VOLUME 29

Better Prompting May Help Reduce AI Hallucinations, False Vaccine Claims Spread, and Industrial Solvent Promoted as Hidden Cancer Cure


Summary

This volume highlights new research showing that certain prompting techniques can help reduce the risk of AI chatbots amplifying false medical information when users include fabricated terms in their queries. It also examines false claims linking vaccines to sudden infant death syndrome and the promotion of the industrial solvent dimethyl sulfoxide as an allegedly suppressed cancer cure despite a lack of clinical evidence. Lastly, it explores misunderstandings among first responders about the risks of overdose from fentanyl exposure and ongoing myths about sunscreen safety.


The Problem Isn’t Trust in Vaccines, It’s That People Don’t Know Who to Trust

In last week’s “Beyond the Data” column, KFF’s CEO, Dr. Drew Altman, draws on years of KFF polling about vaccines and writes that uncertainty about vaccines stems not from lack of confidence in their safety but from eroding trust in sources of health information, leaving many unsure where to turn for reliable guidance. As Altman notes in the column, just 16% of the public believe mRNA vaccines are unsafe, but only 14% of the public say they have a lot of trust in federal health agencies like the Centers for Disease Control and Prevention (CDC) and Food and Drug Administration (FDA) to ensure the safety and effectiveness of vaccines. The result: the majority of Americans are uncertain and unsure what to believe.


AI & Emerging Technology

Chatbots Prone to Hallucinations When Prompted with Fabricated Terms

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Artificial intelligence (AI) chatbots can convincingly amplify false claims when false medical information is embedded within user questions, according to new research published in Communications Medicine. The study, conducted by researchers at Mount Sinai Medical Center, tested how leading large language models (LLMs) respond when fictional medical terms are included in patient scenarios. The researchers created 300 hypothetical cases containing fabricated diseases, symptoms, or medical tests to evaluate whether chatbots would identify and reject the false information. 

Without additional safety prompts, the AI responses regularly contained hallucinations, a phenomenon that occurs when an LLM fabricates false information instead of relying on evidence. In 65.9% of responses, the chatbot expanded on the fictional medical details, generating confident explanations about treatments for non-existent conditions like “Faulkenstein Syndrome.” Researchers suggested that users may unknowingly include false information in their health queries to AI chatbots, from unreliable sources or misremembered medical terms, and may receive responses that not only repeat but expand upon those inaccuracies.

The study also demonstrated, however, that including additional safeguards in the prompt could reduce this risk. By asking the AI models to use only clinically validated information and acknowledge uncertainty, the rate of hallucinations dropped to 43.1%. The researchers suggested that additional safeguards built into AI models, or included in user prompts, help mitigate the risks of chatbots amplifying false health information. The findings demonstrate the need for further education about AI, including around proper prompting techniques. An August 2024 KFF poll found that most adults (56%) were not confident in their ability to tell the difference between what is true and false when it comes to information from AI chatbots. Users may benefit by developing new prompting strategies, particularly when using AI for health information where falsehoods can cause particular harm. Framing prompts with accurate, verified details, or including safeguards in the prompts, could help prevent chatbots from repeating false information, enhancing their reliability and usefulness.


Recent Developments

False Claims Link Vaccines to Sudden Infant Death Syndrome

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Widely-shared social media posts in early August repeated unsubstantiated claims that routine childhood immunizations are associated with sudden infant death syndrome (SIDS). The claims circulated online this summer following the publication of a review, authored by a researcher who has previously published studies claiming that vaccines are unsafe, that alleged without evidence that vaccines cause SIDS. One X user, with nearly 800,000 followers, falsely alleged that children who died of SIDS were killed by the vaccine industry. Another account, with more than 100,000 followers, called for a ten-year ban on all vaccines, implying that such a ban would lead to “a society without SIDS” and other illnesses like cancer and autism.

Claims of an association between childhood vaccinations and SIDS have persisted for decades, largely citing the temporal association between the recommended vaccination schedule and incidence of SIDS. Cases of SIDS peak around 2-4 months of age, coinciding with the timing of recommended early childhood vaccines. Multiple large-scale studies, though, have found no causal link between childhood vaccines and SIDS. Research has identified multiple factors that may contribute to SIDS risk, including sleep position, maternal smoking, and premature birth, but vaccination is not among them. Rates of SIDS sharply declined after the American Academy of Pediatrics (AAP) introduced safe sleep guidelines for infants, then stabilized in the 2000s during the same timeframe that the childhood vaccination schedule expanded. Some studies have found that vaccinations may in fact be associated with a lower risk of SIDS. 

Polling Insights: Recent KFF polling has found that notable shares of parents are coming across vaccine-related content on social media. In KFF’s July Tracking Poll on Health Information and Trust four in ten parents (41%) reported seeing information about vaccines on social media in the past 30 days. Previous KFF polling has found that about a third of parents (36%) say they are “not too confident” or “not at all confident” that they can tell what is true versus what is false when it comes to information on social media.

As parents are exposed to vaccine information online, the July Tracking Poll also found that many express distrust in the CDC and in local public health departments when it comes to providing reliable information about vaccines. Overall, four in ten parents say they trust the CDC “not much” or “not at all” to provide reliable information about vaccines and a similar share (38%) express distrust towards their local public health department.

About Four in Ten Parents Report Little to No Trust in the CDC and Their Local Public Health Department To Provide Reliable Vaccine Information

Dimethyl Sulfoxide, An Industrial Solvent, Promoted as Suppressed Cancer Cure

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Some influential X accounts with large followings have promoted dimethyl sulfoxide (DMSO), an industrial solvent and byproduct of paper production, as a “miracle cure” for a range of health issues, often portraying past regulatory restrictions on the substance as evidence of a deliberate suppression of an effective treatment. Social media posts in late July and early August have claimed that the solvent can treat conditions including blindness, tinnitus, skin issues, and cancer. One X account, with more than 1.8 million followers, described a combination of DMSO and the histologic stain hematoxylin as “The 50-Year-Old Cancer Miracle Hiding in Plain Sight” and said that the FDA “chose to bury the evidence.” Other accounts also presented unsupported claims about DMSO as a cancer cure as evidence of a conspiracy, including one with more than 300,000 followers who claimed that the FDA banned the substance despite knowing that it “cured cancer” and “made chemo more likely to work.”

DMSO, which penetrates the skin quickly and is used in some transdermal drug delivery systems, was tested in the 1960s as a pain reliever, but trials were halted after research showed abnormal changes in the eyes of laboratory animals. Research has since continued into DMSO’s potential for pain relief, including for pain from osteoarthritis, but has yielded inconsistent results. The FDA has approved DMSO for treating symptoms of interstitial cystitis, which remains the only FDA-approved use of the substance. While its effectiveness in treating cancer has also been investigated, claims that it is a “cure” overstate the available evidence. Some research in laboratory settings has shown that it may have anti-cancer properties, but other studies have found it may increase the rate at which cancer cells multiply, and no large-scale clinical trials have demonstrated its effectiveness for treating cancer in humans. DMSO has also been shown in some research to adversely interact with effective cancer treatments, including platinum-based chemotherapy drugs like cisplatin, carboplatin, and oxaliplatin.

It has nonetheless been promoted by alternative medicine advocates for decades, and some science communicators have theorized that the FDA’s effective ban of the chemical may have contributed to advocacy for its use. The substance’s promotion as a cancer cure, despite a lack of evidence, may cause patients to delay treatment, which is known to lead to higher mortality rates. Its popularity mirrors unsupported claims about ivermectin’s ability to treat cancer and demonstrates the potential for unproven and potentially harmful treatments to gain attention as trust in health authorities declines.

Police Video Highlights Ongoing Misunderstandings About Fentanyl Overdose Risk

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Widespread misunderstandings about brief skin contact with fentanyl continue to shape public perception and emergency protocols, despite a decline in opioid deaths that began in mid-2023 and continued through 2024.In early August, a video of a police officer collapsing after handling evidence during an arrest was widely shared on social media, contributing to discussion about the risk of fentanyl exposure among law enforcement. According to the local sheriff’s office, the officer handled a dollar bill containing fentanyl without gloves and was administered naloxone and transported to a local hospital. The sheriff’s description has not confirmed fentanyl as the cause, but it has reinforced misconceptions about the drug, with some commenters falsely suggesting that brief skin contact with fentanyl could cause an overdose. A former narcotics officer repeated the claim on cable television, saying that merely touching fentanyl “could kill someone.” Others, though, including an X user who identified himself as a medical doctor, stated that physical absorption of fentanyl through such brief contact was not possible.

The misunderstanding that brief skin contact with fentanyl can cause an overdose can be traced to a 2016 Drug Enforcement Administration (DEA) video that warned law enforcement officers that such contact could be fatal. Fentanyl can be absorbed through the skin, but a joint statement from the American College of Medical Toxicology (ACMT) and the American Academy of Clinical Toxicology (AACT) clarified that small, unintentional skin exposures to fentanyl powder or tablets are “very unlikely” to cause significant opioid toxicity. According to the statement, it would take 14 minutes with both hands covered with high-absorption fentanyl patches to receive a therapeutic dose. Risk may be greater for workers in certain high-risk situations, like a drug storage or distribution facility where the potential for longer duration exposure is higher, and the National Institute for Occupational Safety and Health (NIOSH) has recommended higher levels of personal protective equipment (PPE) when larger quantities may be encountered. 

Studies have found no confirmed cases of fatal overdoses among first responders due to contact with the drug, and there have been no documented cases of harm from incidental exposure. Still, the perceived risk among first responders remains high, and misunderstandings about the potential of accidental overdose have shaped emergency response protocols. These concerns may result from conflating brief contact during routine emergency calls with prolonged, high-concentration exposures which carry higher risks. A KFF Health News article reported that these misconceptions may have contributed to some first responders being warned to proceed with caution when responding to an overdose. This has prompted concern among some public health advocates that misunderstandings of risk could lead to delayed interventions such as CPR and rescue breaths, techniques that are recommended by the Substance Abuse and Mental Health Services Administration (SAMHSA) as essential steps in responding to opioid overdoses. 

Sunscreen Claims Persist as UV Protection Remains Important

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Misleading claims that sunscreen is ineffective or toxic have circulated on social media through late summer, with some influencers promoting the idea that chemical sunscreens cause more harm than sun exposure itself. One post, from an account with more than 1.1 million followers, claimed that an increase in melanoma rates was associated with the “toxic chemicals” found in commercially available sunscreen. Others promoted alternative sun protectants, like beef tallow, and claimed that vitamin D from sun exposure helped reduce cancer risk. 

Claims that ingredients in sunscreen are toxic may have originated with a 2020 study that found some chemical ingredients, including oxybenzone and avobenzone, were systematically absorbed by the body in concentrations that exceed the FDA’s limit for requiring further safety testing. The FDA has requested further safety data on these chemicals, but the agency has noted that the fact that an ingredient is absorbed does not mean it is unsafe, nor does its request for additional information. There has been no conclusive evidence that these chemicals are harmful, and dermatologists have noted that they have been safely used for decades. The FDA continues to recommend the use of sunscreen, along with other sun-protective measures, like limiting time in the sun. Some posts also referenced recent recalls of sunscreen products containing benzene, a known carcinogen, incorrectly associating it with oxybenzone and avobenzone. Melanoma diagnosis rates have risen alongside increased use of sunscreen, but this trend also coincided with greater public awareness and improved diagnostic tools. Exposure to ultraviolet (UV) radiation from sun exposure is a known risk factor for developing skin cancers like melanoma, and trials have shown that regular use of sunscreen significantly reduces this risk. There is no evidence that vitamin D reduces the risk of skin cancers, and evidence shows that regular sunscreen use does not cause vitamin D deficiency.

Ongoing myths about supposed harms of sunscreen may lead some to discontinue use, resulting in higher rates of the most common and preventable forms of cancer. UV rays remain a year-round concern, as fall and winter months can still present significant UV exposure. Damage from sun exposure is cumulative, and contributes both to skin cancer risk and accelerated aging. The FDA recommends use of broad spectrum sunscreens with SPF values of 15 or higher. 

About The Health Information and Trust Initiative: the Health Information and Trust Initiative is a KFF program aimed at tracking health misinformation in the U.S., analyzing its impact on the American people, and mobilizing media to address the problem. Our goal is to be of service to everyone working on health misinformation, strengthen efforts to counter misinformation, and build trust. 


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The Monitor is a report from KFF’s Health Information and Trust initiative that focuses on recent developments in health information. It’s free and published twice a month.

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Support for the Health Information and Trust initiative is provided by the Robert Wood Johnson Foundation (RWJF). The views expressed do not necessarily reflect the views of RWJF and KFF maintains full editorial control over all of its policy analysis, polling, and journalism activities. The data shared in the Monitor is sourced through media monitoring research conducted by KFF.

Status of State Medicaid Expansion Decisions

Published: Aug 26, 2025

The Affordable Care Act’s (ACA) Medicaid expansion expanded Medicaid coverage to nearly all adults with incomes up to 138% of the Federal Poverty Level ($21,597 for an individual in 2025) and provided states with an enhanced federal matching rate (FMAP) for their expansion populations.

To date, 41 states (including DC)   have adopted   the Medicaid expansion and 10 states   have not adopted   the expansion. Current status for each state is based on KFF tracking and analysis of state expansion activity.

These data are also available in a table format. The map may be downloaded as a Powerpoint.

Status of State Action on the Medicaid Expansion Decision
Key States with Expansion Activity

Medicaid Expansion Resources

Charting the Way Forward: New Efforts to Advance Electronic Health Information Sharing

Published: Aug 26, 2025

In July 2025, the Trump administration announced a new effort (“Making Health Tech Great Again”) towards health data interchange (referred to in this brief as “interoperability”). This announcement accompanied voluntary commitments from more than 60 providers, payers, and software companies—vendors of electronic health records (EHR) systems, health care analytics platforms, and those traditionally outside the realm of health care, such as artificial intelligence (AI) companies. The announcement focused on two concepts: establishing (1) a Centers for Medicare and Medicaid Services (CMS) “Interoperability Framework,” which refers to a set of criteria and other agreements; and (2) “CMS Aligned Networks,” which are networks of entities that voluntarily agree to adhere to the Interoperability Framework and other agreements that support a standardized system to share information electronically. The new ecosystem would serve users—including providers, health insurance plans (“payers”), and patients—who would connect through applications (or “apps”) or other software. These efforts are intended to facilitate more seamless sharing of health information between these users, and to increase the availability of patient-facing digital health tools. This issue brief examines the new initiative, provides an overview of key health information technology (IT) laws and regulations, and highlights some challenges to health data interoperability.

