Short answer: For gifts made on or after 02-08-2006, the penalty starts on the first day of the month the person would otherwise be eligible for Medicaid and receiving long-term care, not when the gift was made. So it begins just when the money has run out.
The penalty clock starts only once the person has applied, is in care (or approved for waiver care), and meets every other eligibility rule, including being down to the resource limit. HHSC uses the first day of the month of the medical effective date.
That is what makes a poorly timed gift dangerous. A parent who gives $50,000 to a child and two years later enters a nursing home and spends down to $2,000 will then face about 190 days (at the $262.37 per day 2025 divisor) when Medicaid will not pay, and the family’s own money is already gone.
For a person already on Medicaid who later makes a transfer, the penalty starts the first day of the month of that transfer. Either way, the person or facility can ask for an undue hardship waiver, but it is not automatic.