Note: This document was originally published on May 19 and has been updated to reflect developments as of July 11,

reflecting when Congress passed H.R.1 on July 3 and President Trump then signed the legislation into law on July 4,
2025. The updated content below incorporates policy changes included in the final version.

SUMMARY OF FEDERAL CHANGES AND THE IMPACT ON MAINE

MEDICAID July 11, 2025

Background
On July 3, Congress passed H.R. 1 Budget Reconciliation, and on July 4, President Trump signed the
legislation into law. The final version of H.R. 1 maintains major Senate provisions restricting eligibility and
enrollment, Medicaid financing, and federal financial participation for certain populations and providers.
These provisions include work, or “Community Engagement” requirements, coverage cuts for certain legally
present immigrants, provider tax restrictions, and increased financial exposure to states for technical
payment errors. Using national data sources, national experts estimate that the total fiscal impact of H.R. 1
on the State of Maine would equal an estimated $5.0 billion over 10 years.1 Some of the most significant
impacts to Maine, as well as high-level estimates of these changes, are outlined below.

Snapshot of MaineCare
MaineCare includes Maine’s Medicaid program, Children’s Health Insurance Program (CHIP), and a small
state-funded health coverage program. MaineCare serves individuals with low incomes and/or disabilities
and children with special health care needs.

Enrollees
As of April 2025, approximately 393,000 Maine people had MaineCare coverage.2 Over 1 in 5 adults with
MaineCare coverage (38,000 individuals) and over 5,000 children with MaineCare coverage have disability-
related coverage. Additionally:

1 Manatt Health, Senate-Passed H.R. 1: Updated Estimates on Impact to State Medicaid Coverage and Expenditures, Hospital Expenditures,
Including Impacts by Congressional District
2 This enrollment count excludes approximately 9,000 members with state-only spenddown coverage, as the proposed federal policies are unlikely to
interact with MaineCare costs associated with these individuals.

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Office of MaineCare Services (OMS)
 Funding
$4.7 billion annual budget cost shared between the state and federal government: approximately $3.0
billion federal, $1.7 billion state.
The traditional rate at which the federal government matches state Medicaid funds varies by state and is
determined by a formula based on a state’s per capita income. Some reimbursement categories, such
as CHIP and the Medicaid expansion population, are matched at a higher rate. For fiscal year 2025 in
Maine, the federal government assumes:
• 90.00% of the cost for low-income, childless adults covered under MaineCare expansion
• 73.44% of the cost for moderate to low-income children covered under CHIP
• 62.06% of the cost for traditional MaineCare members

Enrollment by County
Smaller and more rural counties in Maine have the
highest rates of MaineCare enrollment.

Services covered
MaineCare’s highest-expenditure services are:
• Hospital care
• Community-based services for individuals
with developmental disabilities
• Prescription drugs
• Long-term care facilities
• Mental health and substance use disorder
treatment
• Physician and Community Health Center
Services