What Is Interoperability?

In general, interoperability refers to the capability for different technology systems to communicate with each other and share information, even if those systems were made by different companies. In the health care context, interoperability enables different health care providers, hospitals, health insurers, health apps, and patients to efficiently and securely share a broad array of electronic health information without special effort. For example, say a patient moves across the country and finds a new doctor. With interoperability, the patient’s new doctor should be able to quickly and securely retrieve the patient’s medical history electronically. Without interoperability, the doctors might have to send faxes or make phone calls to exchange that information, which could delay care.

Interoperability requires standardization of the information that is shared so that it is in the same format and can be passed seamlessly between unaffiliated systems. For example, a standard “Continuity of Care Document” (CCD) contains a summary of specific clinical information about a patient that can be sent electronically to a patient’s regular doctor after being hospitalized so that the doctor is aware of why the patient was hospitalized, what care was provided, what medications the patient was given, and other important clinical information. These CCDs may be made available to an organization facilitating exchange of electronic health information (a “health information exchange”) that coordinates aggregation and distribution of health information, and sent to a health care provider, for example.

Electronic information sharing is not limited to the movement of clinical information between patients and providers but also includes the sharing of administrative information between these entities and payers to determine whether a claim for benefits, including prior authorization, is covered by the plan, or to make information available about a plan’s provider network.

What is the New CMS Interoperability Framework?

CMS issued a request for information (RFI) in May 2025 seeking input on ways to advance a seamless, secure digital health infrastructure. Based on the input received from the RFI, CMS announced its voluntary new Interoperability Framework in July 2025 and reported that more than 60 private sector entities had agreed to participate. While full specifications still need to be developed, the CMS Interoperability Framework contains some details as to who the users will be and how they could interact with the CMS Aligned Networks.

  • Providers will have access to discrete (e.g., medication dosages) and non-discrete (e.g., x-ray imaging) data in a timely fashion, as well as derived quality measures.
  • Payers will distribute claims data and respond to requests from other entities, such as providers and other payers.
  • Patients will be able to control their medical information on the network securely and transparently. They interface with these networks through apps with one of the following initial uses:
    • Management of diabetes and obesity, delivering tailored guidance to the patient
    • Conversational use of AI assistants to provide personalized help based on the patient’s medical record
    • A so-called “Kill the clipboard” initiative to increase the use of automation for administrative tasks, such as a patient retrieving their past health records via a QR code on their smartphone. This could eliminate the need for patients to fill out paper forms at the doctor’s office.

It remains to be seen how these new voluntary commitments will play out and what impact they will have on patients. This is not the first time organizations have pledged to work towards interoperability. Much of what was announced echoes previous pledges many of the same companies have already made to increase interoperability. Initiatives to allow electronic platforms to connect with each other in a standardized way have been around for some time. However, this iteration includes specific target applications for this technology, involving technology and standards that did not exist in the previous round of commitments, as well as expanding the scope of what types of organizations get a seat at the table, such as AI companies.

CMS hopes to showcase the efforts of “early adopters” meeting the Interoperability Framework’s goals in the first quarter of 2026 and to collaborate with early adopters in developing implementation guidelines for criteria that are currently less mature. In its announcement, CMS lists 26 “visionary” criteria, with four items related to data availability and standards compliance that early adopters will plan to meet by July 4, 2026:

  • Facilitating or providing access to data using specific technical standards
  • Making chart notes and other clinical documents available in human-readable formats (e.g., PDFs)
  • Providing appointment and encounter notifications for outpatient, telehealth, emergency department, and inpatient visits using specific technical standards
  • Collaborating with CMS to implement medical record locator functionality to more efficiently identify the electronic location of records

In addition to this new initiative, in a June 2025 press conference discussing the May RFI, CMS announced other initiatives related to the health technology ecosystem, including taking steps toward the creation of a national provider directory.

What is the History of Health IT and Interoperability in the U.S.?

Is health IT interoperability a new federal policy initiative?

No. Initiatives to develop standards-based connections to improve how the fragmented U.S. health system functions have been around for some time. Health insurance information, such as eligibility and claims, has had electronic specifications via the American National Standards Institute’s (ANSI) X12 standards for decades. Health Level 7 (HL7), an international organization dedicated to developing standards for the exchange of electronic health information, has evolved its standards since the late 1980s.

While the Health Insurance Portability and Accountability Act (HIPAA) is mostly discussed as a law regulating health information privacy and security, it was passed by Congress in 1996 to set standards for and to promote electronic data interchange (EDI)—standardized formats for certain health care transactions to promote “administrative simplification” in the health care system.

These early actions were followed by a 2004 executive order and several federal laws and regulations that have been the primary building blocks for federal interoperability standards. Two laws in particular—the Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009 and the 21st Century Cures Act (Cures Act) of 2016— created a patchwork of specific standards and incentives for voluntary actions by various stakeholders to create an interoperable health care system.

The HITECH Act incentivized “meaningful use” of electronic health records (EHR) systems among those providing services for Medicare patients—almost all non-pediatric providers—by tying Medicare reimbursement to demonstration of use of certified EHR technology. In 2009, 12% of hospitals used a certified EHR; by 2014, the share had risen to 97%. Broad adoption of EHR technology has led to increased digitization of health information, resulting in the opportunity for electronic data interchange.

The Cures Act added several parts of the interoperability framework that are still being implemented through different initiatives and regulations by CMS and the Office of the National Coordinator for Health Information Technology (ONC), now also the Assistant Secretary for Technology Policy (ASTP), which directly oversees health IT standards development and data policy. A selection of these initiatives is discussed below.

What are the key parts of federal interoperability?

Key parts of the federal interoperability landscape include:

1. A Health IT Certification Program. ONC oversees a program for the voluntary certification of health IT. The program sets a baseline standard for how health IT software, such as electronic health records, operates. A final rule issued in 2020 included initial development of the United States Core Data for Interoperability (USCDI), standards for describing the types of health data that may be exchanged. The Fast Healthcare Interoperability Resources (FHIR) specification maintained by HL7 provides the technical framework for transmitting information according to USCDI, and is a commonly-used standard for exchanging health information covering a broad assortment of clinical and administrative data.  

2. Prohibitions on “Information Blocking.” Information blocking is any practice that interferes with, prevents, or discourages the access, exchange, or use of electronic health information—practices that may interfere with interoperability. Federal information blocking restrictions apply to health care providers, developers of certified health IT, and organizations that exchange health information. For example, information blocking can take the form of charging patients excessive fees to access their medical records or preventing patients from sharing their records with other health care providers. Notably, the Cures Act clarified that health IT developers and health care providers can independently engage in information blocking. According to a federal report to Congress before the Cures Act, information blocking specifically by EHR developers presented barriers to access to and exchange of health information. The Cures Act established a complaint and enforcement mechanism for violations.

3. Requirements on CMS-regulated payers to maintain application programming interfaces (APIs). CMS has directly influenced interoperability by mandating data exchange in programs it regulates: issuers of qualified health plans (QHPs) on the federal ACA Marketplace, Medicaid and the Children’s Health Insurance Program (CHIP) fee-for-service and managed care plans, and Medicare Advantage. Part of a broader push under the Cures Act to enhance interoperability and transparency, the 2020 CMS Interoperability and Patient Access final rule mandated that CMS-regulated payers implement standardized APIs for the exchange of health information (e.g., patient claims history and encounter data) and details about their provider networks (e.g., provider names and contact information) between payers (except issuers of QHPs on the federally Marketplace). APIs, in general, allow different software programs to communicate and share information more seamlessly. Other key provisions of the 2020 rule include requiring: most CMS-regulated payers to exchange certain clinical data with other payers at the patient’s request; CMS to publicly report health care providers, hospitals, and critical access hospitals (CAHs) who may be engaged in information blocking; and most hospitals to send electronic notifications of a patient’s admission, discharge, and transfer information to all applicable health care providers and facilities.

The 2024 CMS Interoperability and Patient Access final rule, which will take full effect by January 2027, builds upon the 2020 Interoperability and Patient Access final rule and adds new provisions aimed at increasing data sharing and streamlining and automating prior authorization processes for insurance programs overseen by CMS. In both rules, affected payers are required to use FHIR APIs to securely exchange health data.

4. Development of a “Trusted Exchange Framework and Common Agreement” (TEFCA). Established as part of the Cures Act but not fully implemented until 2023, the Trusted Exchange Framework and Common Agreement (TEFCA) is aimed at promoting the security and seamless exchange of electronic health information across the networks of health systems, plans, and other health care entities. Intermediary organizations that facilitate information exchange, called Qualified Health Information Networks (QHINs), agree to meet certain technical and legal requirements for facilitating information sharing. The roster of TEFCA’s QHINs continues to grow. QHINs agree to comply with the “Common Agreement,” which includes standard operating procedures concerning privacy and security. Providers can then use the QHINs to share information, for example, by retrieving their patients’ records from unaffiliated systems. By establishing a single nationwide framework, TEFCA helped close some of the gaps in prior health information exchange practices, such as fragmented use, uniform policies surrounding whose data are collected and who gets to see them, and standards to avoid incompatibility between proprietary health information exchanges. Participation in the Agreement is voluntary.

What federal privacy and security protections exist for patient information shared through these interoperable processes?

Regulations from 2000 established a federal floor of protections for patients’ protected health information (PHI), including safeguards under the Security Rule (2003) for the exchange of electronic PHI between covered entities: health plans, health care clearinghouses, health care providers, and their business associates. The HIPAA Security Rule standards apply to patient health information regardless of whether it is shared with other entities. Even before interoperability was well defined, HIPAA put provisions in place—such as requiring covered entities to implement technical safeguards to prevent unauthorized access during electronic transmission—that remain important for protecting patient data today in the context of interoperability.

HIPAA regulations are now almost 25 years old. Updates to the HIPAA privacy rules were proposed at the end of the first Trump administration, and updates to HIPAA’s security standards were proposed at the end of the Biden administration. Neither has been finalized. It is unclear whether renewed proposals in this area are imminent. HIPAA also does not reach many of the key players in health interoperability, including developers and other business entities that are not providers, plans, or health care clearinghouses. For example, a direct-to-consumer health app from a software developer does not fall under HIPAA. Although non-HIPAA entities that misrepresent or do not follow their privacy policies or mishandle patient data would not face repercussions under HIPAA, they could face federal legal repercussions for “unfair and deceptive” practices under the Federal Trade Commission (FTC) Act. The FTC website offers a health app interactive tool to assist developers in navigating the laws and regulations that may apply to them or their app.

The HITECH Act also introduced new requirements that a covered entity or its business associate must notify affected individuals, within a specified timeframe, of data breaches, which are instances where unsecured, protected health information has been accessed, acquired, or disclosed without proper authorization. The notification must include a brief description of how the breach occurred, the types of unsecured protected health information involved, the steps individuals should take to protect themselves from potential harm, how the entity is investigating the breach, and contact information for individuals with questions. The HITECH Act also requires covered entities and business associates to report data breaches to the U.S. Department of Health and Human Services (HHS) and external sources such as the media.

Additionally, TEFCA includes privacy and security standards in its Common Agreement. Each non-HIPAA entity working with data from a TEFCA entity also must protect identifiable health data, much like HIPAA-covered entities do.

How does value-based care relate to interoperability?

Although the Affordable Care Act (ACA) contains some provisions building upon HIPAA to standardize and simplify electronic data interchange, it also aimed to improve quality through value-based provider payment models (such as Accountable Care Organizations), which need data to coordinate between multiple providers and health care settings. The shift away from traditional fee-for-service payments towards alternative payment models that place financial risk on providers was reinforced with the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, tying reimbursement to quality measures. The Merit-Based Incentive Payment System, authorized by MACRA, incentivizes providers to engage in interoperability initiatives, such as electronic prior authorization. These changes have helped spur the development of new analytic platforms and services that require timely, accurate health data collection and exchange across providers and health care settings.

What interoperability standards apply to Medicare?

While Medicare Advantage plans must meet API standards from 2020 regulations, enrollees with traditional Medicare have already had access to information exchange through APIs. Early demonstration of patient ownership of health data came from the CMS Blue Button specifications, established by CMS and the Veterans Administration in 2010. The CMS Blue Button was intended to give traditional Medicare beneficiaries and veterans easy access to their personal health records as a text file and to share their records. Blue Button grew to be more sophisticated with the implementation of Blue Button 2.0 in 2018, which additionally allowed data sharing with third-party apps, broadening participants in regulated health data exchange for those covered by traditional Medicare. However, in 2023, CMS reported low enrollee participation in the Blue Button program; as of February 2022 (the most recent data available), fewer than 250,000 Medicare beneficiaries had used it.

What interoperability standards apply to employer-sponsored coverage?

The CMS 2020 Interoperability and Patient Access rules do not apply to health plans sponsored by employers, the largest source of health coverage in the U.S. Payers and third-party administrators (TPAs) may choose to implement interoperability standards, but are not compelled to by the 2020 regulation. Some employer plan sponsors do offer consumer-facing tools that use technologies that may or may not meet federal IT certification standards, consumer protection standards in the 2020 interoperability rule (e.g., opt-out vs. opt-in), or HIPAA standards. These could include digital tools, such as apps similar to Medicare’s Blue Button initiative, that help employees navigate coverage options, clinical decisions, or provide general wellness advice and care. Federal ERISA standards, such as fiduciary requirements, likely apply to decisions by employers to offer these tools, although the reach of these fiduciary standards is still unclear. The voluntary initiative recently announced by the Trump administration could presumably encourage employers to implement more interoperable technologies, although no pledges were made specifically by employers related to the coverage they offer their employees.

What are the Challenges in All These Efforts?

Coalescing around standards requires cooperation between all entities involved. CMS stepping in with this announcement to coordinate efforts could advance interoperability, even if it is not entirely novel. A perennial problem has been that regulation often lags behind technological developments, leading to incompatibility at best and security and privacy issues at worst. As health care information technology continues to shift focus towards AI applications, the arena of organizations that deal with health care data has evolved to include even more players outside of HIPAA’s jurisdiction, which could lead to new privacy and security problems for which there are no federal regulations to address.

