Please submit comments to the agency or primary contact person listed below, before the deadline.
Rule Details
Rule Number:
26P021
Title:
Health Benefits Eligibility and Enrollment Rule, Eligibility Standards (Part 2).
Type:
Standard
Status:
Proposed
Agency:
Agency of Human Services
Legal Authority:
3 V.S.A. 801(b)(11); 33 V.S.A. 1901(a)(1) and 1810
Summary:
This proposed rule amends part 1-3, 5 and 7 of the 8-part Health Benefits Eligibility and Enrollment (HBEE) rule. Parts 1,2,3,5 and 7 were last amended effective January 1, 2026. Substantive revisions include: newly requiring certain adult Medicaid applicants and enrollees demonstrate compliance with work and community engagement rules as a factor of eligibility; reducing the retroactive Medicaid coverage period from three months to one month for Adult coverage group enrollees and two months for all other enrollees; restricting non-citizen eligibility for both Medicaid
and Qualified Health Plan premium tax credits and adding a new category of "eligible non-citizen" to clarify which individuals remain eligible; adjusting the renewal period from 12 to 6 months for Medicaid enrollees in the Adult coverage group; shortening the annual open enrollment period from November 1st-January 15th to November 1st - December 15th. All of these substantive revisions are required by federal law.
Persons Affected:
Applicants and enrollees of Medicaid and Qualified
Health Plans with financial assistance; Health law, policy, and related advocacy and community-based organizations and groups including the Office of the Health Care Advocate; Health care providers; Eligibility and enrollment assisters, including agents and brokers; The Agency of Human Services including its departments; The Vermont Department of Labor.
Economic Impact:
The Agency of Human Services (AHS) anticipates that many of the proposed changes to HBEE carry an economic impact. Changes to eligibility criteria for certain non-citizens will result in reduced enrollment in Medicaid and Qualified Health Plans. AHS anticipates that increased frequency of renewals for enrollees in the Medicaid Adult coverage group, as well as the introduction of new work and community engagement requirements, will reduce enrollment in Medicaid. The change to retroactive Medicaid periods represents a reduction in coverage for eligible Medicaid enrollees. Overall, these changes will reduce total Medicaid enrollment, increase the number of uninsured people in Vermont, increase financial hardship on individuals and families impacted, and increase the burden of uncompensated care on healthcare providers and systems. The implementation and ongoing administration of these changes represent significant additional costs to the state. These costs have been quantified in a $5 million dollar project budget for implementation.
Posting date:
Jul 15,2026
Hearing Information
Information for Hearing # 1
Hearing date:
Location:
Agency of Human Services
Address:
Waterbury State Office Complex, 280 State Drive, Conference Room Cherry A
City:
Waterbury
State:
VT
Zip:
05671-1010
Hearing Notes:
Also Virtual Hearing-Phone or Microsoft Teams Call in (audio only) (802) 828-7667; Conference ID:564 838 973# https://teams.microsoft.com/meet/233297609116516?pleCIIA3r4n2nvslTbO
Virtual via MS Teams
https://teams.microsoft.com/meet/233297609116516?pleCIIA3r4n2nvslTbO
Call in (audio only) (802) 828-7667; Conference ID: 564 838 973#