Department of Health & Human Services 2

Office of MaineCare Services (OMS)
Federal Medicaid Changes and Impacts on Maine

1. Work or Community Engagement Requirements for Certain Medicaid Expansion

Members
Beginning December 31, 2026, the Act requires states to condition Medicaid eligibility on
compliance with work or other community engagement requirements for adults ages 19
through 64 enrolled through Medicaid expansion. Over 90,0003 MaineCare members meet
this definition and will thus be subject to work requirements or need to meet an exemption
on January 1, 2027. Members who do not meet an exemption will need to either work at
least 80 hours per month or complete other qualifying activities, such as volunteering at
least 80 hours per month or enrolling at least half-time in an educational program. Exclusion
categories include:
• Pregnant women
• Former foster youth under age 26
• Tribal members and Alaska Natives
• Veterans with rated disabilities
• People participating in defined substance use or alcohol use disorder treatment
programs
• People who are compliant with TANF/SNAP work requirements
• People who are parents or caregivers of a dependent child under age 14 or someone
with a disability
• People who are currently incarcerated or have been released within the past 90 days
• Family caregivers as defined in RAISE Family Caregivers Act
• People who are medically frail or otherwise have special medical needs, including a
Substance Use Disorder or disabling mental health condition.
Based on experience in other states, Maine anticipates that over 31,000 of these members
may be disenrolled within the first year of enforcing the requirements. Not necessarily
because they aren’t meeting work requirements or qualifying for an exclusion, but rather due
to verification barriers. These barriers are likely to arise in part from the significant
technology and workforce investments required to systematically verify employment; the
challenges in communicating a policy of this magnitude to the impacted MaineCare
population; and obstacles to facilitating a streamlined process that enables working
members, many of whom may have multiple jobs, jobs that are seasonal, or irregular work
hours, to regularly report on their status.4
States have the option of not requiring verification of exemption status, which will help to
ease the burden on members. In addition, states must also implement passive enrollment
and renewal systems that utilize data available to the state for purposes of determining that
a member has met the work requirement or an exclusion. Nonetheless, these requirements
represent a significant shift and added burden to members, and effectively reaching all
members will be a challenge given the barriers this population often faces with stable
housing and other stressors associated with low wage work and low-income status. In
addition, the system changes and outreach necessary to minimize the disenrollment of
individuals who do meet work or exclusion requirements will come at a significant cost to the
state. Total administrative, staffing, and technology costs are estimated to exceed $8 million
in fiscal year 2027 for the Department, and about $5.5 million on an annual basis thereafter.
3
Estimate of Medicaid Expansion members increased from the May version as parents/caregivers of a dependent child 14 years of
age and older are not subject to mandatory exception under the Act.
4
Actual disenrollments may exceed this estimate given the outreach and communication challenges that are expected to
accompany the accelerated time to implementation of the proposed work requirement.

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Office of MaineCare Services (OMS)
 Because the Act also prohibits members who do not meet the Medicaid work requirements
or exceptions from qualifying for Marketplace subsidies, which significantly lower monthly
premium costs for coverage purchased through Maine’s state-based health insurance
Marketplace (“CoverME.gov”), access to other affordable coverage options will be limited for
these individuals. The interaction between these policies risks increasing uninsured rates
among this population, resulting in higher levels of uncompensated care costs to Maine
providers, and driving up insurance costs for everyone with private health coverage in
Maine.
The implementation of work requirements for the expansion population will result in a
substantial reduction in federal funding for Maine’s health care system, affecting not only
members but also our providers, who will face increasing uncompensated care burdens.

Currently, expenditures for expansion members benefit key health care provider sectors –
$329 million to hospitals, $70 million to physicians and federally qualified health centers, $50
million to behavioral health providers, and $218 million to pharmacies.

2. Other Changes to Eligibility Processes

Additional provisions in the bill are also expected to have both short- and long-term impacts
on expansion group and other group enrollment in Maine. Beginning December 31, 2026,
states will be required to conduct eligibility redeterminations for expansion population adults
every six months, a change from the current annual cadence. More frequent eligibility
redeterminations are expected to both increase churn in the MaineCare program and to
have a compounding effect with work requirements on the number of disenrollments in 2027
and beyond. In addition, because individuals subject to work requirements may be
prevented from enrolling in MaineCare unless they are already employed or qualify for an
exclusion, overall expansion population enrollment in Maine may further decline after 2027,
especially among individuals facing health or economic challenges that limit their ability to
work.
An additional provision in the Act will also further limit coverage and increase
uncompensated care costs for Maine providers. For individuals who apply for Medicaid
coverage on or after January 1, 2027, states will be required to limit retroactive coverage
from three months to one month for the adult expansion population, and from three months
to two months for all other Medicaid and CHIP members. As a result, the provision of care to
uninsured individuals who would otherwise be eligible for Medicaid and CHIP coverage
outside of these narrower retroactive coverage windows will no longer be reimbursed
through MaineCare.

