For our March 19 General Membership Meeting, we were joined by folks at Northwest Health Law Associates (NoHLA) and Community Health Plan of WA (CHPW) to hear about the impacts to Medicaid under HR1. We also heard a brief legislative recap from our Community Policy Manager Hali Willis, took action on some proposed rules at the U.S. Department of Housing and Urban Development (HUD), and learned about the Coalition’s efforts to prepare service providers in the stadium district for the 2026 FIFA World Cup.

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Changes to Medicaid Under HR1

Jump to 07:18 in the recording to hear this presentation.

Read about the statewide impacts of HR1 from the Washington State Office of Financial Management here: https://ofm.wa.gov/budget/resources/h-r-1-impacts-on-washington-state-people-and-budget/#section-health-care-medicaid-enrollee-impacts

Key dates:

Oct 1, 2026: HR1 Eliminates Medicaid and Children’s Health Insurance Program (CHIP) eligibility for certain lawfully present immigration status’ (refugees, asylees, and other non-citizen adults). COFA migrants, Cuban/Haitian entrants and lawful permanent residents will still remain eligible.

Dec 31, 2026: Work requirements go into effect for Medicaid expansion adults (adults age 19-64, up to 138% of the Federal Poverty Level) unless they qualify for an exemption. 

Work requirements under HR1 impact Medicaid Expansion clients. If your coverage is labeled as any of the following, it is not Medicaid Expansion:

• Pregnancy Medicaid

• Parent/Caretaker Medicaid

• Aged, Blind, Disabled (ABD) Medicaid

• SSI-related Medicaid

• Medicare Savings Program

• Long-term care Medicaid

• CHIP (for children)

Generally “work requirements” and “community engagement requirements” are used interchangeably with “community engagement” being the formal phrase in the bill. The requirements can be met by working sufficient hours but also by volunteering, school, etc. However, we don’t yet have specific definitions around what counts as “community engagement,” but we will share more once there is additional info. For more information about health care for uninsured people, please see NoHLA’s fact sheet here: https://nohla.org/wordpress/wp-content/uploads/2026/01/affordability-Jan-26.pdf

Individuals deemed to have a “disabling mental disorder” may qualify for the “medically frail” community engagement exemption. However, more information is needed to understand what criteria will be used to determine exemption eligibility. For more on work requirements and mental health disorders, see the National Alliance on Mental Illness’s recommendations for protecting coverage for people with mental health conditions:  https://www.nami.org/wp-content/uploads/2025/11/2025-Work-Reporting-Requirements-and-Mental-Health.pdf.

Q: Do these changes impact Apple Health?

A: Apple Health is another name for Medicaid in Washington state. Whether or not these changes impact someone on Apple Health depends on the path through which a particular person has coverage. If someone is on “classic Medicaid,” i.e. though disability or another pathway, the work requirements do not apply. But if you are on Medicaid solely because you are low income, the work requirements will probably apply to you.

Here’s a little more info about the Apple Health/Medicaid connection: https://connections.hca.wa.gov/apple-health/2025/april/apple-health-is-medicaid-what-you-need-to-know

Q: What about emergency room visits?

A: Emergency room care qualifies for charity care for income-eligible people. You can read more about Washington state’s charity care requirements here: https://www.atg.wa.gov/charitycare

Q: What about retroactive coverage?

A: Medicaid coverage can cover a period that took place before you applied. HR1 shortens that period. See slides for more detail.

Q: What about clients on Age, Blind, Disabled (ABD) benefits?

A: Aged/Blind/Disabled Medicaid is distinct from the Medicaid Expansion population, so work requirements will not apply. No exemption needed. This link from the Washington Health Care Authority has the eligibility for the different Apple Health programs (including ABD). A client should also be able to see individual eligibility in ProviderOne.

Q: Is auto-renewal going away?

A: States should still attempt auto-renewal before requesting additional info from the enrollee, just on a 6-month timeline instead of 12-month timeline.

Take Action on these two proposed HUD rules

The HUD has proposed two rule changes: Both risk compromising housing for thousands of people across the country. Please note that neither of these rules are currently in effect.

When federal agencies propose significant rule changes like these, they must accept public comments. The agency is required by law to review all comments and respond to the issues raised in their final rule. It is important to submit as many comments as possible (and it is even better if those comments are unique and raise different concerns, so please add your own words). You can submit comments that include your contact information, or you may submit anonymously if you wish.

The “Mixed Status” Rule

HUD has proposed a rule change that would prevent entire families from receiving federal housing assistance if a single family member can’t prove their eligibility (citizenship or another qualifying immigration status). This is a significant change from current policy. Currently, mixed-status families are allowed to receive federal housing assistance that is pro-rated to exclude the person who isn’t eligible*. This proposed change would:

• Kick out 80,000 people including 37,000 children who are currently housed using HUD assistance (Source: Center for Budget and Policy Priorities)
• Deny federally-subsidized housing to tens of thousands of families that include an undocumented family member
• Deny assistance to families who are eligible but can’t produce sufficient proof of eligibility. Many people who have experienced poverty and homelessness lack sufficient documentation to prove eligibility even if they are US citizens or otherwise eligible to receive federal housing assistance.

