H.R. 1 and Illinois: What It Means for Healthcare, Medicaid & SNAP
The One Big Beautiful Bill Act (Public Law 119-21), or H.R. 1, signed into law on July 4, 2025, is the biggest federal budget reconciliation package in years. For Illinois, it puts billions in healthcare funding and food assistance at risk. Medicaid financing changes alone could cost the state billions in lost federal revenue, with provider-tax restrictions estimated to reach roughly $2B per year once fully phased in by 2032. Supplemental Nutrition Assistance Program (SNAP) penalty exposure could reach $550M annually. The cuts are real, but as they roll in over several years, the state has money and time to respond, and a new president from either political party could change the picture entirely.
Medicaid: Big Cuts, Long Runway
Illinois’ Medicaid program covers roughly 3 million residents, about 1 in 4 Illinoisans, and costs about $33B a year. It is also an economic engine: Illinois hospitals, doctors, nurses and health systems generate roughly $135.5B for the state economy each year and support 521,000 full-time jobs. In addition to its economic impact, the healthcare industry is an important political stakeholder in every state, not just Illinois. When federal Medicaid dollars decrease, the effects do not stop at patients. The cuts will reach the entire industry, local governments, schools and entire regional economies.
H.R. 1 goes after Medicaid financing in several ways, on a staggered timeline.
- Provider tax restrictions. The law freezes existing provider taxes at their levels at enactment and prohibits new ones. It phases down the federal hold-harmless threshold for expansion states from 6% to 3.5% of net patient revenues, beginning Oct. 1, 2027, with exceptions for nursing facilities and intermediate care facilities. These changes are estimated to cost Illinois roughly $2B per year in lost revenue once the reductions are fully in effect by 2032, with losses ramping up from roughly $1B in the first year of the phase-down.
- State directed payment (SDP) reductions. The Kaiser Family Foundation (KFF) estimates that 40 states currently receive $93B in annual federal Medicaid spending through SDPs, with 84% going to hospital services. Illinois ranks fourth nationally at an estimated $5.1B. Under H.R. 1, new SDPs are immediately capped at or near Medicare payment levels, and existing SDPs must be reduced by 10 percentage points per year starting Jan. 1, 2028, until they hit that cap. The Illinois Hospital Association estimates revenue losses to Illinois hospitals at approximately $3B over five years starting in 2028. Safety net and critical access hospitals are most at risk.
- Work requirements. Beginning Jan. 1, 2027, approximately 700,000 Affordable Care Act (ACA) expansion adults ages 19 to 64 must demonstrate at least 80 hours per month of work, education, volunteering or other qualifying activities to maintain Medicaid eligibility. This is the nearest-term change and the one most likely to affect individuals’ coverage. Illinois estimates 165,000 to 300,000 enrollees could end up losing coverage. There are significant exemptions: parents of children 13 and under, pregnant individuals, veterans with total disability ratings, medically frail individuals and several other groups. States will need to build verification and reporting infrastructure before the January 2027 effective date.
How the state is responding on Medicaid.
In 2025, the General Assembly passed HB 2771, increasing the hospital provider assessment to finance a 65% average increase in net hospital reimbursements: approximately $1.47B in new annual funding. The Centers for Medicare and Medicaid Services (CMS) approved the plan in September 2025. Because HB 2771 was enacted before H.R. 1, the assessment is frozen at its current level, but that protection is temporary. As the federal safe harbor cap phases down from 6% to 3.5% beginning in October 2027, Illinois will eventually be required to reduce its hospital and managed care organization (MCO) assessment rates to stay within the new ceiling. Illinois faces exposure on both fronts, with hospital and MCO provider-tax rates above the incoming 3.5% threshold. The total baseline revenue impact in fiscal year (FY) 2028 alone is estimated at $629M, combining $239M in lost state assessment revenue with the corresponding loss of federal matching funds. HB 2771 buys critical time and keeps the system stable heading into the transition, but its funding will progressively decrease as the cap tightens through 2032. The state was also awarded $193.4M through the new $50B Rural Health Transformation Program created by H.R. 1. Neither of these measures will completely offset the effects of H.R. 1.
Work requirements present a particular fiscal paradox for Illinois. Approximately 441,000 Illinoisans could lose Medicaid coverage by 2034, with 85% of losses concentrated among ACA expansion adults. Notably, 92% of Medicaid recipients already work or otherwise meet the new eligibility requirements, meaning the policy largely creates an administrative barrier rather than a genuine work incentive.
While disenrolling these individuals generates nominal savings, the state retains minimal funding. Because the federal government finances 90% of expansion-adult costs, Illinois would save only about $720M per year even as total Medicaid spending falls by roughly $3.75B annually.