Privacy and Security Gaps in the CMS Interoperability Framework

Although the new CMS Interoperability Framework includes security specifications, it does not cover what happens when data travel beyond CMS Aligned Networks. AI tools and advanced analytics may use cloud computing or systems that distribute data processing across connected computers, necessitating transfers of health information beyond the reach of regulation in CMS Aligned Networks and HIPAA-covered entities. When data are moved across connections, information is spread across different systems with differing data management and storage practices. And while the CMS Interoperability Framework requires auditing access within the CMS Aligned Network, this requirement does not extend to data transmitted beyond its boundaries. Accounting of where data has gone may be incomplete, and outdated or inaccurate data may be stored at various sites.

Limitations of HIPAA Privacy and Security Protections

Control and retention of health data are also not cohesively governed by federal law. Some states, such as California, maintain regulations granting patients the right to review and delete their data, even outside of HIPAA-covered entities. However, there is no federal equivalent. (The American Data Privacy and Protection Act, introduced in 2022, would have codified this right, but has not been passed into law.) This latest round of corporate pledges accompanying the announcement includes organizations that have built their businesses by monetizing data. Consumer health apps, fitness trackers, wearable devices, and other health technologies that operate outside traditional health care settings produce data that lie on the periphery of what could be considered protected health information. While they may not be “individually identifiable health information,” the data can still have sensitive information (e.g., mental health ratings, menstrual cycles, stress scores). The sale of these non-HIPAA protected data poses a legitimate privacy concern, as does identifiability in aggregate or in conjunction with other personal information, such as what may be obtained from data brokers. Some protections do exist for these data, such as the Health Breach Notification Rule; however, regulation only retrospectively covers breaches and does not proactively stipulate privacy and security safeguards that might prevent a breach in the first place.

User consent also poses a challenge for data privacy and security. While apps may explain how they use data in their terms and conditions and privacy policies, users might not have the time or expertise to fully understand them. Apps developed outside of the CMS Interoperability Framework may have weaker security and privacy protections than those that follow security measures integrated into the CMS Interoperability Framework. Users of health data applications may not immediately understand whether their apps follow this CMS Interoperability Framework and, consequently, could be unaware of how their data are handled with respect to privacy and security. To direct users to certified apps, directories may help (the approach with CMS Blue Button apps), but users may obtain their apps outside these listings. Even apps with strict privacy policies are no guarantee that data remain private. Recent action by the FTC illustrates the risk of health data apps, investigating companies such as GoodRx, BetterHelp, and Flo Health for selling data obtained through their services to third parties, such as social media and data analytics companies, allegedly in violation of their own privacy policies.

Complexity for Patients and Consumers

In addition to privacy and security challenges, the increased use of health apps and other digital tools that rely on personal health information could add more complexity for patients and consumers, many of whom already have challenges navigating the health care system. The onus falls on the consumer to understand how to use these apps and digital tools, obtain health information from providers, and input it into the app, all of which could require substantial time commitments. Few resources are available to help consumers understand how to use these tools and get their health information. Additionally, the “consumer friendliness” of apps and tools can vary between products; while some developers may test their products with consumers, there is no explicit requirement for developers to make them easy to use for people of all ages, health literacy levels, and technological abilities, or to make consumer support available. Another challenge is expanding the use of digital health tools to people with lower incomes and those who live in rural areas, who are less likely than their peers to own a smartphone or have internet access.

Looking Forward

As apps come online, they may be sold directly to consumers or offered through an insurer or employer. It is unclear how large the appetite for health apps will be, and whether patients will choose to integrate these apps into their health care. Incentives for providers to recommend these apps to their patients are also not well defined. Opportunities for app developers to influence provider practices, such as recommending their product, may pose ethical challenges. At the same time, some of the biggest names in the business have made pledges, and this announcement will almost certainly boost the companies that sell these apps.

Open questions about data privacy, security, and accuracy are key concerns as the details of the CMS Interoperability Framework and associated CMS Aligned Networks are developed. While development of certified health IT software has generally had a focus on privacy and security (and even requires attestation of security for federal ONC certification), how reliable the “early adopters” from outside this sphere are in maintaining tight privacy and security controls remains to be seen.

Unlike federal regulations, these pledges are voluntary and do not create any new legally binding requirements for these entities. Additionally, mechanisms for the CMS Interoperability Framework to evolve with technological advancements have not been defined, since it is not based on regulation. However, a voluntary private sector initiative could evolve more quickly than regulation, which is inherently slower and harder to change. CMS invites early adopters to collaborate to document and publish implementation guidelines, which could be effective in maintaining standards, but may encourage a race to market so that one early adopter’s technology becomes the standard for all.

Even with advancements in health IT, consumers may still have trouble understanding how to access their health information (such as medical records), what their rights are with respect to electronic health information, and how their data are handled. Many consumers are likely unaware of the patchwork of laws, regulations, and voluntary private sector commitments shaping the digital health landscape and to whom they apply. A 2023 Pew Research Center survey found that 72% of Americans say they understand very little or nothing about laws and regulations protecting their data privacy, and that 81% are concerned with how companies use data collected about their users. In the event products fail to comply with external standards or internal policies for data exchange, how does a consumer know? Do consumers know what to do if they suspect their rights are being violated? Do they know how to delete their health information or opt out of automated sharing of their information? The extent to which recent CMS efforts achieve their stated goals will rely heavily on bolstering consumer education and understanding, as well as expanding legal protections that may encourage patients to take on the role that has been the vision of health data interoperability for decades.

Medicare Advantage Enrollees Account for 25% of all Inpatient Hospital Days

Published: Aug 26, 2025

Editorial Note: Originally published on July 23, 2024, this brief has been updated with more recent data, a revised methodology, and state-level results.

Key Findings

Enrollment in Medicare Advantage has grown rapidly in recent years, with more than half of all eligible Medicare beneficiaries now receiving their coverage from a private plan. Although the pace of enrollment increases slowed in 2025, the total number of Medicare Advantage enrollees still increased and the share of Medicare beneficiaries who obtain their Medicare benefits from a private plan is expected to continue to grow over the next decade. This trend has implications for beneficiaries and health care providers, including hospitals, because Medicare Advantage differs from traditional Medicare in many ways.

For hospitals and beneficiaries, one key distinction is that virtually all Medicare Advantage enrollees are in a plan that requires prior authorization for inpatient hospital stays (96%), post-acute skilled nursing facility stays (99%) and home health care (91%). Prior authorization is intended to reduce unnecessary care and lower costs, but it also imposes administrative burdens on providers, and sometimes leads to delays and barriers to care. Medicare Advantage plans also typically establish provider networks and impose higher out-of-pocket costs for out-of-network care. In light of the reported uptick in utilization among some Medicare Advantage enrollees, insurers looking to protect profits and guard against losses may seek to cut costs in ways that could impact hospitals, such as by tightening networks to direct patients to providers with lower costs. As Medicare Advantage enrollment grows, decisions made by insurers (related to networks, payment rates, prior authorization, and denials) along with decisions made by hospitals (whether to be in a Medicare Advantage network) can be expected to affect a larger share of the Medicare population.

Recently, hospitals and other providers—including in rural areas—have raised concerns about the impact of Medicare Advantage on their finances. Some hospitals have terminated contracts over payment rates, delays in payment, more restrictive coverage determinations, and denials. One issue that has drawn scrutiny from these groups has been plans’ practice of shifting hospitalized patients to “observation status,” which often means lower payments to hospitals and higher costs for patients. Additionally, one study estimated that Medicare Advantage denials of inpatient services reduced provider revenue by approximately 7%.

This data note examines the growth of Medicare Advantage as a share of hospital inpatient days between 2015 and 2023 based on cost reports submitted by hospitals to the Centers for Medicare and Medicaid Services (CMS).

Key Takeaways

  • Medicare Advantage represents a growing share of total hospital inpatient days. Medicare Advantage grew from 13% to 25% of total inpatient hospital days between 2015 and 2023, and as of 2023, half (50%) of all Medicare inpatient hospital days were attributed to Medicare Advantage enrollees.
  • Nearly four in ten hospitals had more inpatient days from Medicare Advantage enrollees than traditional Medicare enrollees in 2023. The share of hospitals with more Medicare Advantage than traditional Medicare inpatient days grew from 4% in 2015 to 38% in 2023.
  • Medicare Advantage inpatient shares have grown fastest in rural areas. The share of inpatient hospital days attributed to Medicare Advantage enrollees more than doubled in rural counties adjacent to metropolitan areas between 2015 and 2023 and nearly tripled in rural counties not adjacent to metropolitan areas.
  • Medicare Advantage inpatient shares ranged from 2% to 33% across states in 2023. Medicare Advantage inpatient shares were lowest in Alaska (2%) and Wyoming (6%) and highest in Ohio (32%) and Michigan (33%).
  • Within counties, the share of inpatient days attributed to Medicare Advantage enrollees also varied widely across hospitals in 2023. For example, in Allegheny County, PA (where Medicare Advantage penetration is relatively high), inpatient days attributed to Medicare Advantage enrollees ranged from 14% to 59% across hospitals. Similarly, in Cook County, Illinois (where Medicare Advantage penetration is relatively low), the Medicare Advantage inpatient share ranged from 2% to 38% across hospitals.

Medicare Advantage steadily increased as a share of inpatient days between 2015 and 2023, while the share attributed to traditional Medicare decreased.

The share of total inpatient days attributed to Medicare Advantage enrollees grew from 13% in 2015 to 25% in 2023 among general short-term hospitals in the U.S (see Figure 1). During this same period, the share of inpatient days attributed to traditional Medicare declined from 36% to 25%. As of 2023, half of all Medicare inpatient days were attributed to Medicare Advantage patients. The rise in the share of inpatient days attributed to Medicare Advantage enrollees coincided with an increase in Medicare Advantage enrollment as a share of all eligible Medicare beneficiaries from 32% in 2015 to 51% in 2023.

Medicare Advantage Steadily Increased as a Share of Inpatient Days Between 2015 and 2023, While the Share Attributed to Traditional Medicare Decreased

The share of hospitals with more inpatient days from Medicare Advantage than traditional Medicare increased from 4% in 2015 to 38% in 2023.

The increase in Medicare Advantage enrollment has contributed to a shift in patient mix across hospitals, affecting some more than others. The share of hospitals with more Medicare Advantage than traditional Medicare inpatient days increased from just 4% in 2015 to 38% in 2023 (Figure 2). Hospitals with a greater share of patients from Medicare Advantage than traditional Medicare may be more reliant on revenue from these plans and more affected by various plan rules and decisions, such as prior authorization requirements, denials of claims, observation stay designations, and network restrictions.

The Share of Hospitals With More Inpatient Days From Medicare Advantage Than Traditional Medicare Grew From 4% in 2015 to 38% in 2023

Among rural hospitals, the share of inpatient days for Medicare Advantage enrollees more than doubled between 2015 and 2023.

Medicare inpatient shares more than doubled (from 11% in 2015 to 26% in 2023) in rural counties that are adjacent to metropolitan areas and nearly tripled (from 7% in 2015 to 19% in 2023) in rural counties that are not adjacent to metropolitan areas (referred to here as the “most rural” counties). Medicare inpatient shares were lower in adjacent rural areas versus urban areas in 2015 (11% versus 13%) but were higher in 2023 (26% versus 25%). Although Medicare inpatient shares grew fastest in the most rural areas, they also were lower in these areas in any given year than in other areas (e.g., 19% in 2023 versus 26% in adjacent rural areas and 25% in urban areas). The majority of Medicare beneficiaries in the most rural counties receive their coverage through traditional Medicare, unlike in rural counties adjacent to metropolitan areas and urban counties, where most beneficiaries are enrolled in Medicare Advantage plans.

Some rural hospitals have raised concerns about the growth of Medicare Advantage, pointing to payment rates that are lower than rates paid by traditional Medicare and payment delays and denials. Rural hospitals often face unique financial challenges, which could make it harder to adjust to the expansion of Medicare Advantage than other hospitals. As Medicare Advantage enrollment continues to climb, and as Medicare Advantage enrollees comprise a larger share of patients, rural hospitals may face new challenges.

Among Rural Hospitals, the Share of Inpatient Days for Medicare Advantage Enrollees More Than Doubled Between 2015 and 2023

Medicare Advantage inpatient shares ranged from 2% to 33% across states in 2023.

State-level Medicare Advantage inpatient shares tracked with Medicare Advantage enrollment. Medicare Advantage inpatient shares were lowest in Alaska (2%), and Wyoming (6%), which were also the two states with the lowest Medicare Advantage penetration in 2023 (2% and 11%, respectively). Meanwhile, Medicare Advantage inpatient shares were among the highest in states like Michigan (33%) and Hawaii (29%) where penetration was at least 60% of all Medicare beneficiaries. State-level Medicare Advantage penetration is influenced by a range of factors, including insurance market dynamics, beneficiary characteristics, and the share of the state’s population living in urban or rural areas. 

Medicare Advantage Inpatient Shares Ranged From 2% to 33% Across States in 2023

Medicare Advantage comprised a higher share of inpatient days in counties with higher Medicare Advantage penetration in 2023.

Across the country, the share of Medicare beneficiaries enrolled in Medicare Advantage varies widely. As might be expected, counties with higher Medicare Advantage penetration also had higher Medicare Advantage inpatient shares than counties with lower Medicare Advantage penetration. Among counties in the top quartile of Medicare Advantage penetration, Medicare Advantage comprised 28% of inpatient days in 2023 (Figure 4), substantially greater than the 18% share among the bottom quartile of counties.

Medicare Advantage Comprised a Higher Share of Inpatient Days in Counties With Higher Medicare Advantage Penetration in 2023

The share of inpatient days attributed to Medicare Advantage enrollees varied widely across hospitals within counties in 2023.

Although the share of inpatient days attributed to Medicare Advantage tracked county-level Medicare Advantage penetration, there was large variation within counties. The figure below illustrates the range in Medicare Advantage inpatient shares for a set of counties that have several hospitals and are geographically dispersed in each quartile of Medicare Advantage penetration. For example, in Allegheny County, PA, a high-penetration county where 73% of eligible Medicare beneficiaries were enrolled in a Medicare Advantage plan in 2023, Medicare Advantage enrollees accounted for just 14% of all inpatient days in one hospital but more than half (59%) in others. Even in counties with lower than average penetration, there was substantial variation in the share of inpatient days attributed to Medicare Advantage. For instance, in Cook County, Illinois, where 42% of beneficiaries were enrolled in a Medicare Advantage plan, the Medicare Advantage inpatient share ranged from 2% to 38% across hospitals.

