Every FQHC leadership team I talk to has some version of the same plan for H.R.1.
“We’re going to wait and see what Epic does.”
“Our vendor is working on something.”
“Our EHR vendor will have a module by January.”
I understand the instinct. You’ve invested heavily in your EHR. Your staff is trained on it. Your workflows run through it. When a new federal requirement lands, it makes sense to look to your existing vendor first.
But here is what I need you to understand before December 31, 2026 arrives: your EMR vendor is not coming to save you. And waiting for them will cost you patients.
What H.R.1 Actually Requires
The One Big Beautiful Bill Act, signed July 4, 2025, made three changes that every FQHC operating in an expansion state needs to understand:
Work requirements. Medicaid expansion adults ages 19 to 64 must document 80 hours per month of qualifying activity — employment, job training, caregiving, community service, or education — or qualify for a recognized exemption. Nebraska implemented this May 1, 2026. Oklahoma, Montana, and Iowa are following. The rest of the country hits the federal deadline January 1, 2027.
Six-month redeterminations. Expansion adults must now renew their Medicaid coverage every six months instead of once a year. Starting December 31, 2026, your state must verify eligibility twice as often as before. That means twice the paperwork, twice the outreach cycles, and twice the opportunities for procedural disenrollment.
Tighter income verification. Stricter data-matching rules are already generating more administrative terminations in 2026 — before the major requirements even kick in.
The CMS June 2026 interim final rule added further clarification: states cannot delegate community engagement enforcement to managed care entities. The verification burden falls on the state eligibility system — and the documentation burden falls on your health center.
What Your EHR Is Built to Do
Your EHR — whether it’s Epic, eClinicalWorks, Athena, or any other platform — was built to do three things extraordinarily well: document clinical encounters, manage billing, and schedule patients.
It was not built to manage Medicaid recertification lifecycles. It was not built to track 80-hours-per-month work requirement compliance. It was not built to identify medically frail patients using the two-element standard under 42 CFR 440.315, route their exemption attestations to clinicians, and file the completed packet with your state agency as an authorized representative under 42 CFR 435.923.
These are eligibility management functions. They sit in the gap between your EHR and your state Medicaid agency — and that gap is where your patients fall through.
The EMR Vendor Reality
Your EMR vendor — whether they deliver Epic through a community network, run eClinicalWorks, or operate any other platform — is in the same position. There is currently no publicly announced EMR module purpose-built for H.R.1 work requirement tracking, medically frail exemption determination under the two-element standard, or authorized-representative submission to state Medicaid portals at the FQHC level.
Even for the vendors actively working on something, there is the question of timing. EHR features don’t appear overnight. They move through product roadmaps, compliance reviews, configuration cycles, and staff training requirements. Community health-focused EHR networks often receive new features months after larger health systems — sometimes 6 to 18 months later — because of the complexity of multi-tenant deployments and FQHC-specific configurations.
Even if your vendor announced a module today, there is no realistic path to having it configured, tested, and operational at your health center before January 1, 2027.
The 2023 Lesson Nobody Learned
We have done this before. During the 2023 Medicaid unwinding — when pandemic-era continuous enrollment protections expired — approximately 25 million people lost Medicaid coverage nationally. The majority of them were still eligible.
They lost coverage because they missed a notice. Because they couldn’t navigate the paperwork. Because no one at their health center caught the renewal before it lapsed. Because the EHR had no mechanism to flag it, route it, and act on it before the deadline.
H.R.1 is that same dynamic, permanently installed, running every six months. The difference is that this time you know it is coming. The difference is that this time there is no excuse for being unprepared.
The Window That’s Closing Right Now
Here is the part that most health center leaders don’t fully appreciate.
The patients who will lapse coverage on January 1, 2027 are not a future problem. They are a right now problem.
If a patient has a Medicaid renewal due in the next 90 days, their window for documented work-requirement compliance, exemption confirmation, or authorized-representative submission is closing today. By the time January 1 arrives, you will not have time to act on those patients. The renewal will have lapsed. The coverage will have dropped. The pharmacy will have rejected the prescription. And you will be in recovery mode — retroactive appeals, rebilling, and explaining to a COO why revenue dropped in Q1 2027.
The health centers that survive H.R.1 intact will be the ones that treated this as a today problem, not a January problem. They are building their pipelines now. They are capturing consent now. They are documenting work-requirement status now. They are identifying their medically frail patients now, before the exemption paperwork becomes a scramble.
The Decision in Front of You
You have two choices.
You can wait for your EMR vendor to build something. You can assume that a module will arrive, that your team will be trained on it, and that it will be ready before December 31, 2026. You can hope that the feature lag runs shorter than usual. You can hope that your state implements gently.
Or you can act now. You can put the patients with renewals due in the next 90 days into a managed pipeline today. You can document work-requirement status before the first redetermination cycle hits. You can identify your medically frail population now, not in January. You can position your health center to spend 2027 in compliance rather than recovery.
The tools exist. The window is open. The question is whether you use it.
Your EMR vendor is not coming to save you. The deadline is.
Dr. Adetoro Oriaifo is the founder of Quantum 5D Consulting LLC, a health technology firm focused on Medicaid coverage intelligence for Federally Qualified Health Centers.
Sources
- H.R.1 — One Big Beautiful Bill Act, P.L. 119-21, signed July 4, 2025
- CMS June 2026 Interim Final Rule: Medicaid Program; Community Engagement Requirement for Certain Individuals
- KFF, 2024 — Medicaid Unwinding Coverage Loss Analysis
- CHCS — A Summary of Federal Medicaid Work Requirements, June 2026 Update
- Beyond the Basics — Work Requirements and Six-Month Redeterminations FAQ, June 2026
- BDO Healthcare — Understanding New Medicaid Redetermination and Work Requirements, October 2025