*For example, a family of three US citizens and one undocumented person can currently receive housing assistance. Because the undocumented family member doesn’t receive a subsidy, this family’s assistance is 75% of what a family of four US citizens (or eligible non-citizens) would receive. Under the new proposed rule, this family would not be able to receive any federal housing assistance at all.

Source: the Protecting Immigrant Families Coalition

Speak up against the Mixed-Status Rule (Due April 21, 2026)

For individuals: https://www.keep-families-together.org/#take-action 

For organizations: https://pifcoalition.org/campaigns/hud-mixed-status-rule/ 

Direct link to the comment page: https://www.regulations.gov/commenton/HUD-2026-0199-0001

Example comment (adapted from the Keep Families Together campaign):

I strongly oppose HUD’s proposed rule “Housing and Community Development Act of 1980: Verification of Eligible Status (FR-6524).” The Trump administration should immediately withdraw its current proposal. 

The proposal threatens to exacerbate the housing crisis, kicking people out of housing and on to the streets. It will significantly reduce the supply of affordable housing for everyone, citizens and immigrants alike, and public housing authorities will need to either offer fewer vouchers or allow more units to sit vacant.

Work with Congress to make major new investments in the federal housing programs and take actions that ensure everyone has a safe and affordable place to call home.

The “Time Limits and Work Requirements” Rule

On March 2, HUD proposed allowing public housing agencies and HUD-assisted owners to impose work requirements and 2-year time limits on families living in HUD-assisted housing. If implemented, a 2-year time limit on assistance would result in an estimated 3.3 million people losing their rental assistance, including 1.7 million children.  

Under this rule, “work-eligible” people** living in HUD-assisted housing could be required to work up to 40 hours per week or lose their housing.

**According to the proposed rule, people who are “work-eligible” are age 18-61 without disabilities, not pregnant, not enrolled in higher education, and not primary caretakers for someone with a disability (temporary or permanent) or a child under 6.

Source: the National Low Income Housing Coalition

Speak up Against the Time Limit & Work Requirement Rule (Due May 1, 2026)

Direct link to the comment page: https://www.regulations.gov/document/HUD-2026-0298-0001

Example comment (adapted from the National Low Income Housing Coalition)

Everyone deserves to live in a safe, stable, affordable home. Federal rental assistance programs help more than 10 million people – overwhelmingly families with children, older adults, people with disabilities, full-time caregivers, and workers paid low wages – keep a roof over their heads. Rental assistance is a vital tool to combat the affordable housing crisis, helping families afford the cost of rent and other necessities, like nutritious food, medical care, transportation, and school supplies. However, because of chronic underfunding, only one in four households that qualify receive any form of rental assistance. Instead of fighting for increased investments in federal rental assistance programs, this proposed rule would put over 3 million people nationwide, more than half of them children, at risk of eviction and homelessness.

Most people in HUD-assisted housing who can work do work. Eighty-one percent of non-disabled people without young children worked in the past year, and those who do not work attend school, are caregivers, or are ill. Many working people still need rental assistance to help them afford housing because wages have not kept up with housing costs. For example, in Washington State, A full-time worker must earn an hourly Housing Wage of $41.11 to afford the average Fair Market Rent (FMR) of $2,138 for a two-bedroom rental home, but minimum wage in the state is $16.66 per hour. That means a minimum-wage worker must work 99 hours per week to afford a modest two-bedroom rental home at Fair Market Rent.

In Washington State alone, these proposed time limits would put 56,300 people – including 28,300 children – at risk of losing their assistance and facing eviction, and in worst cases, homelessness. Given the severe shortage of affordable homes for the lowest-income renters and the gap between low incomes and the high cost of housing, harmful policies like time limits and work requirements only serve to kick people off assistance – not increase employment opportunities or wages. Instead of pursuing policies that will increase housing insecurity for millions of people, HUD should enact proven solutions to help struggling households, including expanding rental assistance to help people afford safe, stable housing.

Our Next Meeting

Our next General Membership Meeting will be our 2026 Legislative Wrap Up on Thursday, April 16 from 9-10:30 a.m. over Zoom. Please join us! We will be joined by Rep. Strom Peterson (LD-21), Rep. April Berg (LD-44), and our statewide advocacy partners, Poverty Action.

+ SAVE THE DATE!

Our Annual Membership Meeting is in person this year! Location is TBA, but please save the date to join us on Thursday, May 21 from 9-11 a.m. We are looking forward to sharing information, resources, and space with you.