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+# H.R. 1 Medicaid working assumptions
+
+These assumptions reflect how OSCER currently interprets H.R. 1 statute in the absence of complete CMS rulemaking. They will be revisited and updated as the interim final rule (due June 1, 2026) and subsequent guidance is issued. They are not legal determinations.
+
+_This is a working document and will be updated continuously_
+
+
+## Time and reporting periods
+- Month’ means a calendar month, not a rolling 30-day period (unless later guidance (unless later guidance defines otherwise).
+
+## Compliance pathways
+- Income and hours are two independent, equivalent compliance pathways and they cannot be combined or mixed within a single reporting month. A member must satisfy the full requirement through one path: either 80+ hours of qualifying activity OR $580+ in monthly income. A member cannot combine partial hours and partial income (e.g., 40 hours + $290 in income) to meet the threshold.
+- Quarterly wage data (QWD) satisfies the income compliance pathway when quarterly wages imply at least $580/month. If quarterly wages are ≥ $1,740 (≥ $580 × 3 months), OSCER can flag the member as automatically compliant (pending policy confirmation)
+
+## Exemptions
+- Exemption categories are state-configurable. The statute defines a floor of required exemptions; states may recognize additional categories. OSCER does not hardcode a single national exemption list.
+- States may accept self-attestation for exemptions without requiring documentation. Whether documentation is required is a state-level policy decision, not an OSCER default. OSCER supports both paths: attestation-only and document-verified.
+-  Medically frail includes individuals with mental health conditions and substance use disorders, not only physical disabilities. This aligns with the KFF/CBPP interpretation and the statute's language. OSCER's screener and exemption logic reflect this broader definition.
+- If a member is already compliant with SNAP or TANF work requirements, they are excluded from the Medicaid CE requirement. OSCER should be able to accept a cross-program compliance flag from the state's eligibility system to support this path.
+
+## Policy gaps, flagged as open questions
+The following assumptions are less certain and should be revisited with CMS or when the interim final rule is published (due June 1, 2026)
+
+- How volunteer/community service hours should be verified in the absence of an institutional record-keeper is not yet defined in guidance.