3. Coverage of Certain Immigrant Groups

As of October 1, 2026, the Act amends the definition of “qualified aliens” – those non-
citizens historically eligible to receive federal Medicaid match – to exclude refugees,
humanitarian parolees, asylum grantees, certain abused spouses, trafficking victims, and
certain other non-citizens. The Act continues to allow for coverage of children and pregnant
women in these categories. We estimate this change will result in the elimination of
coverage for approximately 3,000 MaineCare members. These are individuals who are
legally present in the United States, have long been recognized federally as eligible for full
coverage, and are very likely to have experienced trauma and have associated physical and
mental health needs.

Department of Health & Human Services 4

Office of MaineCare Services (OMS)
 Deferred Action for Childhood Arrivals (DACA) recipients are no longer eligible for
CoverME.gov, and most other legally present immigrants – such as those in MaineCare’s
five-year waiting period – can enroll but will not be eligible for advance premium tax credits;
only a few narrow categories remain fully eligible, making coverage unaffordable for many.
Also beginning October 1, 2026, the state will no longer receive enhanced federal match for
individuals who would otherwise qualify for expansion but for their immigration status; all
emergency Medicaid services will be at the base Federal Medical Assistance Percentage
(FMAP), regardless of eligibility category for the enrollee. This is estimated to result in an
increase of over $600k annually to the state share paid for these services.

4. Prohibited Federal Payments to Family Planning Services, Reproductive

Health, and Related Medical Care
This proposal, for a one-year period following the July 4 enactment of the legislation,
prohibits federal Medicaid match from going to non-profit family planning agencies that,
among other services, provide abortion services and have a certain level of Medicaid
revenue. This proposal is projected to immediately impact two of the three family planning
agencies in Maine, which combined provide Medicaid-covered services for an estimated
5,900 MaineCare members annually. The loss of federal Medicaid funds could lead these
organizations to close some of their existing locations.
Family Planning agencies provide important contraceptive, reproductive, preventive, and
primary care services to members, services which all received state and federal Medicaid
dollars prior to enactment of this legislation. The closure of these important health care
providers would mean lack of access to these critical services.
MaineCare will continue to cover state-funded abortion services delivered by these and
other providers.
Note: impacted providers have filed legal action regarding this provision. Maine will closely
track these proceedings and adjust implementation accordingly.

5. Moratorium on Provider Taxes

The Act places a moratorium on new or increased provider taxes, with exceptions for taxes
for services provided by nursing facilities and intermediate care facilities for individuals with
intellectual disabilities (ICF-IDDs), effective upon the July 4 enactment. In Maine, this will
limit provider taxes to the state’s current Nursing Facility, ICF-IDD, and Hospital taxes.
Provider tax revenues play a critical role in helping to ensure the financial sustainability of
Medicaid programs nationally – Maine is one of 49 states with provider taxes. Provider tax
revenue comprises roughly 12 percent of state dollars used to fund MaineCare. Prohibiting
new provider taxes and any tax increases limits Maine’s ability to generate additional
revenue needed for the program and to update revenue bases to reflect growth in the
program. This freeze also reduces the potential options Maine has to be able to make up
for any lost federal revenue, further exacerbating state budget constraints.
The current hospital tax of 3.25 percent applies to all hospitals except for public hospitals
and critical access hospitals. Maine statute specifies that the tax is based on revenue from
2022, with current collections estimated at $178M annually. Under the moratorium, Maine
will not be able to rebase, updating tax payments to a more current year, over time. This
will substantially limit the State’s ability to respond to increasing hospital costs of providing
care and otherwise invest in hospital reimbursement. The estimated combined loss in tax
revenues plus federal matching funds based on what would typically be biannual rebasing

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Office of MaineCare Services (OMS)
 and reinvestment of tax dollars is estimated to approach $3 billion dollars over a 10-year
period, assuming a 5 percent annual growth rate.