More importantly, people who lose coverage do not stop needing care. Illinoisans will lose access to preventive and primary care services and instead turn to emergency rooms, with higher treatment costs and care that is often uncompensated. The net effect is that Illinois would cover substantially fewer people while gaining limited budget relief, as the modest enrollment savings are likely outweighed by provider-tax revenue losses and the increasing costs of uncompensated emergency care.
SNAP: New Cost-Sharing Hits a Vulnerable Program
SNAP served more than 1.8M Illinoisans and distributed $4.7B in benefits in FY2025. H.R. 1 rewrites the cost structure, and Illinois’s high error rate makes the state vulnerable to these changes.
At current enrollment levels of approximately 1.565M individuals, the Civic Federation estimates that Illinois could face approximately $550M in annual state costs under the new error rate penalties alone. Here is how the law gets there:
- Administrative cost shift. Starting Oct. 1, 2026, the federal share of SNAP administrative costs drops from 50% to 25%, an estimated $80M annual increase for the state.
- Error rate penalties. Beginning in FY2028, states with SNAP payment error rates above 6% will, for the first time, be required to share in the cost of SNAP benefits. The amount a state must pay depends on its payment error rate (PER):
- PER between 6% and 8%: State pays 5% of SNAP benefit costs
- PER between 8% and 10%: State pays 10% of SNAP benefit costs
- PER above 10%: State pays 15% of SNAP benefit costs
- Illinois’s PER is well above the highest threshold. According to the most recent data released by the U.S. Department of Agriculture (USDA) on June 24, 2026, Illinois’s SNAP PER increased from 11.56% in FY2024 to 14.67% in FY2025, the sixth-highest rate in the country. At 14.67%, Illinois would fall into the 15% cost-sharing tier. The national average PER declined slightly to 10.62%. Ten states had PERs below 6% and, therefore, would not owe any share of SNAP benefit costs.
- Penalty timeline. Because Illinois’s FY2025 error rate exceeds the roughly 13.33% threshold for delayed implementation, the state qualifies for a one-year delay: penalties would not begin until FY2029, beginning Oct. 1, 2028. If the FY2026 error rate also exceeds that threshold, Illinois may qualify for a second year of delay to FY2030. Given the upward trend, that second delay is plausible, potentially giving the state a full two-year window before penalties begins.
- Eligibility restrictions. Work requirements took effect Feb. 1, 2026, limiting nonexempt individuals who don't meet them to three months of benefits within a three-year period. An estimated 150,000 Illinois households could be affected. Separately, eligibility was narrowed as of April 1, 2026, excluding most refugees, asylum seekers and certain survivors of trafficking and domestic violence.
What Comes Next
While, these are significant fiscal problems, the timeline is staggered and that matters.
|
Change |
Effective Date |
|
SNAP work requirements |
Feb. 1, 2026 (in effect) |
|
SNAP eligibility narrowed (excluding refugees, asylum seekers) |
April 1, 2026 (in effect) |
|
SNAP administrative cost shift (50% → 25%) |
Oct. 1, 2026 (in effect) |
|
Medicaid work requirements |
Jan. 1, 2027 |
|
Provider tax restrictions begin |
Oct. 1, 2027 |
|
SDP reductions begin (10 ppts/year) |
Jan. 1, 2028 |
|
Illinois SNAP error rate penalties (earliest) |
FY2029 (Oct. 1, 2028) |
|
Deepest Medicaid financing cuts fully phased in |
~2032 |
Illinois enters this stretch in the strongest fiscal shape it has been in for years. The state has received 12 credit rating upgrades under Gov. Pritzker. In late August and early September 2026, Moody’s raised Illinois’s bond ratings to A1, its highest in nearly 15 years, and S&P upgraded it to an ‘A’ with a stable outlook. The state has eliminated a nearly $17B backlog of unpaid bills and built a rainy-day fund of $2.5B. It also collected roughly $1B in unallocated surplus revenue in FY2026. And the FY2027 budget assumes zero revenue growth, yet first-quarter receipts are already running 7% above projections.
This cushion gives the state real room to absorb near-term costs while the bigger changes will occur in the next presidency.
A new president and Congress could scale back, restructure or repeal these provisions. A new administration could also use executive authority to delay implementation, grant waivers or simply decline to aggressively enforce certain requirements. The 2028 presidential election happens before most of the significant cuts take effect. If the White House and Congress change hands, much of this law could look very different before it fully phases in. That said, some changes, such as coverage losses from work requirements or hospital closures driven by funding cuts, create tangible effects that are difficult to undo.
The fiscal effects from H.R. 1 during this presidential term are significant. But the deepest structural changes are still a few years out, and a new administration could change the trajectory entirely.
Illinois has resources, lead time and legislative tools. What it does within the next 18 months, and what happens in the 2028 election, will determine how many of these changes actually land.
McGuireWoods Consulting’s Illinois state government relations team continues to monitor the effects of H.R. 1 closely.
For further questions, contact Tom Londrigan or Lauren Hund.