Differences in Medicare Advantage inpatient shares across hospitals within the same county may be due to a number of factors, including whether a given hospital is in Medicare Advantage networks, the extent to which a given hospital tends to serve people with Medicare based on the types of services and procedures it provides, and beneficiary preferences that might be based on convenience or perceived quality. As noted above, hospitals with a relatively large number of patients from Medicare Advantage may be more affected by prior authorization requirements, denials of claims, observation stay designations, and network restrictions of these plans. As Medicare Advantage enrollment continues to rise, the decisions made by Medicare Advantage plans related to reimbursement, coverage, and networks could have revenue implications for hospitals and other health care providers that can be expected to vary across counties and within local markets.

The Share of Inpatient Days Attributed to Medicare Advantage Enrollees Varied Widely Across Hospitals Within Counties in 2023

This work was supported in part by Arnold Ventures. KFF maintains full editorial control over all of its policy analysis, polling, and journalism activities.

Methods

This analysis draws on a number of data sources. Data on inpatient days came from annual cost report data that Medicare-certified hospitals are required to submit to the Healthcare Cost Report Information System (HCRIS). Most hospital characteristics came from RAND Hospital Data, which is a cleaned and processed version of cost report data. To our knowledge, the accuracy of traditional Medicare and Medicare Advantage days listed in hospital cost reports has not been evaluated. Hospitals report combined days for Medicare Advantage and cost plan enrollees. Cost plans account for a negligible share of Medicare enrollment, so we refer to the combination as “Medicare Advantage days” throughout.

County-level Medicare Advantage penetration was calculated from Medicare enrollment data.  Enrollment data is only provided for plan-county combinations that have at least 11 beneficiaries, and some counties do not have plans that meet this threshold. We assumed these counties had 0% Medicare Advantage penetration. Urban Influence Code (UIC) classifications were used to designate hospitals as being in urban areas, rural areas adjacent to a metropolitan area, and rural areas not adjacent. Urban was defined as metropolitan and rural as nonmetropolitan.

This analysis updates previous KFF work with some methodological updates. The analysis uses a revised approach for calculating Medicare Advantage and traditional Medicare inpatient shares that aligns with the definition of these shares used as part of CMS’s formula for calculating graduate medical education payments. This approach differs from our prior analysis in a few ways, such as by including days from inpatient psychiatric and rehabilitation facilities that are components of sample hospitals. At the national level, Medicare Advantage inpatient shares are one percentage point higher in some years when using the revised measure as compared to prior work. This analysis also includes a new definition of “rural areas” (i.e., nonmetropolitan areas) and divides rural areas into those that are and are not adjacent to metropolitan areas, in line with recent KFF work. 

We restricted this analysis to general short-term hospitals and excluded hospitals in U.S territories. Cost reports reflect varying reporting periods that often do not align with a calendar year. We assigned cost reports to calendar years based on the year that the cost report ended in. We only examined cost reports that covered 365 or 366 days (referred to as “full-year cost reports”). These restrictions left 4,368 cost reports in 2023. We also excluded observations missing Medicare Advantage or traditional Medicare inpatient days and, in rare cases, dropped implausible or difficult to interpret data (e.g., where combined Medicare Advantage and traditional Medicare inpatient days exceeded total inpatient days). This left 3,797 cost reports in 2023.

Thirteen percent of the 4,368 cost reports described above were missing data for Medicare Advantage inpatient days in 2023 (compared to less than 1% for traditional Medicare days). The 13 percent of hospitals that were missing Medicare Advantage data were more likely to be small or rural and accounted for less than 2 percent of all inpatient days. None of the reports in our sample reported zero Medicare Advantage inpatient days. It is unclear whether and when missing values represent zero days. We suspect that Medicare Advantage may represent a relatively small share of inpatient days on average among hospitals with missing data, in part because hospitals with relatively few Medicare Advantage days have a smaller incentive to track and report these days when required for additional reimbursement under traditional Medicare (e.g., for medical education adjustments).

We conducted sensitivity analyses to explore the implications of missing Medicare Advantage data. First, we ran analyses excluding groups of hospitals that were most likely to be missing data, such as hospitals with fewer than 25 beds. Second, we ran analyses that assumed that hospitals with missing data had zero Medicare Advantage inpatient days, which would be the lower bound of the possible Medicare Advantage shares at these hospitals. Third, we ran our analysis of overall and rural hospital Medicare Advantage share trends using hospitals that had Medicare Advantage data for all years (2015 through 2023). Different approaches increased or decreased average Medicare Advantage shares. For example, non-adjacent rural hospitals had slightly lower shares when replacing missing values with zeroes and slightly higher shares when excluding small hospitals. However, Medicare Advantage inpatient shares overall and by geography and state were generally similar when using these approaches (e.g., differed by two percentage points or less when treating missing values as zeroes). Further, our main findings that there were large increases in Medicare Advantage inpatient shares across hospitals in non-adjacent rural, adjacent rural, and urban areas alike and that shares were higher in counties with greater Medicare Advantage penetration was true across all of our sensitivity analyses.

Income and Assets of Medicare Beneficiaries in 2024

Authors: Alex Cottrill, Juliette Cubanski, Tricia Neuman, and Karen Smith
Published: Aug 25, 2025

Issue Brief

Close to 70 million people ages 65 and older and younger people with long-term disabilities receive their health insurance coverage through the federal Medicare program. While overall satisfaction with the program is high, paying for health care services can prove challenging for Medicare beneficiaries. In 2023, more than one-third (36%) of beneficiaries said they had delayed or gone without a visit to the doctor’s office, vision services, hearing services, prescription drugs or dental care in the past year because of the cost. Medicare households also spend a larger share of their total budgets on health care than non-Medicare households, and are more likely to need expensive long-term services and supports over an extended period of time, which are not covered by Medicare.

The cost of health care may become even more burdensome for Medicare beneficiaries in the coming years. A recent KFF analysis found that 7 million Medicare beneficiaries spent more than 10% of their annual income on Part B premiums alone in 2024, a number that may grow over the next decade if Part B premiums grow faster than income. Part B premiums are projected to nearly double between 2024 and 2034, from $2,100 per year to more than $4,000 per year. While people with relatively low incomes and limited financial resources can qualify for financial assistance with Medicare premiums and cost sharing through the Medicare Savings Programs, many beneficiaries with modest incomes do not qualify for this assistance, because their income or savings exceed the maximum amount. Other eligible beneficiaries may not receive these benefits because they don’t know about them or find the application process too challenging. In addition, provisions in the GOP’s recently enacted tax cut and spending law are expected to make it more difficult for eligible low-income Medicare beneficiaries to enroll in these programs, which is estimated to reduce the number of people receiving this coverage by 1.3 million beneficiaries.

To understand the financial resources available to people with Medicare that can be used to cover their health care costs, this brief examines the income, assets, and home equity of Medicare beneficiaries, overall and by age, race and ethnicity, and gender, using data derived from the Dynamic Simulation of Income Model (DYNASIM) for 2024. Due to data limitations, estimates for beneficiaries in some racial and ethnic groups, including Asian, American Indian and Alaska Native, and Native Hawaiian or Other Pacific Islander beneficiaries, as well as beneficiaries who identify as two or more races, are unavailable (see Methods for additional details on the model).

This analysis highlights that a large share of Medicare beneficiaries live on relatively low incomes and have modest financial resources to draw upon if they need to cover costly medical care or long-term services and supports, with notable differences by age, race and ethnicity, and gender. For example:

  • One in four Medicare beneficiaries – 16.5 million people with Medicare – lived on incomes below $24,600 per person in 2024. Half (32.9 million) of all Medicare beneficiaries lived on incomes below $43,200 per person. At the upper end of the income spectrum, the top 5% (3.3 million) of Medicare beneficiaries lived on incomes above $169,700 per person.
  • One in four Medicare beneficiaries had savings below $18,950 per person in 2024, while half had savings below $110,100 per person. At the higher end of the savings distribution, the top 5% of Medicare beneficiaries had savings above $1.7 million per person.
  • One in four Medicare beneficiaries had no home equity at all in 2024, while half of all Medicare beneficiaries had home equity below $128,200 per person. The top 5% of Medicare beneficiaries had home equity above $886,800 per person.
  • Per person estimates of income and savings varied by characteristic and were generally lower for beneficiaries ages 85 and older than for beneficiaries ages 65 to 84, lower for women than men, and lower for Black and Hispanic beneficiaries than White beneficiaries. Income and savings were also lower for beneficiaries under 65 with long-term disabilities than those ages 65 and older.
  • Nearly half of all Black and Hispanic beneficiaries had no home equity, and roughly one in five Black and Hispanic beneficiaries had no savings or were in debt, compared to one in five White beneficiaries with no home equity, and fewer than one in ten White beneficiaries with no savings or in debt.

Income among Medicare Beneficiaries

In 2024, one in four Medicare beneficiaries, or 16.5 million people with Medicare, lived on incomes below $24,600 per person. Half of all Medicare beneficiaries, or 32.9 million people with Medicare, had incomes below $43,200 per person (Figure 1). At the higher end of the income distribution, the top five percent of Medicare beneficiaries (3.3 million) had incomes above $169,700 per person, including the top one percent (0.7 million) whose incomes exceeded $376,450 per person.

One in Four Medicare Beneficiaries Lived on Incomes Below $24,600 Per Person and Half Lived on Incomes Below $43,200 Per Person in 2024

Per person estimates of income varied by age, race and ethnicity, and gender, though nearly all beneficiaries across groups had at least some per capita income in 2024, in large part due to Social Security (Figure 2, Appendix Table 1).

Estimates of Per Capita Income Declined with Age among Older Adults, Were Lower for Women, Black and Hispanic Beneficiaries, and Beneficiaries Under 65

Age: Median per capita income was substantially lower among Medicare beneficiaries ages 85 and older ($37,000) than among those ages 65 to 74 ($47,300) or 75 to 84 ($45,650, Figure 2). This pattern reflects the lower likelihood of having income from earnings at older ages (for example, 49% of beneficiaries ages 65-74 and 20% of beneficiaries ages 75-84 had income from earnings in 2024, compared to just 1% of beneficiaries ages 85 and older). Medicare beneficiaries under age 65, who qualify for Medicare because of a long-term disability, had the lowest median per capita income of any age group (Figure 2). One in four beneficiaries under age 65 lived on incomes below $15,800 per person, which was just above the federal poverty threshold of $15,060 for a single person in 2024.

Race/Ethnicity: At the median and among those in the bottom 25% of the income distribution, per capita income was lower among Black and Hispanic beneficiaries than among White beneficiaries (Figure 2). One quarter of Black beneficiaries lived on incomes below $20,150 per person, and one quarter of Hispanic beneficiaries lived on incomes below $14,150 per person, compared to $27,550 per person among White beneficiaries, reflecting wider racial and ethnic disparities in job opportunities and earnings during their working years, lower access to pension and other retirement benefits, and fewer years of education. Older Black and Hispanic beneficiaries are also more likely than older White beneficiaries to report difficulties paying for health care expenses, given the larger share who live with lower incomes.

Gender: Per capita income was lower among women than men, both at the median ($42,350 vs. $44,150) and among beneficiaries in the bottom 25% of the income distribution ($23,900 vs. $25,500, Figure 2). On average, women have lower wages than men during their working years, even when working in similar roles, and often take on a larger share of unpaid family caregiving, resulting in lower lifetime earnings and lower Social Security benefits once they retire. These gender differences persisted across age groups among those age 65 or older (Appendix Table 2). For example, median income among women ages 85 and older was just $34,300 per person, compared to $40,750 per person among men of the same age.

Marital Status: Both at the median and among those in the bottom 25% of the income distribution, per capita income was higher among beneficiaries who were married, compared to those who were widowed, divorced or single. One quarter of married beneficiaries lived on incomes below $28,550 per person, compared to $25,250 among widowed beneficiaries, $22,150 among divorced beneficiaries, and $15,600 among single beneficiaries (Appendix Table 1). Spouses (or ex-spouses for marriages longer than ten years) can opt to receive half of their spouse’s Social Security benefit in lieu of the benefit based on their own earnings, which may offer greater flexibility to beneficiaries who are or have been married.

Education: Both at the median and among beneficiaries in the bottom 25% of the income distribution, per capita income rose with educational attainment. One quarter of beneficiaries with less than a high school education lived on incomes below $13,350 per person, compared to $41,250 among beneficiaries with a college degree (Appendix Table 1).

Savings among Medicare Beneficiaries

One in four Medicare beneficiaries (16.5 million) had savings below $18,950 per person in 2024, while half (32.9 million) had savings below $110,100 per person (Figure 3). One in ten (6.6 million) had no savings or were in debt. Among the wealthiest Medicare beneficiaries, the top five percent (3.3 million) had savings exceeding $1.7 million per person, including the top one percent (0.7 million) whose savings exceeded $4.3 million per person.

One in Four Medicare Beneficiaries Had Savings Below $18,950 Per Person and One in Ten Had No Savings or Were in Debt in 2024

Per person estimates of savings, as well as the share of beneficiaries without savings or with debt, varied by age, race and ethnicity, and gender (Figure 4, Appendix Table 1).

Estimates of Per Capita Savings Declined with Age among Older Adults, Were Lower for Women, Black and Hispanic Beneficiaries, and Beneficiaries Under 65

Age: Both at the median and among those in the bottom 25% of the savings distribution, per capita savings declined with age among Medicare beneficiaries ages 65 and older (Figure 4). One quarter of beneficiaries ages 85 and older had savings below $4,250 per person (vs. $31,950 among beneficiaries ages 65-74), and half had savings below $47,950 per person (vs. $148,150 among beneficiaries ages 65-74). By way of comparison, the median annual cost of care nationwide in 2023 was $116,800 for a private room in a nursing home, and $64,200 for an assisted living facility.

Among beneficiaries with disabilities under the age of 65, one quarter had savings below $5,250 per person (vs. $22,600 among seniors), and half had savings below $38,600 per person (vs. $124,550 among seniors, Figure 4). Roughly 15% of beneficiaries under age 65 (vs. 9% of seniors) had no savings or were in debt (Appendix Table 1). Relatively low income and savings may present a particular challenge to Medicare beneficiaries under age 65, who are over three times more likely than older beneficiaries to report a problem paying a medical bill in the past 12 months, and nearly twice as likely to report delaying or forgoing a health care service, such as doctor visits or prescription drugs, due to their cost.