6. Payment Error Rate Measurement penalties:

Payment Error Rates are determined from federally required audits and are intended to
ensure accuracy in documentation and processing. Payment errors are very rarely indicative
of fraud, but instead most commonly represent administrative omissions, and often reflect the
fact that Medicaid agencies must maintain claims and eligibility systems that are complex and
constantly evolving to meet new requirements.

Beginning October 1, 2029, HHS will both expand the sorts of errors that can subject states
to financial penalties and restrict the longstanding practice of granting states waivers of these
penalties upon demonstration of good faith efforts and progress toward achieving
compliance. Error rates that exceed a 3 percent threshold will subject states to penalties,
even though the current national error rates vary between 5-6 percent. The changes to both
the scope of errors and the extent to which states may seek waivers of penalties expose
states to potentially severe and unpredictable financial penalties during a time when they will
also be required to implement numerous complex system changes to comply with H.R. 1 –
thus increasing the likelihood of errors.

Maine’s most recent PERM error rate was 2.4 percent for Medicaid, but it has exceeded the
threshold in the past. As a conservative example of the potential magnitude of penalties
Maine could face, if it were to perform at the national average error rate of 5 percent, Maine
could face a penalty for Medicaid payment errors of almost $64 million dollars, absent a
waiver.

Department of Health & Human Services 6

Office of MaineCare Services (OMS)
 Note: This document was originally published on May 19 and has been updated to reflect developments as of
July 11, reflecting when Congress passed H.R.1 on July 3 and President Trump then signed the legislation
into law on July 4, 2025. The updated content below incorporates policy changes included in the final version.

Supplemental Nutrition Assistance Program

(SNAP) July 11, 2025

Background / Demographics
• Annual benefits issued: $356 million (100% Federal)
• February 2025 recipients: 176,532 individuals (54,927 children, 92,973 adults, 28,632 older
Maine people) and includes
o 5,669 veterans
o 53,030 people with disabilities
o 25,203 people experiencing homelessness (defined as lacking a fixed or regular
nighttime address)

• In 2024, of SNAP households in Maine:

o 73% included someone who was working, even for able-bodied adults without
dependents (ABAWDs) work requirement enforcement was waived
o 58% included a person with a disability
o 43% included older Maine people
o 34% included children

Economic Impact
% of Total Population Enrolled in SNAP by County, 2023
Washington 21.1%
20.7%
Aroostook 20.4%
19.0%
Androscoggin 18.1%
17.6%
Franklin 15.3%
15.2%
Waldo 15.0%
14.0%
Maine 12.8%
10.3%
Hancock 9.8%
9.7%
Cumberland 8.6%
8.4%
Sagadahoc 8.3%
0% 5% 10% 15% 20% 25%
• Each $1 in SNAP spending generates $1.54 in local economic activity.
• $356 million in SNAP benefits are issued annually in Maine, resulting in nearly $548 million in
estimated economic activity.

Department of Health & Human Services 7

Office of MaineCare Services (OMS)
Federal Changes to SNAP
State Cost Shifting: Increase state administrative cost sharing from 50
percent to 75 percent starting in October 2026 and require states to pay up
to 15 percent of benefits depending on their Payment Error Rate (PER)
starting in October 2027.
• Administrative Costs: Maine’s total administrative costs for SNAP are $26.6 million annually:
o USDA currently reimburses 50 percent of this amount, or $13.3 million
o Maine’s current responsibility of $13.3 million will increase by $6.6 million to roughly $20
million per year.
• When both cost-sharing provisions are combined, the State’s annual SNAP obligation would
increase by $60 million annually within two fiscal years. Flattening or decreasing state revenues
means Maine will be unable to absorb this federal cost shift.
• Benefit Costs: Since SNAP was created, the Federal government has paid 100% of SNAP
benefits, a key component in its ability to mitigate impacts of economic downturns. Beginning
October 1, 2027, states will be required to pay a percentage of SNAP benefits if they have a
Payment Error Rate (PER) above 6 percent. As of FFY24, only nine states had error rates below
6 percent. Maine’s FFY24 error rate was 10.3 percent, below the national average of 10.9
percent. At this percentage, Maine would be responsible for 15 percent of benefits, or
approximately $53 million annually.
• Combined cost-sharing changes will increase Maine’s SNAP obligation by $60 million annually
within two years. However, the households most affected by these cost-shifts generally receive
minimal or zero monthly benefits, so total state benefit outlays may remain largely unchanged.
Further tightening of eligibility criteria or asset limits would require legislative approval and is
likely to raise administrative complexity and error rates – offsetting any marginal savings.

