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H.R. 1 Readiness Tracker Update: Strain Is Building Before the Work Reporting Requirements Clock Starts

As states prepare to implement work reporting requirements, we are closely monitoring Medicaid and CHIP performance indicators on our H.R. 1 tracker. The latest Q1 2026 data show the status of state eligibility systems and processes right before most states start notifying enrollees about the requirements. The short answer: already strained and getting worse.

Renewals are gradually backing up. Each month, states report to CMS how many renewals were due in the month and how many were not processed (or acted on) by the last day of the month. Based on those initial reports, the national median share of pending renewals rose for three straight quarters – from 4.3% in Q2 2025 to 5.3% in Q3, 6.2% in Q4, and 7.0% in Q1 2026. Thirty states, including Washington, D.C., saw an increase in Q1 2026 over the prior quarter. North Dakota’s share of pending renewals more than doubled, from 11.2% in Q4 2025 to 24.8% in Q1 2026, its highest rate since reporting began in July 2023. Levels are still far below the unwinding period, when the median was 18% in Q3 2023, but the post-unwinding decline has clearly reversed.

States later report an update to CMS showing how many of those renewals were still unresolved after three months. That number is much lower as most cases do get resolved. But the updated data doesn’t tell us whether states are keeping pace with the new renewal work arriving each month, which is what we look at here. A high share still pending at the end of any given month suggests the state may be experiencing significant system issues or having difficulty keeping up with the workload. These renewal cases are waiting in a queue until a staff worker is available to process them, and in the meantime, creating more work when individuals call for information.

Applications are also taking longer to process. The national median share of individuals whose new applications took longer than 30 days to process rose to 21.9% in Q1 2026 – up from 11.5% the prior quarter and 17.8% in the same quarter a year earlier, the highest first quarter since 2024. In North Dakota (69.3%), Alaska (65.8%), North Carolina (50.8%) and Georgia (50.2%), more than half of applicants waited longer than 30 days for their application to be processed.

The value of administrative capacity is best illustrated by what happens when some of it disappears. During the unwinding period, states used section 1902(e)(14)(A) waivers to increase automatic renewals – like renewing Medicaid coverage based on SNAP eligibility –  and reduce administrative barriers. These are known as ex parte renewal rates, relying on available data rather than more paperwork and document submissions. Several of those waivers, which expired on June 30, 2025, continue to be available as state plan options, although some states are not adopting or continuing to use them. This matters because higher ex-parte renewal rates are associated with fewer procedural disenrollments – when eligible individuals lose coverage due to paperwork or administrative issues rather than being determined to be ineligible. As these waivers expire, some of these flexibilities may no longer be in place. That means a renewal that the state could have completed on its own becomes a form that must be mailed out, returned and processed by hand. It brings more work for caseworkers who might be already behind on their work tasks and one more deadline an enrollee has to be notified about, understand, and meet, often while working a shift or having moved since the state last had their address.

In the first full quarter after the temporary unwinding waivers expired, ex parte renewal rates declined dramatically in two states that didn’t continue most of these e-14 flexibilities: New Hampshire’s ex parte rate fell from 74.4% in Q2 2025 to 26.8% in Q3, and California’s from 78.0% to 35.7%. Twenty states experienced ex parte rate declines over the same period, but no others fell by more than 10 percentage points.

Renewals that can’t be completed with data on hand become onerous red tape and paperwork difficulties become procedural terminations. California’s share of beneficiaries disenrolled for procedural reasons increased from 65.2% in Q2 2025 to 82.4% in Q3 2025, and New Hampshire’s from 80.4% to 83.8%. Overall renewal rates fell from 90.8% in Q2 2025 to 69.2% in Q3 2025 in California and from 86.6% to 64.2% in New Hampshire.

When renewals require action, such as uploading extra documents or completing more paperwork, enrollees often call the state’s call center for assistance. Q1 2026 wait times rose in 36 states out of 49 states and D.C., and rate of abandoned calls rose in 37 of 49 states reporting and D.C. The median call wait time increased from six to seven minutes and the call abandonment rate also increased from 7.1% to 9.2%. A caller on average waited for one hour  and 18 minutes in Oklahoma, one hour in Nevada, 59 minutes in Idaho, and 57 minutes in Georgia. Hawaii leads with an average wait time of 193 minutes in Q1 2026. In 13 states, more than one call in five is abandoned. That rate was 43.9% in North Dakota, 42.7% in Montana and 42.0% in Minnesota.

Long hold time falls hardest on the people Medicaid covers, as my colleague Tricia Brooks warns when she first dubbed call center statistics the canary in the coal mine. Enrollees working frontline shifts in retail, service and hospitality can’t stay on hold while doing something else. Enrollees without an unlimited cell plan are paying for every minute they wait. A 40-minute hold might be an inconvenience for some callers and impossible for many others.

The Q1 2026 data is not reassuring as states begin implementing work reporting requirements and before every state absorbs the administrative work that comes with many of the other H.R. 1 Medicaid cuts. Processing of renewals is slowing down and backing up. The share of enrollees losing coverage over paperwork rather than being ineligible is steadily increasing putting them at serious risk of becoming uninsured. Call centers’ response times are degrading and more consumers are unable to stay on hold. As the work reporting requirement implementation workload, not to mention semi-annual renewals, arrives over the next months, it will land on top of strained systems and eligibility workers that are already, in a number of states, struggling with the work they have.

We’ll keep updating the tracker as states further implement work reporting requirements and keep watching these indicators closely.

Note: Because CMS retroactively updates the sources we use for the tracker, the figures in this blog reflect CMS data as published in July 2026. You can read more about our methodology here.