Race/Ethnicity: Median per capita savings were higher among White beneficiaries than among Black and Hispanic beneficiaries. Likewise, among beneficiaries in the bottom 25% of the savings distribution, per capita savings among White beneficiaries ($37,300) were more than 30 times higher than among Black beneficiaries ($1,100) and more than 25 times higher than among Hispanic beneficiaries ($1,400, Figure 4). More than one in five Black and Hispanic beneficiaries (20% and 19%, respectively) had no savings or were in debt, compared to just 6% of White beneficiaries (Appendix Table 1). Racial and ethnic disparities in per capita savings are generally larger than disparities in income, and persist even among beneficiaries with similar levels of education, suggesting wider inequities in financial security and intergenerational wealth.

Gender: Per capita savings were lower among women than men, both at the median ($96,150 vs. $128,050) and among beneficiaries in the bottom 25% of the savings distribution ($15,400 vs. $24,200), and a larger share of women than men had no savings or were in debt (11% vs. 8%, Appendix Table 1). Average life expectancy at age 65 is somewhat higher for women than men, and those with less wealth accumulation may be at greater risk of running out of retirement savings as they age. As with income, gender differences in savings persisted across age groups among those 65 and older (Appendix Table 2).

Marital Status: Married beneficiaries had median per capita savings ($173,500) that were more than twice as high as among beneficiaries who were widowed ($82,300) or divorced ($71,700) and nearly six times higher than among beneficiaries who were single ($29,250, Appendix Table 1). A similar pattern was true among beneficiaries in the bottom 25% of the savings distribution. Likewise, a smaller share of married beneficiaries (5%) had no savings or were in debt, compared to beneficiaries who were widowed (11%), divorced (14%), or single (21%).

Education: Beneficiaries with a college degree had median per capita savings ($332,200) that were more than five times higher than beneficiaries with only a high school degree ($65,150) and more than 30 times higher than beneficiaries with less than a high school education ($10,650, Appendix Table 1). A similar pattern was true among beneficiaries in the bottom 25% of the savings distribution. Just 4% of beneficiaries with a college degree had no savings or were in debt, compared to 11% of beneficiaries with only a high school degree and 25% of beneficiaries with less than a high school education.

Home Equity among Medicare Beneficiaries

Half of all Medicare beneficiaries (32.9 million people) had less than $128,200 per person in home equity in 2024, while more than one quarter (26% or 17.1 million) had no home equity at all. At the higher end of the distribution, the top five percent of Medicare beneficiaries (3.3 million people) had more than $886,800 per person in home equity, including the top one percent (0.7 million) who had more than $1.5 million per person (Figure 5).

Half of All Medicare Beneficiaries Had Home Equity Below $128,200 Per Person and One in Four Had No Home Equity in 2024

Per person estimates of home equity, as well as rates of homeownership, varied by age, race and ethnicity, and gender (Figure 6, Appendix Table 1).

Estimates of Per Capita Home Equity Rose with Age, But Were Much Lower for Black and Hispanic Beneficiaries and Beneficiaries Under 65

Age: Median per capita home equity rose with age, from $134,450 among those ages 65-74 to $179,700 among those ages 85 and older, likely reflecting the larger share of homeowners who had reduced or paid off mortgage debt in older age groups. Unlike other financial assets, which may decrease as seniors leave the workforce and spend their accumulated savings, homes typically store and accumulate equity over time. Median per capita home equity was lowest among beneficiaries under the age of 65 ($13,850 vs. $145,200 among seniors), and one in two (48%) had no home equity at all (vs. 23% of seniors) (Figure 6).

Race/Ethnicity: As with income and savings, median per capita home equity was higher among White beneficiaries ($161,450) than among Black ($28,700) or Hispanic ($39,150) beneficiaries (Figure 6). This was due in part to differences in rates of homeownership, with close to half of Black (44%) and Hispanic (42%) Medicare beneficiaries having no home equity at all, compared to one in five (20%) White beneficiaries.

Gender: Median per capita home equity was somewhat higher among women than men ($136,100 vs. $119,100, Figure 6). While rates of homeownership were comparable (75% vs. 73%), differences in life expectancy mean that a larger share of women survive to older ages, allowing more time to accumulate home equity and, in the case of widowed beneficiaries, to own the full share of their homes.

Marital Status: The majority of married and widowed beneficiaries were homeowners, with median per capita home equity of $151,500 and $221,350, respectively. Just 13% of married beneficiaries and 20% of widowed beneficiaries had no home equity at all. By contrast, many divorced beneficiaries and most single beneficiaries were not homeowners. Median per capita home equity among divorced beneficiaries was $54,600 (41% were not homeowners). Single beneficiaries had the lowest rates of homeownership – 64% had no home equity – with median per capita home equity of $0 (Appendix Table 1).

Education: As with income and savings, homeownership and median per capita home equity both rose with educational attainment. Among beneficiaries with a college degree, median per capita home equity was $236,950, while 16% had no home equity. Among beneficiaries with less than a high school education, median per capita home equity was more than 25 times lower ($8,650) and nearly half (48%) were not homeowners (Appendix Table 1).

Alex Cottrill, Juliette Cubanski, and Tricia Neuman are with KFF. Karen Smith is with the Urban Institute.

Methods

Income and asset levels in 2024 are based on the Urban Institute’s Dynamic Simulation of Income Model (DYNASIM4). DYNASIM4 is a dynamic microsimulation model that projects the population and analyzes the long-term distributional consequences of retirement and aging issues. The model starts with a representative sample of individuals and families and ages the data year by year, simulating demographic and economic events including all key components of retirement income. The model integrates many important trends and differences among groups in life course processes, including birth, death, schooling, leaving home, first marriage, remarriage, divorce, disability, work, retirement, and earnings.

Estimates of income take into account Social Security payments, pensions, and other income sources, such as income from assets (e.g., stocks and bonds), rental income, capital gains, partnership and S-corp income, and retirement account (IRA) withdrawals. Estimates of savings take into account retirement account holdings (such as IRAs or 401Ks) and other financial assets such as savings accounts, stocks, and bonds. DYNASIM stock and bond returns use historic data through 2023, based on the Stocks, Bonds, Bills and Inflation (SBBI) 2020 Yearbook and Federal Reserve Economic Data (FRED). Estimates of home equity reflect total home value minus home debt (e.g., mortgages) and are adjusted based on the Case-Shiller US National Home Price Index through 2023. Total household income, savings, and home equity are split equally between spouses in order to estimate per capita values for married beneficiaries. Roughly half of all people with Medicare are unmarried (e.g., single, widowed, or divorced), according to a KFF analysis of the Medicare Current Beneficiary Survey 2021. All dollar amounts are presented in 2024 dollars on a per capita basis. Estimates presented here excluded people who died during the year.

Estimates of per capita income in this analysis include a few income sources (capital gains, partnership and S-corp income) that were not included in KFF’s previously published analysis using Dynasim. This means that newer per capita income estimates are not directly comparable to older estimates in KFF’s previously published analysis.

Appendix

Median Per Capita Income, Savings, and Home Equity of Medicare Beneficiaries by Selected Demographic Characteristics, 2024
Median Per Capita Income, Savings, and Home Equity of Medicare Beneficiaries by Selected Demographic Subgroups, 2024
Distribution of Medicare Beneficiaries' Per Capita Income, Savings, and Home Equity by Age, 2024

Tariffs Are Driving up Premiums for Small Businesses

Authors: Matt McGough, Kaitlyn Vu, and Cynthia Cox
Published: Aug 25, 2025

Small businesses may expect that the recent tariffs levied by President Trump will drive up the price of multiple imported goods from various countries. But less expected is how these trade policies may ripple through employee health benefits. Most recently, President Trump indicated that the administration will phase in tariffs on pharmaceutical imports—starting with a “small tariff,” climbing to 150% within roughly 12 to 18 months, and eventually rising to as much as 250%—as part of an effort to bring drug manufacturing back to the U.S.

Tariffs can indirectly affect health insurance premiums by increasing the cost of imported medical goods, especially prescription drugs. When pricing plans, insurers must make assumptions about future medical costs, often months in advance. In the absence of clear policy guidance, some insurers take a cautious approach by incorporating potential cost increases into their proposed rates for the upcoming plan year. Rather than waiting for final decisions, some carriers preemptively accounted for these risks to avoid underpricing. This can be particularly true when the affected drugs are brand-name or specialty medications with limited alternatives, many of which are imported. By building in assumptions about possible cost increases, tariffs can influence premiums even before any measurable price change has occurred, particularly in markets where insurers may already operate on tighter margins.

The share of total health claims attributable to pharmaceuticals varies by market segment but generally makes up between one-sixth and one-fifth of total claims after adjusting for pharmaceutical rebates.

Pharmaceuticals make up a slightly larger share of health claims for insurers covering small businesses

Pharmaceuticals comprise a slightly larger share of total health care claims in the small group market compared to the individual and large group markets. In the small group market, pharmaceuticals account for just under one-fifth of all claims (19.2%), while the share is slightly lower in the individual (18.2%) and large group (17.9%) markets.

Health insurance companies must submit their proposed premium changes for the coming year to state regulators in the spring and summer. As part of this process, some insurers in the Affordable Care Act (ACA)-compliant guaranteed-issue small group market — just as in the individual market — are explicitly citing tariffs, particularly those affecting pharmaceutical imports, as a reason for higher-than-expected premium increases. In the individual market, several insurers have included upward adjustments of about 3% in response to anticipated increases in drug costs tied to tariffs, while others acknowledge the risk but have not incorporated it into their pricing assumptions. Of the 88 small group market rate filings reviewed in detail, one-quarter (22 insurers) explicitly mentioned tariffs. Other insurers may have factored in tariff effects without stating so directly.

In several states, small group filings note that new import tariffs are expected to increase the cost of certain brand-name and specialty drugs, especially those without generic alternatives.

“IHBC is seeking an overall rate change of 18.9% in 2026, primarily due to increased costs due to inflation and tariffs.” – Independent Health Benefits Corporation (New York)

“To account for uncertainty regarding tariffs and/or the onshoring of manufacturing and their impact on total medical costs, most notably pharmaceuticals, a total claims impact of 2.9% is built into the initially submitted rate filings. This has increased our premium by roughly 2.7%.” – United Healthcare Insurance Company (Oregon)

Among small group insurers that have accounted for the potential impact of tariffs in their rate filings, the estimated premium effect ranges from 1.7% to 3.0%. Other insurers reference the possibility of tariffs but do not factor them into their pricing assumptions.

“Neighborhood did not consider the impact of tariffs during rate development as rates were created based on current law today and too much uncertainty remains of what (if any) tariffs will become final.” – Neighborhood Health Plan of Rhode Island (Rhode Island)

Because insurers in the ACA-compliant small group market must lock in premiums well ahead of the coverage year — often six to nine months in advance — they are frequently pricing against policy uncertainty. Unlike inflation or shifts in service utilization where insurers can draw on historical experience, there is little precedent for how sweeping import tariffs could affect prescription drug pricing.

Additionally, ACA-compliant small group insurers must also adhere to Medical Loss Ratio (MLR) requirements, which limit the share of premiums that can go toward administrative costs and profit. If premiums overshoot actual spending, carriers are required to issue rebates. But if they underprice premiums and tariffs drive up drug costs, insurers could face financial shortfalls.

This dynamic could translate into higher employee benefit costs for small businesses as these tariffs take effect and impact drug prices. For employers operating on narrow margins, even small premium increases can influence decisions around employer contributions, cost sharing, or continuing to offer coverage at all. While ACA’s MLR rules shield employers from some costs by requiring insurers to return excess premiums if spending falls short, these rules do not insulate businesses or workers from the upfront burden of higher premiums. With no clear precedent to guide assumptions, tariff-related uncertainty is now a factor in how some small group insurers approach rate-setting — adding a new variable to the affordability of some job-based coverage.

CMS Phasing Out Medicaid Workforce Initiatives

Section 1115 Waiver Watch

Published: Aug 25, 2025

On July 11, the Centers for Medicare and Medicaid Services (CMS) released a letter to states notifying them that going forward CMS does not anticipate approving new 1115 demonstration workforce initiatives or extending existing waivers. This is the latest action by the second Trump administration reversing major Biden administration waiver priorities. 1115 waivers generally reflect priorities identified by states as well as changing priorities from one presidential administration to another.

Gaps in access to certain providers (e.g., psychiatrists, primary care providers, dentists, and long-term care providers) have been ongoing challenges in Medicaid. Access gaps may reflect system-wide problems, but may be exacerbated by provider shortages in low-income communities, Medicaid’s lower physician payment rates, and lower Medicaid physician participation compared with private insurance. State strategies to address workforce shortages can include increasing rates, reducing provider administrative burden, extending the workforce, and incentivizing participation (such as through student loan repayment or retention bonuses). Improving coverage and access was a strategic priority for the Biden administration, as was strengthening the mental health workforce. Section 1115 waivers have been used as a strategy to invest in the Medicaid workforce and help address provider shortages. Changes to 1115 waiver policy and broader federal Medicaid spending reductions may limit states’ abilities to pursue initiatives investing in the Medicaid workforce, as well as cause states to take actions such as reducing Medicaid provider payment rates that could increase gaps in access. 

Since June 2022, five states (California, Massachusetts, New York, North Carolina, and Vermont) have received approval for waivers that invest in the Medicaid workforce. Some states had used 1115 waivers prior to 2022 to expand workforce capacity, most notably through Delivery System Reform Incentive Payment (DSRIP) waivers. Approved workforce initiatives since 2022 have been focused on investments in qualified providers who make multi-year commitments to working with a patient panel with a minimum percentage of Medicaid and/or uninsured patients. These initiatives include: student loan repayment programs for qualified providers (e.g., registered nurses, nurse practitioners, physician assistants, psychiatrists), recruitment and retention bonuses, training programs, and payments to support additional residency slots (Table 1). The workforce initiatives primarily target providers working in behavioral health, primary care, and long-term care.

In the approvals, CMS explained that states “continue to face health care provider shortages,” which were further exacerbated by the COVID-19 public health emergency, and that these approvals were intended to increase the availability of providers who serve Medicaid beneficiaries. North Carolina, for example, reported in its application that psychiatrists in North Carolina are only meeting 13% of the need in the state, and nearly a third of counties do not have any practicing psychologists. California stakeholders identified the behavioral workforce crisis as the most significant challenge to implementing new behavioral health services in the state. While there is limited implementation data on these workforce initiatives to date (as several waivers were only recently approved), Section 1115 demonstration waivers are subject to regular reporting, monitoring, and evaluation requirements that will provide evidence on the effectiveness of these types of interventions.