Work Requirements: Applies existing work requirements to more people

and removes current exemptions to those requirements, collectively
impacting over 40,000 current SNAP recipients as soon as this Fall.
• Able-Bodied Adults without Dependents (ABAWD) are required to participate in a combination of
work and/or work program hours for a total of at least 80 hours a month to get SNAP for more
than three months in three years, unless they meet an exemption.
• H.R. 1 extended work requirements for ABAWD to adults between ages 54-64 and to parents of
children who are age 14 and above. This will impact 10,195 adults aged 55-64 with no school-
aged children and thousands of parents with children age 14 and above. These children could
see less in a monthly household benefit if their parents don’t meet the requirements.
• 25,203 people who are housing insecure, 5,669 veterans, and 505 former foster youth will lose
their exemptions and now have to meet ABAWD work requirements.
• Tribal citizens will be newly exempt from ABAWD work requirements.
• Most areas in Maine will no longer qualify for a geographic waiver to the ABAWD work
requirements, effective October 2025. This will result in approximately 2,000 current recipients no
longer being eligible for SNAP, mostly in Maine’s most rural communities.
• The Department will notify the public of the expected implementation date of these
changes and more information through a notice of proposed rulemaking.
• Impacted individuals will receive a notice the month prior to any decrease in benefits.

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Office for Family Independence (OFI)
Elimination of SNAP Education Grant as of September 30, 2025
• Maine received $4.8 million last year to deliver evidence-based nutrition education programing
focusing on “How to eat healthy on a budget” to food insecure Maine people.
• The changes eliminate services that are provided by the University of New England and its
network of sub-contractors that in 2024:
o Provided classroom education to 18,759 youth
▪ 31% reported eating more vegetables
▪ 45% reported starting to read nutrition labels
▪ 17% reported increased physical activity
o Delivered classes to 2,987 adults
▪ 45% reported eating more vegetables
▪ 27% reported starting to shop with a list
o Employed more than 40 staff (nutrition educators and administrative staff)
o Reached 147,549 Maine people through its social marketing campaign
▪ Active campaign channels achieved 2,667,846 hits
▪ An additional 3,585,570 hits were achieved through targeted TV ads

Decreasing Benefit Levels: Changes to the Thrifty Food Plan (TFP) as soon
as this Fall, specific date determined by state rulemaking
• The 2021 update increased average SNAP benefits by 21 percent compared to 2019 benefit
levels and was the first inflation-adjusted significant increase to benefits since 1975.
• The increase in SNAP benefits from the reevaluated TFP kept nearly 2.3 million people out of
poverty in the fourth quarter of 2021, reducing poverty by 4.7 percent. The higher benefits from
the reevaluated TFP reduced child poverty by 8.6 percent.5
• Changes to the TFP include specifying new percentages based on household sizes, setting a
reevaluation date of October 1, 2027, and requiring any future changes be cost neutral.
• As a result of these changes, all SNAP recipients are expected to receive an average of $26 per
month less in SNAP benefits as soon as this Fall.
• The Department will notify the public of the expected implementation date of these
changes and more information through a notice of proposed rulemaking.
• Impacted individuals will receive a notice the month prior to any decrease in benefits.

