MCO Tax Six-Month Extension Cliff: HR 1 Uniform-Rate Rule Could Force Restructure or Revenue Loss by Dec 31, 2026

California's MCO Tax violates H.R. 1's new uniform-rate rule. CMS approved a transition-period extension through June 30, 2026. The Governor's January Budget assumes a 6-month additional extension to Dec 31, 2026 that has NOT yet been granted. May Revise must address what happens if CMS denies the extension OR what the post-Dec restructured tax looks like. This directly affects Prop 35 funding (~$264M in FY26-27 already programmed for Medi-Cal cost increases plus FQHC PPS rate enhancements). Strategic implication for FQHC CFOs: Prop 35-funded line items in your FY26-27 budget face material reset risk if MCO Tax restructures or sunsets. Specifically watch for: (1) FQHC PPS supplemental payment continuity, (2) Prop 35 FQHC carve-out preservation, (3) any revenue replacement mechanism (e.g., provider tax expansions) that might shift cost burden to FQHCs. Pairs with Mobile Crisis Services optional-benefit shift and the broader BHCIP funding reshuffle as the May 2026 Medi-Cal financing ecosystem stress test.