Combined, four states have been approved for at least $2.7 billion in total expenditure authority (including both federal and state spending). (In Vermont’s waiver, workforce initiatives are included as part of an umbrella “Investments Framework,” so maximum funding amounts specific to workforce programs are not outlined.) These workforce initiatives are components of broader 1115 waivers. Waivers must be budget neutral (meaning federal costs under an 1115 waiver may not exceed what they would have been for that state without the waiver) and states must use waiver savings to offset expenditures on the approved 1115 workforce programs.  In addition, CMS specified that some states could access federal matching funds for spending on “Designated State Health Programs (DSHP),” with states using “freed up” state funds to help finance the state share of new workforce initiatives.

In its recent letter, CMS said it would not approve 1115 workforce initiatives going forward. Currently approved waivers will be allowed to “run their course,” but CMS does not anticipate extending the workforce initiatives when the waivers are due for renewal. Most of the approved workforce waivers are set to expire in 2027, although California and North Carolina’s waivers are not due to expire until 2029 (Table 1). CMS is also unlikely to approve requests for new workforce initiatives, such as Florida’s May 2025 request for federal matching funds for workforce training and loan repayment programs for doctors, nurses, physician assistants, dentists, dental hygienists, and mental health practitioners who serve Medicaid recipients in medically underserved areas. In the letter phasing out workforce authority, CMS said it is prioritizing “actions that demonstrate clear health benefits, cost savings, and strong accountability for federal spending.”

This CMS guidance is the latest action by the Trump administration undoing Biden administration 1115 waiver policies. CMS also announced in July that it does not anticipate extending existing or approving new section 1115 continuous eligibility waivers for adults or children enrolled in Medicaid coverage.Previous actions from the Trump administration earlier this year also signaled efforts to curtail waivers related to social determinants of health (which also included efforts to bolster access and increase provider payment rates) and to limit waiver financing tools and flexibility. Section 1115 priorities often change from one presidential administration to another; the current administration has not yet enumerated its priorities for 1115 waiver policy.

Interactive DataWrapper Embed

Health Provisions in the 2025 Federal Budget Reconciliation Law

Published: Aug 22, 2025

Editorial Note: Originally published Aug. 4, 2025, this summary has been updated to include the CBO’s coverage estimates for the relevant provisions.

Overview

On July 3, the House passed the same version of the budget reconciliation bill that the Senate passed on July 1. On July 4, President Trump signed the bill, previously known as the “One Big Beautiful Bill Act,” into law. This summary describes the health care provisions in four categories: Medicaid, the Affordable Care Act, Medicare and Health Savings Accounts (HSAs). Included are the Congressional Budget Office (CBO) estimates for the impact of each provision (note coverage estimates for each provision will not sum to the law’s total coverage estimate). The CBO has stated the law will reduce federal spending on health care by over $1 trillion and lead to a 10 million increase in the country’s uninsured population.

An implementation timeline of the health provisions is available along with more background and a side-by-side comparison of the House and Senate passed bills.

Medicaid

Eligibility and Cost Sharing Policies

Section 71119: Work Requirements

Background

Prior to passage of the federal budget reconciliation law, Medicaid eligibility could not be conditioned on meeting a work or reporting requirement without obtaining a Medicaid Section 1115 waiver. During the first Trump administration, 13 states received approval to implement work requirements through Section 1115 waivers. Work requirement waiver approvals were either rescinded by the Biden administration or withdrawn by states, and Georgia is the only state with a Medicaid work requirement waiver currently in place. Since the beginning of Trump’s second term, some states have shown renewed interest in pursuing work requirement policies through 1115 waivers.

Description

  • Requires states to condition Medicaid eligibility for individuals ages 19-64 applying for coverage or enrolled through the ACA expansion group (or a waiver) on working or participating in qualifying activities for at least 80 hours per month or attending school at least half-time.
  • Mandates that states exempt certain adults, including parents with children ages 13 and under, those who are medically frail, and those who are participating in a substance use disorder treatment program, from the requirements.
  • Requires states to verify that individuals applying for coverage meet the requirements for 1 and up to a maximum of 3 consecutive months preceding the month of application and that individuals who are enrolled meet the requirements for 1 or more months between the most recent eligibility redeterminations (at least twice per year).
  • Requires states to use data matching “where possible” to verify whether an individual meets the requirement or qualifies for an exemption.
  • Specifies that if a person is denied or disenrolled due to work requirements, they are also ineligible for subsidized Marketplace coverage.
  • Prohibits these provisions from being waived, including under Section 1115 authority.
  • Allows the Secretary to exempt states from compliance with the new requirements until no later than December 31, 2028, if the state is demonstrating a good faith effort to comply and submits progress in compliance or other barriers to compliance.
  • Provides $200 million in funding to states for systems development for FY 2026 and an additional $200 million to HHS to support implementation (for FY 2026).

Effective Date: Not later than December 31, 2026, or earlier at state option.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $326 billion over 10 years and will increase the number of people who are uninsured by 5.3 million in 2034.

KFF Resources

Section 71107: More Frequent Eligibility Determinations

Background

Under the Affordable Care Act (ACA), states are required to renew eligibility every 12 months for Medicaid enrollees whose eligibility is based on modified adjusted gross income (MAGI), including children, pregnant individuals, parents, and expansion adults. For enrollees whose eligibility is based on age 65+ or disability, states must renew eligibility at least every 12 months . States are required to review eligibility within the 12-month period if they receive information about a change in a beneficiary’s circumstances that may affect eligibility.

Description

  • Requires states to conduct eligibility redeterminations every 6 months for Medicaid expansion adults.
  • Provides $75 million in implementation funding for FY 2026.

Effective Date: For renewals scheduled on or after December 31, 2026.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $63 billion over 10 years years and will increase the number of people who are uninsured by 700,000 in 2034.

KFF Resources

Section 71103: Verifying Enrollee Address and Other Information

Background

The Eligibility and Enrollment final rule issued in April 2024 requires states to leverage reliable data sources to update enrollee address information, effective June 2025.

Description

  • Requires states to update enrollee address information using reliable data sources, including the National Change of Address Database and managed care entities.
  • Requires the Secretary to establish a system to share information with states for purposes of preventing individuals from being simultaneously enrolled in two states and requires states to submit monthly enrollee SSNs and other information to the system.

Effective Date: January 1, 2027 for states to obtain contact information; October 1, 2029 to establish system to prevent enrollment in two states simultaneously.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $17 billion over 10 years. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Section 71104: Ensuring Deceased Individuals Do Not Remain Enrolled

Description

  • Requires states to review the Master Death File at least quarterly to determine if any enrolled individuals are deceased.

Effective Date: January 1, 2027.

Budgetary and Coverage Impact

CBO estimates this provision will not affect federal Medicaid spending over 10 years. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Section 71102: Eligibility and Enrollment Final Rule

Background

In April 2024, CMS issued a final rule to streamline application and enrollment processes in Medicaid, align renewal policies for all Medicaid enrollees, facilitate transitions between Medicaid, CHIP, and subsidized Marketplace coverage, and eliminate certain barriers in CHIP. Implementation deadlines for states vary across provisions, but many provisions in the rule are already in effect, and for others, states are already in compliance.

Description

  • Prohibits the Secretary from implementing, administering, or enforcing certain provisions that have not yet taken effect in an April 2024 CMS final rule until October 1, 2034.

Effective Date: Upon enactment.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $56 billion over 10 years and will increase the number of people who are uninsured by 400,000 in 2034.

KFF Resources

Section 71101: Medicare Savings Program Final Rule

Background

In September 2023, CMS issued a final rule to reduce barriers to enrollment in Medicare Savings Programs (MSPs), which provide Medicaid coverage of Medicare premiums and cost sharing for low-income Medicare beneficiaries. Implementation deadlines for states vary across provisions in the rule, but many provisions are already in effect, and for others, states are already in compliance.

Description

  • Prohibits the Secretary from implementing, administering, or enforcing certain provisions in a September 2023 final rule that have not yet taken effect until October 1, 2034.

Effective Date: Upon enactment.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $66 billion over 10 years. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Section 71109: Restricting Immigrant Eligibility for Medicaid and CHIP

Background

In addition to meeting other eligibility requirements, lawfully present immigrants must have a “qualified” immigration status to be eligible for Medicaid or CHIP. Qualified immigrants include: lawful permanent residents (LPRs); refugees; individuals granted parole for at least one year; individuals granted asylum or related relief; certain abused spouses and children; certain victims of trafficking; Cuban and Haitian entrants; and citizens of the Freely Associated States (COFA migrants) residing in states and territories. Many lawfully present immigrants must wait five years after obtaining qualified status before they may enroll in Medicaid; states may waive the five-year wait for children and pregnant individuals (referred to as the ICHIA option). Some states have state-only funded coverage programs for undocumented immigrants.

Description

  • Restricts the definition of qualified immigrants for purposes of Medicaid or CHIP eligibility to Lawful Permanent Residents (“green card” holders), certain Cuban and Haitian immigrants, citizens of the Freely Associated States (COFA migrants) lawfully residing in the US, and lawfully residing children and pregnant adults in states that cover them under the ICHIA option.
  • Provides $15 million in implementation funding for FY 2026.

Effective Date: October 1, 2026.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $6 billion over 10 years and will increase the number of people who are uninsured by 100,000 in 2034.

KFF Resources

Section 71112: Retroactive Coverage

Background

Under current law, states are required to provide Medicaid coverage for qualified medical expenses incurred up to 90 days prior to the date of application for coverage.

Description

  • Limits retroactive coverage to one month prior to application for coverage for individuals enrolled through the Medicaid expansion and two months prior to application for coverage for traditional enrollees.
  • Provides $15 million in implementation funding for FY 2026.

Effective Date: January 1, 2027.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $4 billion over 10 years and will increase the number of people who are uninsured by 100,000 in 2034.

Section 71120: New Cost Sharing Requirements for Certain Expansion Individuals

Background

States have the option to charge premiums and cost-sharing for Medicaid enrollees within limits, and certain populations and services (emergency, family planning, pregnancy and preventive) are exempt from cost-sharing. Cost-sharing is generally limited to nominal amounts but may be higher for those with income above 100% of the federal poverty level (FPL). Out-of-pocket costs cannot exceed 5% of family income. States may allow providers to deny services to enrollees for nonpayment of copayments.

Description

  • Requires states to impose cost sharing of up to $35 per service on expansion adults with incomes 100-138% FPL; maintains existing exemptions of certain services from cost sharing and exempts primary care, mental health, and substance use disorder services and services provided by federally qualified health centers, behavioral health clinics, and rural health clinics from cost sharing; limits cost sharing for prescription drugs to nominal amounts.
  • Maintains the 5% of family income cap on out-of-pocket costs.
  • Permits states to allow providers to deny services for failure to pay cost sharing but does not prevent providers from reducing or waiving cost sharing.
  • Eliminates enrollment fees or premiums for expansion adults.

Effective Date: October 1, 2028.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $7 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Financing

Section 71115: Provider Taxes

Background

States are permitted to finance the non-federal share of Medicaid spending through multiple sources, including state general funds, health care related taxes (or “provider taxes”), and local government funds. Federal rules specify provider taxes must be broad-based and uniform (i.e., states can’t limit provider taxes to only Medicaid providers) and may not hold providers “harmless” (i.e., guarantee providers receive their money back). The hold harmless requirement does not apply when tax revenues comprise 6% or less of providers’ net patient revenues from treating patients (referred to as the “safe harbor” limit).

Description

  • Prohibits all states from establishing any new provider taxes or from increasing the rates of existing taxes.
  • Reduces the safe harbor limit for states that have adopted the ACA expansion by 0.5% annually starting in fiscal year 2028 until the safe harbor limit reaches 3.5% in FY 2032.
  • Applies the new safe harbor limit in expansion states to state and local government taxes on all providers except nursing facilities and intermediate care facilities.
  • Provides $20 million in implementation funding for FY 2026.

Effective Date: Upon enactment for prohibition of new or increased taxes; October 1, 2027 for reduction in safe harbor limit.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $191 billion over 10 years and will increase the number of people who are uninsured by 1.1 million in 2034.

KFF Resources

Section 71117: Requirements for Provider Tax Uniformity Waivers

Background

States are permitted to finance the non-federal share of Medicaid spending through multiple sources, including state general funds, health care related taxes (or “provider taxes”), and local government funds. Federal rules specify provider taxes must be broad-based and uniform (i.e., states can’t limit provider taxes to only Medicaid providers) and may not hold providers “harmless” (i.e., guarantee providers receive their money back).

Description

  • Revises the conditions under which states may receive a waiver of the requirement that taxes be broad-based and uniform so that some currently permissible taxes, such as those on managed care plans, will no longer be permissible in future years.
  • Provision overlaps with a proposed rule released May 12, 2025.

Effective Date: Upon enactment; HHS Secretary may provide a transition period of up to three years.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $35 billion over 10 years and will increase the number of people who are uninsured by 100,000 in 2034.

KFF Resources

Section 71116: State Directed Payments

Background

States are generally not permitted to direct how managed care organizations (MCOs) pay their providers. However, subject to CMS approval, states may use “state directed payments” (SDPs) to require MCOs to pay providers certain rates, make uniform rate increases (that are like fee-for-service supplemental payments), or to use certain payment methods.

A 2024 rule on access to care in Medicaid managed care codified that the upper limit for SDPs is the average commercial rate for hospitals and nursing facilities, which is generally higher than the Medicare payment ceiling used for other Medicaid fee-for-service supplemental payments.

Description

  • Directs HHS to revise Medicaid regulations for state directed payment to cap the total payment rate for inpatient hospital and nursing facility services at 100% of the total published Medicare payment rate for expansion states and at 110% of the total published Medicare payment rate for non-expansion states.
  • Prevents payments approved after May 1, 2025 in excess of the new limits from taking effect unless they are for rural hospitals.
  • Reduces existing payments that are above the allowable Medicare-related payment limit by 10 percentage points each year until they reach the new lower limit.
  • Specifies that in the absence of published Medicare payment rates, the limit is set at the Medicaid fee-for-service payment rate.

Effective Date: Upon enactment for lower limit on new state directed payments; January 1, 2028 for reduction in existing state directed payments above new allowable Medicare-related limit.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $149 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Section 71118: Section 1115 Demonstration Waiver Budget Neutrality

Background

Under long-standing policy and practice, Section 1115 demonstration waivers must be “budget neutral” to the federal government over the course of the waiver. Federal costs under an 1115 waiver may not exceed what they would have been for that state without the waiver. Typically, budget neutrality calculations are determined on a per enrollee basis—so, per enrollee spending over the course of the waiver (usually 5 years) cannot exceed the projected per enrollee spending calculated in the “without-waiver baseline.”

