OBBBA Updates: Recent CMS Guidance and State and Provider Responses

• December 12, 2025

As 2025 closes, the implications of the One Big Beautiful Bill Act (now rebranded as the Working Families Tax Cut Act) on Medicaid continue to ripple through the health care industry. CMS has issued major guidance, and state Medicaid agencies and health care providers are scrambling to implement this guidance at an operational level. Harsh P. Parikh, Partner, Nixon Peabody LLP, Lloyd A. Bookman, Founding Partner, Hooper Lundy & Bookman PC, and Anne Winter, Senior Managing Director, FTI Consulting, provide updates on the community engagement/work requirements, beneficiary eligibility and coverage requirements, funding and payment reforms, and the Rural Health Transformation Program. They also discuss what challenges might be on the horizon in 2026 and the role of technology.