The recently passed One Big Beautiful Bill Act (OBBA) introduces federal changes to Medicaid eligibility and work requirements that could have real-world implications for providers, particularly those serving individuals with behavioral health and substance use disorder (SUD) needs.
What's Changing
One exception category includes individuals deemed medically frail, which includes those with SUD. HHS has until June 2026 to release guidance on the process. Once released, the states have the ability to determine any ambiguity. It is possible that only those with severe diagnosis or admitted in certain categories of SUD treatment programs may qualify. If the state attempts to implement the work and community engagement requirements in good faith, but fails to do so by December 31, 2026, HHS can grant the state an additional year to implement. Thus, some states may not know what these requirements will look like until December 31, 2027.
Why it Matters
These changes could create new challenges for providers, including:
- Coverage gaps due to paperwork or missed verifications
- Disruptions in care for patients who lose eligibility
- More complexity in helping patients navigate an uncertain system
How Wayspring Is Responding — and How We Can Support Providers
At Wayspring, we’re closely monitoring how states interpret the new guidelines and how they may affect the individuals we support together. Our teams are already working to:
- Stay engaged with members during coverage transitions, helping reduce drop-off in care
- Support members through exemptions and community engagement reporting as states clarify their processes
- Address social needs that can become barriers to treatment — including transportation, housing, and access to required documentation
- Partner with providers to enhance continuity so patients can stay on a path toward stability and recovery
Let's Stay Connected
We’ll continue to share updates as various states clarify their approach. In the meantime, if you have questions about how these changes may affect your patients, or want to explore ways to partner more closely, we’re here to talk.
Together, we can help patients stay supported — even as the system around them shifts.