Elimination of SNAP Eligibility for at least 2,000 Non-Citizen Maine people

who are Lawfully Present in the United States as soon as this Fall, specific
date determined by state rulemaking
• Limits SNAP eligibility to those who reside in the United States and are:
o A citizen
o Lawfully admitted for permanent residence
o Cuban and Haitian entrants
o Allowed to live and work in the U.S. under the Compacts of Free Association (COFA)
• Removes eligibility for refugees those granted asylum, victims of severe forms of human
trafficking, and battered noncitizens, as well as any others not explicitly included in the above list.
These changes will impact over 2,000 Maine people.
• Requires that all non-eligible, non-citizen financial resources in any SNAP household will be
included in eligibility and benefit determination, even for those who are not receiving benefits.
• The Department will notify the public of the expected implementation date of these
changes and more information through a notice of proposed rulemaking.
• Impacted individuals will receive a notice the month prior to any decrease in benefits.

5
https://www.rwjf.org/en/insights/our-research/2025/04/snap-boosts-the-economy-reduces-hunger-and-improves-health.html

Department of Health & Human Services 9

Office for Family Independence (OFI)
Other Proposed Changes
• Limits the SNAP and Low-Income Home Energy Assistance Program (LIHEAP) connection
(known as Heat & Eat) to only apply to households with an older adult or disabled member.
Households without an older adult or disabled member will need to have a heating or air-
conditioning expense to be eligible for the full standard utility allowance (FSUA). 980 Maine
households will likely see a lower utility allowance, ultimately reducing their SNAP benefits and
making it more difficult to meet their basic needs.
• Specifies that LIHEAP-like benefits that are provided by state or local governments will be
countable income for households without an older adult or disabled member.
• Prohibits service fees associated with internet connection from being included in computing the
excess shelter expense deduction, which were previously scheduled to be included starting this
fall. Note: this change doesn’t impact any current SNAP recipients since Maine had not yet
implemented this recent change.

Department of Health & Human Services 10

Office for Family Independence (OFI)
 Note: This document was originally published on May 19 and has been updated to reflect developments
as of July 11, reflecting when Congress passed H.R.1 on July 3 and President Trump then signed the
legislation into law on July 4, 2025. The updated content below incorporates policy changes included in
the final version.

MARKETPLACE July 11, 2025

Overview
The changes in H.R. 1 Budget Reconciliation represent a sweeping shift in policy that dramatically
limits access to health coverage for thousands of Maine people. The provisions collectively will
reduce enrollment significantly, especially among lower-income, rural and healthier/younger
individuals, as well as threaten the operational viability of Maine's State-Based Marketplace,
CoverME.gov. This summary outlines the most critical provisions and their expected impacts.

Prohibition of Income-Related Special Enrollment Periods

The law essentially eliminates the Special Enrollment Period (SEP) for individuals earning up to
150% of the Federal Poverty Level (FPL) by removing eligibility for premium tax credits for anyone
enrolling in this SEP. This will strip coverage options from some of Maine's most financially insecure
residents. Moreover, a new federal rule (described in more detail below) prohibits marketplaces for
having SEPs based on household income up to 150 percent% FPL during the 2026 Plan Year. In
2024 alone, nearly 150 Maine people used this SEP to access coverage. Without this flexibility,
more individuals will become uninsured or delay care, resulting in worse health outcomes and
increased bad debt for providers, particularly in rural areas.

Auto-Renewal and Premium Affordability

The law effectively eliminates automatic health insurance coverage renewals for individuals
receiving premium tax credits (APTC). Instead, enrollees will need to actively re-confirm household
income, family size, and other details each year. The law added language that allows marketplaces
to use data available from third-party sources as part of the verification process and allows the HHS
Secretary to waive these requirements when a household enrolls in coverage during a Special
Enrollment Period due to a change in family size. During the 2025 OEP, nearly 30,000 Maine
people – over half of all APTC recipients – were auto-renewed in plans with APTC. While the
changes made in the final version of the bill could reduce some of the administrative burden related
to the original proposal, this new annual eligibility certification requirement could lead to a large
drop in coverage, especially among those who enroll late or have difficulty navigating complex
eligibility systems.

