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Through hardships, to the brightest path.

New Rules, New Risks: Medicaid in Puerto Rico Is Changing

  • Writer: Astra
    Astra
  • Oct 7
  • 2 min read

Graphic with Astra logo and title text: ‘Focus: What’s Happening Right Now — Puerto Rico’s Medicaid Program Faces a Complex Policy Shift.’ Dark teal background with star-like dots and orbit-style lines in a cosmic theme.

The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, introduces significant compliance requirements for Puerto Rico’s Medicaid program. While the territory is exempt from some of the stricter mandates placed on U.S. states, it now faces a new wave of federal obligations that will impact providers, plans, and health systems alike.

For Astra’s clients and partners, the path forward requires proactive planning, timely upgrades, and a clear understanding of what’s changing.


Key Compliance Deadlines for Medicaid in Puerto Rico

  • January 1, 2026 – New home- and community-based services (HCBS)must be launched to qualify for enhanced federal matching funds.

  • FY 2026–2027 – Planning period to implement quarterly provider screenings using the Death Master File.

  • October 1, 2029 – Deadline to connect to the new federal duplicate enrollment data hub.


Compliance Is Expanding—Here’s What’s Required

Puerto Rico’s Medicaid program must now prepare to:

  • Screen providers quarterly to ensure deceased individuals are not listed as active in the system.

  • Establish automated monthly data feeds to identify duplicate Medicaid enrollment across jurisdictions.

  • Comply with new rules under the PERM program—where error thresholds and financial penalties become stricter starting FY 2030.

  • Adopt SAVE-based eligibility verification for lawfully present non-citizens, aligning with federal guidance from USCIS.


What’s Not Required—For Now

Puerto Rico is not subject to certain mandates facing the states, including:

  • Medicaid work requirements or community engagement policies

  • Biannual eligibility redeterminations

  • Medicaid cost-sharing for expansion populations

  • Long-term care staffing standards

  • Federal caps on state-directed payment rates


You can explore our Medicaid compliance overview to learn how Astra supports partners navigating these types of exemptions and mandates.


A Time-Sensitive Opportunity: HCBS Expansion

OBBBA introduces a flexible new pathway to expand Home and Community-Based Services through a Section 1915(c) waiver. This provision aligns with Puerto Rico’s ongoing efforts under its Money Follows the Person (MFP) grant.


However, to access enhanced federal support, expenditures must begin by January 1, 2026. Learn more about Section 1915(c) waivers and how Astra can assist in navigating the waiver process.


Takeaway

The OBBBA marks a turning point for Puerto Rico’s Medicaid program. New compliance requirements, fixed funding caps, and time-sensitive opportunities are converging—demanding both operational readiness and strategic foresight.


Need a quick reference?


Download our one-pager → Includes key dates, compliance checkpoints, and opportunity timelines.


Learn More or Start a Conversation


👉 Visit www.astrapr.com to explore our advisory services, client stories, and upcoming training sessions.


📩 Have a question? Contact us to speak with our experts.


About Us

At Astra, we guide leaders toward the brightest path with precision and care. We deliver strategic solutions in grant management, compliance, and financial alignment—helping public and private organizations operate with autonomy, clarity, and sustained impact.

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