it's been bumped up to next year. Here are some other stuff
Based on the sources provided and our conversation history, there are several provisions related to Medicaid, other health programs, and tax credits that are scheduled to sunset, terminate, or have new requirements take effect within approximately three years of the bill's enactment. Since "the Medicaid change" is quite broad, I will outline various relevant provisions within that timeframe. Assuming the bill is enacted around July 1, 2025, the three-year window extends to approximately July 1, 2028.
Here are key provisions within that timeframe:
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Termination of the IRS Direct File program The bill requires the Secretary of the Treasury to ensure that the Internal Revenue Service Direct File program is terminated as soon as practicable, and not later than 30 days after the date of the enactment of this Act1. Assuming enactment around July 1, 2025, this termination would occur by approximately July 31, 2025.
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Termination of Clean Energy Tax Credits Several tax credits related to clean energy and vehicles, which were discussed in our previous conversation regarding credit eliminations, are terminated effective for property placed in service or construction beginning after December 31, 2025. These include the Previously-owned clean vehicle credit (Section 25E), Clean vehicle credit (Section 30D), Qualified commercial clean vehicles credit (Section 45W), Alternative fuel vehicle refueling property credit (Section 30C), Energy efficient home improvement credit (Section 25C), Residential clean energy credit, and Clean hydrogen production credit (Section 45V) [Previous response analysis]. The Clean Electricity Investment Credit (Section 48E) includes a termination of the credit for construction beginning after the date that is 60 days after the date of enactment [Previous response analysis]. Assuming enactment around July 1, 2025, this termination would be around September 2025.
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Health Savings Account Provisions Effective Several amendments related to Health Savings Accounts become effective for taxable years or coverage beginning after December 31, 2025. This includes provisions on Health Reimbursement Arrangements integrated with individual market coverage2..., allowing individuals entitled to Medicare Part A by reason of age to contribute to HSAs2..., and a special rule for certain medical expenses incurred before establishing an HSA4.... Contributions are permitted if a spouse has a Health Flexible Spending Arrangement for taxable years beginning after the date of enactment6.
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Taxable REIT Subsidiary Asset Test Restoration The amendment related to restoring the Taxable REIT Subsidiary asset test applies to taxable years beginning after December 31, 20256....
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Medicaid Accurate Payments to Pharmacies The amendments aimed at ensuring accurate payments to pharmacies under Medicaid apply beginning on the first day of the first quarter that begins on or after the date that is 6 months after the date of enactment8.... Assuming enactment around July 1, 2025, this would be effective around January 1, 2026.
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ACA Exchange Enrollment Periods and Income Verification Changes to enrollment periods for ACA Exchanges and requirements regarding verification of income apply with respect to plan years beginning on or after January 1, 202612.... The removal of the automatic extension to resolve income inconsistencies also applies to enrollment for plan years beginning on or after January 1, 202612.... Amendments regarding the controlled group definition for Premium Tax Credits apply to plan years beginning on or after January 1, 202614....
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ACA Exchange Premium Tax Credit for Certain Aliens The disallowance of the Premium Tax Credit during periods of Medicaid ineligibility due to alien status applies with respect to plans enrolled in during calendar months beginning after the third calendar month ending after the date of the enactment of this Act17. Assuming enactment around July 1, 2025, this would be effective for calendar months beginning November 2025. Permitting the Premium Tax Credit only for certain individuals (excluding certain alien statuses) applies to taxable years beginning after December 31, 202618....
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Medicaid and CHIP Citizenship/Immigration Status Verification Amendments prohibiting Federal financial participation under Medicaid and CHIP for individuals without verified citizenship, nationality, or satisfactory immigration status, and modifying the state option to continue providing medical assistance during a reasonable opportunity period, apply beginning October 1, 202620....
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Medicaid and CHIP Retroactive Coverage Modification The amendments modifying retroactive coverage under Medicaid and CHIP apply to medical assistance and child health and pregnancy-related assistance with respect to individuals whose eligibility is based on an application made on or after October 1, 202623.... This changes the period of retroactive coverage from three months to one month prior to the application date27....
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Medicaid and CHIP Address Verification Requirement States must provide for a process to regularly obtain address information for enrolled individuals, beginning not later than January 1, 2027, for the 50 States and DC29. Contracts with managed care entities must also require them to promptly transmit address information to the State, beginning January 1, 202730.
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Medicaid Accurate Pharmacy Payments (Managed Care Contracts) The amendments related to contracts between States and managed care entities, other specified entities, or pharmacy benefit managers (including provisions on abusive spread pricing) apply to contracts that have an effective date beginning on or after the date that is 18 months after the date of enactment of this section31.... Assuming enactment around July 1, 2025, this would be effective around January 1, 2027.
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ACA Essential Health Benefits Prohibition for Gender Transition Procedures For plan years beginning on or after January 1, 2027, essential health benefits defined under the ACA may not include items and services furnished for a gender transition procedure35.
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Medicaid Eligibility Redeterminations Frequency Requirements increasing the frequency of eligibility redeterminations for certain individuals (specifically requiring states to conduct them every six months for Expansion population adults, a change from twelve months under current law36) begin on October 1, 202737.
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Medicaid Reducing Expansion FMAP for Certain States The provision reducing the enhanced FMAP to 80 percent for certain specified states providing payments for healthcare to certain individuals applies for calendar quarters beginning on or after October 1, 202721. This section is also described as sunsetting the temporary five percent enhanced FMAP afforded to states under the American Rescue Plan Act38....
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Medicaid Provider Screening Against Death Master File States are required to check the Death Master File as part of the provider enrollment process and at least quarterly during enrollment, beginning January 1, 202840....
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Medicaid Home Equity Limit for Long-Term Care Amendments revising the home equity limit for determining eligibility for long-term care services under the Medicaid program apply beginning on January 1, 202847....
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Orphan Drugs Exclusion Under Drug Price Negotiation Program This provision, which relates to Medicare Part D and drug pricing, applies to eligibility years beginning on or after January 1, 202815....
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Tennessee DSH Program Funding Extension Sunsets Funding for Tennessee's Disproportionate Share Hospital (DSH) program, which is set to expire, is extended through fiscal year 202850.... This means the extension sunsets at the end of FY 2028.
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Provider Tax Uniformity Waiver Transition Period Ends The amendments regarding waiver of the uniform tax requirement for the Medicaid provider tax take effect upon enactment, subject to a transition period determined appropriate by the Secretary of HHS, not to exceed 3 fiscal years52.... This means any such transition period must end by the end of the third fiscal year following enactment.
While many of these are effective dates for new requirements or changes in how programs operate, the specific tax credits mentioned earlier and the IRS Direct File program are explicitly terminated or eliminated within this three-year window. Additionally, the eligibility for the enhanced Medicaid FMAP for new expansion states is described as sunsetting38..., and the extension of the Tennessee DSH program funding ends in FY 2028, representing a sunset of that specific funding extension50....