Budget neutrality calculations and the use of “savings” when expenditures decrease on account of the waiver are negotiated between states and CMS and the Office of Management and Budget.

Description

  • Specifies the Chief Actuary for CMS must certify 1115 waivers are not expected to result in an increase in federal expenditures compared to federal expenditures without the waiver.
  • Provides $5 million in implementation funding for each of FY 2026 and FY 2027.

Effective Date: January 1, 2027.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $3 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Section 71106: Payment Reduction for Certain Erroneous Medicaid Payments

Background

Federal law directs CMS to recoup federal funds for erroneous payments made for ineligible individuals and overpayments for eligible individuals if the state’s eligibility “error rate” exceeds 3%. CMS may waive the recoupment if the Medicaid agency has taken steps to demonstrate a “good faith” effort to get below the 3% allowable threshold.

Description

  • Requires HHS to reduce federal financial participation to states for identified improper payment errors related to payments made for ineligible individuals and overpayments made for eligible individuals.
  • Expands the definition of improper payments to include payments where insufficient information is available to confirm eligibility.

Effective Date: October 1, 2029.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $8 billion over 10 years and will increase the number of people who are uninsured by 100,000 in 2034.

KFF Resources

Medicaid Expansion

Section 71114: Eliminating Temporary Financial Incentive for Medicaid Expansion

Background

The Affordable Care Act expands Medicaid eligibility to non-elderly adults with incomes up to 138% FPL based on modified adjusted gross income and provides 90% federal financing for the expansion population. The Supreme Court effectively made expansion an option for states. The American Rescue Plan Act (ARPA) added a temporary financial incentive for states that newly adopt expansion. Currently, 41 states, including DC, have implemented the Medicaid expansion.

Description

  • Eliminates the temporary incentive for states that newly adopt the Medicaid expansion.

Effective Date: January 1, 2026.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $14 billion over 10 years and will increase the number of people who are uninsured by 100,000 in 2034.

KFF Resources

Section 71110: Federal Medical Assistance Percentage (FMAP) for Emergency Medicaid

Background

Emergency Medicaid reimburses hospitals for the costs of emergency care provided to immigrants who would qualify for Medicaid except for their immigration status, which hospitals are required to provide under federal law. States receive federal matching payments based on the federal medical assistance percentage (FMAP), which is computed using a formula that takes into account states’ per capita income, for traditional populations; they receive a 90% federal match rate for individuals enrolled in the Medicaid expansion.

Description

  • Limits federal matching payments for Emergency Medicaid for individuals who would otherwise be eligible for expansion coverage except for their immigration status to the state’s regular FMAP.
  • Provides $1 million in implementation funding for FY 2026.

Effective Date: October 1, 2026.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $28 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Long-term Care

Section 71111: Nursing Home Staffing Final Rule

Background

A 2024 Biden-administration final rule requires long-term care facilities (LTC) to meet minimum staffing levels (including a 24/7 RN on-site and a minimum of 3.48 total nurse staffing hours per resident day), requires state Medicaid agencies to report the share of Medicaid payments for institutional LTC that are spent on worker compensation, and provides funding for people to enter careers in nursing homes.

Description

  • Prohibits the Secretary of Health and Human Services from implementing, administering, or enforcing the minimum staffing levels required by the final rule until October 1, 2034.

Effective Date: Upon enactment.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $23 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Section 71108: Home Equity Limits

Background

Most Medicaid enrollees who qualify for Medicaid because they need long-term care (LTC) are subject to limits on their home equity. In 2025, federal rules specified that states’ limits on home equity must be between $730,000 and $1,097,000, and those amounts are updated each year for inflation.

Description

  • Reduces the maximum home equity limits to $1,000,000 regardless of inflation.
  • Allows states to apply different requirements for homes that are located on farms.

Effective Date: January 1, 2028.

Budgetary and Coverage Impact

CBO estimates this provision will reduce federal Medicaid spending by $195 million over 10 years. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Section 71121: New Home and Community Based Services (HCBS)

Background

States are required to cover nursing facility care under Medicaid, but nearly all home care (HCBS) is optional. Nearly all states provide home care through “1915(c) waivers,” which limit services to people who require an institutional level of care. Because those services are optional, states may limit the amount of care people receive and the number of people receiving services. Most states have waiting lists because the number of people seeking services exceeds the amount of care available.

Description

  • Allows states to establish 1915(c) HCBS waivers for people who do not need an institutional level of care.
  • Requires state waiver submissions to demonstrate that new waivers will not increase the average amount of time that people who need an institutional level of care will wait for services.
  • Includes $50 million in FY 2026 and $100 million in FY 2027 for implementation.

Effective Date: July 1, 2028 for new waiver approvals.

Budgetary and Coverage Impact

CBO estimates this provision will increase federal Medicaid spending by $7 billion over 10 years. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Access

Section 71401: Rural Health Transformation Program

Description

  • Establishes a rural health transformation program that will provide $50 billion in grants to states between fiscal years 2026 and 2030, to be used for payments to rural health care providers and for other purposes.
  • Distributes 50% of payments equally across states with approved applications; the remaining funds will be distributed by CMS based at least in part on states’ rural populations that live in metropolitan statistical areas, the percent of rural health facilities nationwide that are located in a state, and the situation of hospitals that serve a disproportionate number of low-income patients with special needs.
  • Uses of funds include promoting care interventions, paying for health care services, expanding the rural health workforce, and providing technical or operational assistance aimed at system transformation.
  • Provides CMS with $200 million in implementation funding for FY 2025.

Effective Date: Upon enactment but funding is first available in fiscal year 2026. CMS to determine state application deadline, which will be no later than December 31, 2025.

Budgetary and Coverage Impact

CBO estimates this provision will increase federal spending by $47 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Section 71113: Prohibiting Federal Medicaid Payments to Certain Providers

Background

States must generally allow beneficiaries to obtain Medicaid services from any provider that is qualified and willing to furnish services. Managed care organizations (MCOs) may restrict enrollees to providers in the MCO’s network, except that such plans cannot restrict free choice of family planning providers.

Description

  • Prohibits federal Medicaid funds to be paid to providers that meet the following criteria on October 1, 2025: are nonprofit organizations, essential community providers primarily engaged in family planning services or reproductive services, provide for abortions outside of the Hyde exceptions and received $800,000 or more in payments from Medicaid in 2023; this would affect Planned Parenthood and other Medicaid essential community providers.
  • Provides $1 million in implementation funding for FY 2026.

Effective Date: Upon enactment for 1 year; implementation is currently blocked for some providers due to ongoing litigation.

Budgetary and Coverage Impact

CBO estimates this provision will increase federal spending by $53 million over 10 years. This provision is not expected to impact coverage.

KFF Resources

Section 71105: Medicaid Provider Screening Requirements

Background

Provider screening and enrollment is required for all providers in Medicaid fee-for-service or managed care networks. Additionally, the ACA requires states to terminate provider participation in Medicaid if the provider was terminated under Medicare or another state program. CMS has multiple tools to assist states with provider screening and enrollment compliance, including leveraging Medicare data.

Description

  • Requires states to conduct checks at provider enrollment or reenrollment and on a quarterly basis of the Social Security Administration’s Death Master File to determine whether providers enrolled in Medicaid are deceased.

Effective Date: January 1, 2028.

Budgetary and Coverage Impact

CBO estimates this provision will not affect federal Medicaid spending over 10 years. This provision is not expected to impact coverage.

KFF Resources

Affordable Care Act

Sec. 71303: Pre-Enrollment Verification of Eligibility for Premium Tax Credit

Background

Currently, new enrollees are granted conditional eligibility if there is a mismatch in the information they provided and that in federal databases. Enrollees can retain coverage and tax credits for up to 90 days while submitting verification documents. Returning enrollees who take no action during open enrollment are auto-renewed into the same or similar plan. Nearly half of Marketplace enrollees in 2025 auto-renewed.

Description

  • Requires verification of household income, health coverage status or eligibility for coverage, place of residence, family size, status as an eligible alien, and any other information that the Secretary of Health and Human Services deems necessary are verified before coverage.
  • Exchanges can use any third-party sources and any available data for verification.
  • Consumers can still enroll in a plan but cannot receive premium tax credits or cost-sharing reductions (CSRs) until after they verify their eligibility.
  • This provision effectively ends auto-renewals.
  • Restricts premium tax credit eligibility for enrollees who fail to file and reconcile their premium tax credits for one year.
  • Restricts premium tax credit eligibility for enrollees who fail to file and reconcile their premium tax credits for one year.

Effective date: Taxable years beginning after December 31, 2027.

Budgetary and Coverage Impact

Decreases budgetary spending by $36.9 billion and increases revenue by $4.4 billion through 2034 and will increase the number of people who are uninsured by 700,000 in 2034.

KFF Resources

Sec. 71305: Recapture of Excess Premium Tax Credits

Background

Currently, if an enrollee receives excess premium tax credits because their estimated income was lower than their actual income, they must repay the excess. However, for most enrollees, there is a repayment cap that varies based on household income. For enrollees with household incomes at least 400% of the federal poverty level (FPL), there is no limit. They must repay the entirety of their excess tax credit. Other repayment limits vary from $375 for a single person with an income that is 100% FPL up to 200% FPL to $3,250 for families with an income between 300%-400% FPL for tax year 2025.

Description

  • Requires that all premium tax credit recipients repay the full amount of any excess, no matter their income.

Effective date: taxable years beginning after December 31, 2025.

Budgetary and Coverage Impact

Decreases budgetary spending by $17.3 billion and increases revenue by $2.3 billion through 2034 and will increase the number of people who are uninsured by 100,000 in 2034.

KFF Resources

Sec. 71301: ACA Marketplace Coverage Eligibility for Lawfully Present Immigrants

Background

Currently, U.S. citizens and lawfully present immigrants are eligible to enroll in ACA Marketplace coverage and receive premium subsidies and cost-sharing reductions.

Description

  • Limit eligibility for subsidized ACA Marketplace coverage to lawfully present immigrants who are lawful permanent residents (LPRs or “green card” holders), Compact of Free Association (COFA) migrants residing in the U.S., or Cuban and Haitian entrants as defined in section 501(e) of the Refugee Education Assistance Act of 1980, eliminating eligibility for many lawfully present immigrants including refugees, asylees, and people with Temporary Protected Status.

Effective date: Taxable years beginning after December 31, 2026.

Budgetary and Coverage Impact

Decreases budgetary spending by $69.8 billion and increases revenue by $4.8 billion through 2034 and will increase the number of people who are uninsured by 900,000 in 2034.

KFF Resources

Sec. 71302: Premium Tax Credit Eligibility for Lawfully Present Immigrants Ineligible for Medicaid

Background

Currently, lawfully present immigrants with incomes under 100% of the federal poverty level (FPL) who do not qualify for Medicaid coverage due to their immigration status also are eligible for ACA Marketplace coverage.

Description

  • Prohibits lawfully present immigrants ineligible for Medicaid due to immigrant status from receiving tax credits if making below 100% of poverty.

Effective Date: taxable years beginning after December 31, 2025.

Budgetary and Coverage Impact

Decreases budgetary spending by $49.5 billion and increases revenue by $176 million through 2034 and will increase the number of people who are uninsured by 300,000 in 2034.

KFF Resources

Sec. 71304: Special Enrollment Periods (SEPs) and Tax Credit Eligibility

Background

In addition to qualifying life events (QLEs) that enable eligibility for an SEP, people in states that use Federally-Facilitated Marketplaces (FFM) and make no more than 150% of the federal poverty level can apply for a year-round SEP to sign up for coverage. Some state-based exchanges also offer SEPs that are based on the relationship of people’s income to the poverty line. Any person who enrolls in a plan via an SEP is eligible for both premium tax credits and cost-sharing reductions (CSRs). In 2025, enrollees with an income of less than 150% of the federal poverty line made up the largest share of all Marketplace enrollees (47%).

Description

  • Bars any consumer who enrolls in a plan via a non-qualifying life event (QLE) SEP from receiving either premium tax credits or CSRs.

Effective date: Plan years beginning after December 31, 2025.

Budgetary and Coverage Impact

Decreases budgetary spending by $39.5 billion and increases revenue by $1.3 billion through 2034 and will increase the number of people who are uninsured by 400,000 in 2034.

KFF Resources

Expiration of Enhanced Premium Tax Credits

Background

The enhanced premium tax credits were first made available as part of the American Rescue Plan Act in 2021 and later extended through the end of 2025 as part of the Inflation Reduction Act. The ARPA and IRA’s enhanced health insurance tax credits both increase the amount of financial help available to those already eligible for assistance under the ACA and also newly expand subsidies to middle-income people (with incomes over four times the poverty level), many of whom were previously priced out of coverage. These enhanced tax credits, combined with increased funding for outreach and marketing have led to record-high enrollment in the ACA Marketplaces.

Description

  • There was no extension of the enhanced tax credits in the law. The Republican-led Senate opted to use a “current law” baseline for Congressional Budget Office scoring of the budget impact. Therefore, the expiration of the enhanced tax credits was not scored as a new policy change and has no impact in the law’s official budget and coverage estimates.
  • The number of uninsured people will rise by 4.2 million through 2034, and gross benchmark premiums will increase by 7.9% through 2034 without an extension. Permanent extension would increase the budget deficit by $335 billion through 2034.

Effective date: January 1, 2026 (unless extended by Congress).

KFF Resources

Medicare

Eligibility Policies

Section 71201: Limiting Medicare Coverage of Certain Individuals

Background

Prior to passage of the law, residents of the United States, including citizens, permanent residents, and other immigrants that are lawfully present in the country, were eligible for premium-free Medicare Part A if they or their spouses have worked in a job for at least 40 quarters where they paid Medicare payroll taxes and are at least 65 years old. People under age 65 with a qualifying disability, end-stage renal disease (ESRD), and amyotrophic lateral sclerosis (ALS) are also generally eligible. Legal immigrants age 65 or older who do not have this work history could purchase Medicare Part A after residing legally in the U.S. for five years continuously.

Description

  • Restricts Medicare eligibility to U.S. citizens, green card holders, Cuban-Haitian entrants, and people residing under the Compacts of Free Association, eliminating Medicare eligibility for people not included in these groups, such as those with temporary protected status and refugees and asylees.
  • Terminates Medicare coverage no later than 18 months from enactment for anyone who is currently covered but no longer eligible under these changes.

