the federal government by January 1, 2027, and full implementation is effective January 1, 2029. To prevent duplicate enrollment across states, CMS will require monthly transmission of address and Social Security Number data. By October 1, 2029, states must submit cross-state data to CMS for analysis.
Without thoughtful implementation and input from various stakeholders, many populations that rely on Medicaid for healthcare and services are at risk of losing Medicaid coverage due to challenges with verifying their address.
Populations Most at Risk of Losing Coverage
First, people who are experiencing homelessness or housing instability are more likely be found to have invalid addresses. Many in this group will use a soup kitchen, drop-in center, shelter, Health Care for the Homeless clinic, or other health center as their only long-term address option. This may lead state staff to question the validity of an address with hundreds —if not thousands — of “residents” when in fact the address is valid and the one place of stability in an unstable life.
Children who are in the legal custody of a state or county child welfare system also will be impacted. They will likely have a government office as their legal address. They too may run into issues with this requirement when aggregate data pulls indicate an unexpectedly large number of children with a single address.
Finally, individuals who have been recently released from incarceration are also likely to run into issues with this requirement. As of August 2025, 11 states have approved waivers to allow people who were formerly incarcerated more access to Medicaid with 13 states pending. Most of these waivers include Medicaid coverage 90 days prior to release, and a valid address at that time will be a jail or prison.
As they are leaving the criminal justice system, a person may provide one address and quickly find themselves living at another address due to housing instability. A person’s address once released into the community is likely to change numerous times before housing stability is achieved. Notifying state Medicaid of these address changes may not be a priority when housing is unstable.
These populations at risk of losing Medicaid coverage due to address verification issues are among the vulnerable populations that supporters of H.R.1 promised would not be impacted by the bill.
Numerous reviews and studies suggest a relationship between health insurance coverage and preventative care and improved health outcomes. The populations noted here (those experiencing homelessness, child welfare involved families and individuals, and community members returning from incarceration) are among the most vulnerable groups with the worst health and well-being outcomes. They are among the most impacted by loss of coverage because of an already arduous process to verify their addresses.
Each of these populations have lower rates of access to primary care, preventative screenings and follow up care and loss of health care coverage; frequent churn of insurance coverage likely contributes to these issues and worsens health conditions.
That is why, despite challenging budget times, states must focus on ensuring people have continuous health coverage as the central strategy for an effective and efficient Medicaid program.
Influencing your State’s Address Verification Implementation
- Most states already have a coalition of stakeholders’ groups working to expand health care coverage to all.1 The housing and homeless sector is encouraged to connect with state-based groups and share the stories and unique challenges of those you serve who must navigate an evolving bureaucracy to maintain health insurance coverage. People who receive Medicaid coverage should be front and center in these efforts. They know best what works and what does not work.
- State-based stakeholder groups must collaborate with their states on implementation of the federal bill, with the goal of mitigating loss of health care coverage and other harms. In the coming months, states will begin adapting their eligibility and enrollment systems to meet the bill’s new requirements, and the issues with address verification must be part of the conversation.
- When meeting with state Medicaid staff, advocate for strategies that limit health care coverage losses as much as possible. CSH has summarized a list of State Solutions to Ensure Continuous Medicaid Coverage. Data system integration efforts at the state level lessen administrative burdens on those who are tasked with proving income, disability status and other factors to multiple state systems.
- Many states have a role called “application assisters” that allows a Medicaid beneficiary to designate another individual to have access to their online accounts and support efforts to comply with new requirements. The existence of that role needs to be shared across sectors (homelessness, education, unemployment, child welfare, reentry), supported and trained. The role also needs to be funded at the agency level, and Medicaid Managed Care Organizations (MCOs) may be supporting these roles.
- It will be critical for advocates with expertise in the unique needs of the populations most at risk of losing health care – the housing and homelessness community, child welfare advocates, and advocates working with people released from incarceration – to join those tables. These advocates may be new to state level health access coalitions and coalitions working to ensure continuous coverage may be new to the unique challenges that these populations experience. Each group is encouraged to learn from and support each other.
- Disability advocates are also an essential part of the coalition, as those with disabilities are overrepresented among those experiencing homelessness, are involved in the child welfare system or reentering from carceral settings. All of these groups can be a part of developing state specific implementation recommendations and communications networks.
In Conclusion
States are beginning to plan for and implement H.R.1’s many new requirements, and attention must be given to developing state processes for address verifications. Critical populations such as those experiencing homelessness, involved in the child welfare system, or returning from incarceration will find unique barriers to coverage because it is harder for them to verify their address.
Collaboration between advocates and state officials is essential to reduce administrative barriers and maintain coverage for people facing complex challenges. With careful planning and inclusive implementation, states can meet H.R.1 requirements while ensuring continuous access to care.
CSH thanks Alison Barkoff of George Washington University and Richard Cho of Manatt Health for their support in writing this article.
References:
1 National Health Advocacy Partners & Organizations | FL Voices for Health