Additionally, the law removes current caps on how much individuals must repay in tax credits if they
underestimate their income. This may result in surprise tax bills and lower levels of satisfaction with
marketplace coverage. Although the state lacks IRS data to quantify the precise impact, it is likely
that low-income Maine people and those with fluctuating income will be hardest hit.

Department of Health & Human Services 11

Office of MaineCare Services (OMS)
Immigration Status Restrictions
The legislation removes marketplace premium tax credit eligibility for Deferred Action for Childhood
Arrivals (DACA) recipients and for other immigration statuses, including those with temporary
protected status, those who do not qualify for MaineCare due to immigration status, and others
currently deemed lawfully present. Although many of these individuals pay taxes, they will no longer
qualify for the health coverage tax credit. These eligibility changes will discourage enrollment
among immigrant families have a cooling effect on enrollment for any individual concerned about
the review of their citizenship as an application for health care coverage and increase administrative
costs.

Changes to Health Savings Accounts

The bill includes a provision that would expand Health Savings Account (HSA) eligibility by allowing
all bronze and catastrophic plans to be HSA-eligible.

This change provides more flexibility for healthy consumers. However, it also risks shifting more
people into high-deductible plans with greater out-of-pocket costs, increasing the risk of
underinsurance and delayed care. The risk is greater with individuals that have unpredictable health
care needs and are unable to afford the cost exposure prior to meeting the deductible.

While H.R. 1 does not include many provisions that were part of original versions of the bill, such as
shortening the Open Enrollment Period, restricting abortion coverage, reducing the time period for
households to be able to verify income discrepancies in order to enroll in coverage with premium
tax credits, eliminating provisional eligibility, and requiring other burdensome enrollment verification
processes, many of these provisions will still go into effect because they are included in a recently
finalized federal rule.

On June 20, 2025, the Centers for Medicare & Medicaid Services announced the release of the
final Marketplace Integrity and Affordability Rule (CMS-9884-F). This rule includes the following
additional provisions:
• Removal of marketplace eligibility for DACA recipients.
• Income Verification: Self-attestation will no longer be allowed if income data conflicts
with prior tax filings by more than 10% – currently the threshold is 50%. Consumers will
have only 90 days to resolve discrepancies, down from the current 150 days. This
change especially impacts Maine people with seasonal, variable, or self-employment
income, increasing the risk of disenrollment.
• Failure to Reconcile (FTR): Consumers who did not file and reconcile their prior year’s
tax return will lose eligibility for premium tax credits. Although CoverME.gov is working
toward compliance, full implementation by 2026 is unlikely. The provision further
compresses timelines and strains operational capacity.
• Shortened Open Enrollment Period – shorten the Open Enrollment Period from 75 days
or longer to 9-weeks, or 63 days. This provision will likely result in a risk-pool that is less
healthy than a longer Open Enrollment Period and will require significant communication
to members to notify them of the change.

Collectively, these provisions represent a significant rollback of state flexibility and consumer
protections. They increase costs and reduce access – particularly for low-income, rural, immigrant,
and healthier individuals resulting in more Maine people becoming uninsured, delaying needed
care, facing medical debt, and ultimately experiencing poorer health outcomes.

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Office of Health Insurance Marketplace (OHIM)
In Conclusion
Over the next decade, H.R.1 Budget Reconciliation will redirect billions of dollars in federal funds
away from Maine, while transferring additional costs for administration, system upgrades, and
uncompensated care to the state.
Freezes on provider taxes and restrictions on family-planning funding may increase pressures on
safety-net providers, and changes to error-rate penalties and cost-sharing could pose further
budgetary challenges. As a result, thousands of low-income, rural, older adult, and immigrant
residents could see reduced health coverage and food assistance, alongside additional paperwork
and processing delays, potentially affecting the stability of MaineCare and SNAP during a period of
high demand.
Maine DHHS will continue to analyze implementation details, partner with stakeholders, and
manage resources to mitigate these impacts and help uphold access to essential care and nutrition
for all Maine people.

Department of Health & Human Services 13