Effective Date: Upon enactment.

Budgetary and Coverage Impact

CBO estimates this provision will reduce Medicare spending by $5.1 billion over 10 years and will increase the number of people who are uninsured by 100,000 in 2034.

KFF Resources

Section 71101: Moratorium on Implementation of Rule Relating to Eligibility and Enrollment in Medicare Savings Programs

Background

In September 2023, CMS issued a final rule to reduce barriers to enrollment in Medicare Savings Programs (MSPs), which provides Medicaid coverage of Medicare premiums and cost sharing for low-income Medicare beneficiaries. Implementation deadlines for states vary across provisions in the rule, but some provisions are already in effect, and for others, states are already in compliance.

Description

  • Prohibits the Secretary from implementing, administering, or enforcing certain provisions in a September 2023 CMS final rule that have not yet taken effect until October 1, 2034.

Effective Date: Upon enactment.

Budgetary and Coverage Impact

CBO estimates the moratorium on this rule will reduce federal Medicaid spending by $66 billion over 10 years due to lower enrollment in the Medicare Savings Programs than if all the provisions of the rule were implemented and enforced. CBO has not provided an updated estimate of how many fewer dual-eligible individuals will be enrolled in Medicaid.

KFF Resources

Physician Payment

Section 71202: Temporary Payment Increase Under the Medicare Physician Fee Schedule

Background

Medicare payment rates to physicians and other clinicians under the Physician Fee Schedule are determined in part by a scaling factor, known as the conversion factor, which is updated each year. Under current law, conversion factor updates are based on statutory factors and other budgetary requirements. Beginning in 2026, the Physician Fee Schedule conversion factor was scheduled to increase by 0.25% each year for most Medicare providers.

Description

  • Provides a temporary one-year increase of 2.5% to the Physician Fee Schedule conversion factor for all services furnished between January 1, 2026 and January 1, 2027.

Effective Date: January 1, 2026.

Budgetary and Coverage Impact

The CBO estimates that this change will increase Medicare spending by $1.9 billion in 2026 and 2027. This provision is not expected to impact coverage.

KFF Resources

Prescription Drugs

Section 71203: Expanding and clarifying the exclusion for orphan drugs under the Drug Price Negotiation Program

Background

Under the Medicare Drug Price Negotiation Program, drugs qualify for price negotiation if they are single source brand-name drugs or biological products without therapeutically equivalent generic or biosimilar alternatives, and are at least 7 years (for small-molecule drugs) or 11 years (for biologics) past the FDA approval or licensure date, as of the date that the list of drugs selected for negotiation is published. Under the Inflation Reduction Act of 2022, the law that established the drug price negotiation program, drugs designated for only one rare disease or condition and approved for an indication (or indications) only for that disease or condition were exempt from negotiation. This is known as the orphan drug exclusion.

Description

  • Modifies the orphan drug exclusion of the Medicare drug price negotiation program to exclude drugs from negotiation that are designated for one or more rare diseases or conditions and where the only approved indication or indications are for one or more rare diseases or conditions, rather than only one rare disease or condition.
  • Excludes the period of time that drugs are on the market with only one or more orphan indications from the 7-year or 11-year waiting period that determines a drug’s eligibility for selection for price negotiation.

Effective Date: applies for drug price selection beginning in February 2026 for negotiated prices available on or after January 1, 2028.

Budgetary and Coverage Impact

The CBO estimates that this change will increase Medicare spending by $4.9 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Long-term Care

Section 71111: Moratorium on Implementation of Nursing Home Staffing Final Rule

Background

A 2024 Biden administration final rule requires long-term care facilities (LTC) to meet minimum staffing levels (including a 24/7 RN on-site and a minimum of 3.48 total nurse staffing hours per resident day), requires state Medicaid agencies to report the share of Medicaid payments for institutional LTC that are spent on worker compensation, and provides funding for people to enter careers in nursing homes.

On April 7, 2025, the US District Court for Northern Texas ruled to overturn the minimum staffing requirements, and it is expected that the Administration will not appeal that decision.

Description

  • Prohibits the Secretary of Health and Human Services from implementing, administering, or enforcing the minimum staffing levels required by the final rule until October 1, 2034.

Effective Date: Upon enactment.

Budgetary and Coverage Impact

The CBO estimates the moratorium of this rule will reduce federal spending by $23 billion over 10 years. This provision is not expected to impact coverage.

KFF Resources

Health Savings Accounts

Section 71306. Permanent Extension of Safe Harbor for Absence of Deductible for Telehealth Services

Background

Health savings accounts (HSAs) are tax-advantaged savings accounts that enrollees in certain high-deductible health plans (HDHPs) can use to pay for qualified medical expenses. Enrollees must pay all medical costs, except for certain preventive services and insulin products, out-of-pocket until they reach the deductible. Individuals cannot have other health coverage in order to be eligible for an HDHP with an HSA. In response to the COVID pandemic, federal law permitted HSA-eligible HDHPs to cover telehealth and other remote services before the deductible until the end of 2024.

Description

  • Permanently allows HDHPs with an HSA to cover telehealth and other remote services before the enrollee meets the deductible.
  • Individuals that have other coverage for telehealth and other remote care services will still be eligible for an HDHP with an HSA.

Effective date: Plan years beginning after December 31, 2024.

Budgetary and Coverage Impact

The CBO and JCT estimate a decrease in revenue of $4.3 billion through 2034. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Section 71307. Allowance of Bronze and Catastrophic Plans in Connection with Health Savings Accounts

Background

ACA-compliant health insurance plans are categorized into “metal levels” based on the amount of cost sharing they require. Some bronze plans meet the deductible requirements to be paired with an HSA (the out-of-pocket maximum or other design features might not meet IRS rules though). Catastrophic plans, which have the highest cost sharing and are only available to people under age 30 or those who cannot find other affordable ACA-compliant coverage, are ineligible to be paired with an HSA.

Description

  • Treats bronze and catastrophic plans sold on and off the ACA Marketplace as HDHPs that can be paired with an HSA.

Effective date: January 1, 2026.

Budgetary and Coverage Impact

The CBO and JCT estimate a decrease in revenue of over $3.5 billion through 2034. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Section 71308. Treatment of Direct Primary Care Arrangements

Background

Direct primary care (DPC) arrangements typically offer unlimited primary care services to patients in exchange for a periodic fee paid to the DPC practice. Current law may treat DPC arrangements as a health plan under certain circumstances, making an individual covered by a DPC arrangement ineligible to use an HSA.

Description

  • Certain DPC arrangements will not be considered health plans, allowing individuals covered by these arrangements to be eligible for an HSA. This will apply if the only compensation for the DPC is a fixed periodic fee that does not exceed $150 monthly, or $300 monthly where more than one individual is covered.
  • For the purposes of this provision, DPC arrangements not considered health plans are limited to those only offering primary care services, and do not include:
  • services that require general anesthesia;
  • prescription drugs, except for vaccines, and;
  • laboratory services not typically administered in an ambulatory primary care setting.
  • Treats fees paid for any DPC arrangement as a medical expense (not the payment of insurance) that can be paid for with HSA funds.

Effective date: January 1, 2026.

Budgetary and Coverage Impact

The CBO and JCT estimate a decrease in revenue of over $2.8 billion through 2034. This provision is not expected to impact the number of people who are uninsured.

KFF Resources

Global COVID-19 Tracker

Published: Aug 21, 2025

Editorial Note: The Policy Actions tracker will no longer be updated as the data source has ceased tracking government responses to COVID-19. For more information, please visit the Oxford Covid-19 Government Response Tracker.

Cases and Deaths

This tracker provides the cumulative number of confirmed COVID-19 cases and deaths, as well as the rate of daily COVID-19 cases and deaths by country, income, region, and globally. It will be updated weekly, as new data are released. As of March 7, 2023, all data on COVID-19 cases and deaths are drawn from the World Health Organization’s (WHO) Coronavirus (COVID-19) Dashboard. Prior to March 7, 2023, this tracker relied on data provided by the Johns Hopkins University (JHU) Coronavirus Resource Center’s COVID-19 Map, which ended on March 10, 2023. Please see the Methods tab for more detailed information on data sources and notes. To prevent slow load times, the tracker only contains data from the last 200 days. However, the full data set can be downloaded from our GitHub page. While the tracker provides the most recent data available, there is a two-week lag in the data reporting.

Note: The data in this tool were corrected on March 18, 2024, to clarify that they represent new cases and deaths over a full week rather than the average per day over a seven-day period.

Policy Actions

Editorial Note

The Policy Actions tracker will no longer be updated as the data source has ceased tracking government responses to COVID-19. For more information, please visit the Oxford Covid-19 Government Response Tracker.

This tracker contains information on policy measures currently in place to address the COVID-19 pandemic. Policy categories currently being tracked include social distancing & closure measures, economic measures, and health systems measures. Policies are tracked at the country-, income-, and region-level. Please see the Methods tab for more detailed information on data sources and notes.

Social Distancing and Closure Measures

As countries continue to implement policies to prevent the transmission of SARS-CoV-2, the virus that causes COVID-19, these tables and charts show which social distancing and closure measures are currently in place by country.

Global COVID-19 Policy Actions

Economic Measures

The COVID-19 pandemic has placed an unprecedented strain on country economies. These tables and charts show which economic-related measures, namely income support and debt relief, are currently in place by country.

Global COVID-19 Policy Actions

Health Systems Measures

The COVID-19 pandemic continues to strain and disrupt global health systems. These tables and charts show which health systems measures are currently in place by country.

Global COVID-19 Policy Actions

Methods

Cases and Deaths

SOURCES

As of March 7, 2023, all data on COVID-19 cases and deaths are drawn from the World Health Organization’s (WHO) Coronavirus (COVID-19) Dashboard. Prior to March 7, 2023, this tracker relied on data provided by the Johns Hopkins University (JHU) Coronavirus Resource Center’s COVID-19 Map, which ends on March 10, 2023. Population data are obtained from the United Nations World Population Prospects using 2021 total population estimates. Income-level classifications are obtained from the latest World Bank Country and Lending Groups. Regional classifications are obtained from the World Health Organization.

Policy Actions

NOTES

Policy actions data include the measure that was in place for each indicator at the country-level as of the end of 2022. Policy actions data will no longer be updated as the data source has ceased tracking government responses to COVID-19. For more information, please visit the Oxford Covid-19 Government Response Tracker.

Social Distancing and Closure Measures

Under ‘Stay At Home Requirements’, exceptions for leaving the house may include anything from being able to leave for daily exercise, grocery shopping, and essential trips, to only being allowed to leave once a week, or one person may leave at a time, etc. Under ‘Workplace Closing’, partial closing includes instances in which a country recommends closing the workplace (or working from home); businesses are open but with significant COVID-19-related operational adjustments; or when workplaces require closing for only some, but not all, sectors or categories of workers. Under ‘School Closing’, partial closing includes instances in which a country has recommended school closures; all schools are open but with significant COVID-19-related operational adjustments; or some schools, but not all, are closed; full closing includes schools that are in session but operating virtually. Under ‘Restrictions On Gatherings’, partial restrictions include restrictions on gatherings of more than 10 people; full restrictions include restrictions on gatherings of 10 people or less. Under ‘International Travel Controls’, partial restrictions include screening and quarantine requirements for those entering the country. Values for ‘Cancel Public Events’ were not recodified.

Economic Measures

Under ‘Income Support’, narrow support includes instances in which a country’s government is replacing less than 50% of lost salary (or if a flat sum, it is less than 50% median salary); broad support includes instances in which a country’s government is replacing 50% or more of lost salary (or if a flat sum, it is greater than 50% median salary). Under ‘Debt/Contract Relief’, narrow support includes instances in which a country’s government is providing narrow relief, such as relief specific to one kind of contract.

Health Systems Measures

Under ‘Vaccine Eligibility’, partial availability includes availability for some or all of the following groups: key workers, non-elderly clinically vulnerable groups, and elderly groups, or for select broad groups/ages. Under ‘Facial Coverings’, recommend/partial requirement includes instances in which a country’s government recommends wearing facial coverings, requires facial coverings in some situations, and requires facial coverings when social distancing is not possible. 

SOURCES

Data on and descriptions of government measures related to COVID-19 provided by the Oxford Covid-19 Government Response Tracker (OxCGRT). For more detailed information on their data collection and methodology, please see their codebook and interpretation guide.

Health Costs Consume a Large Portion of Income for Millions of People with Medicare

Authors: Nancy Ochieng, Juliette Cubanski, Tricia Neuman, and Anthony Damico
Published: Aug 21, 2025

Medicare and Social Security play a central role in the lives of tens of millions of older adults and people with disabilities in the U.S., in the form of health insurance from Medicare and retirement or disability income from Social Security. Yet, even with Medicare coverage, beneficiaries can face substantial out-of-pocket health care costs, which can erode the financial support provided by Social Security. Medicare Part B and D premiums and cost sharing alone account for nearly one-fourth of average monthly Social Security benefits, not taking into account other health care expenses, such as dental services, home care, or care in a nursing home, or premiums for supplemental coverage. While most Medicare beneficiaries have other sources of income in addition to Social Security, more than one third of Social Security recipients age 65 and older rely on Social Security for half or more their income. Additionally, many Medicare beneficiaries live on relatively low incomes: one in four Medicare beneficiaries had income below $21,000 per person in 2023, while half had income below $36,000 per person.

Medicare beneficiaries with low incomes and limited financial resources can get help paying for out-of-pocket costs and services not covered by Medicare if they qualify for and receive full Medicaid benefits, which covers long-term care, vision, and dental care. They can also receive help if they are enrolled in the Medicare Savings Programs, which pay for Medicare’s premiums and, in most cases, cost-sharing requirements. However, the recently enacted tax and spending bill includes provisions that are projected to result in fewer low-income Medicare beneficiaries accessing these benefits, and reduce household resources for individuals in the bottom of the income distribution, including households with Medicare beneficiaries. And even today, not all low-income Medicare beneficiaries who are eligible for these benefits are receiving them, while others may have income or assets just above the qualifying thresholds.

To document the affordability challenges posed by out-of-pocket health care costs for people with Medicare, this brief analyzes out-of-pocket health care costs as a share of Social Security income and total income, including other sources of income in addition to Social Security. Due to differences in the underlying data sources, the analysis presents average out-of-pocket spending as a share of average Social Security income on a per person basis, and a broader range of measures – average, median, 75th and 90th percentile – for out-of-pocket spending as a share of total income. (See Methods for more details and data sources).

Out-of-pocket health care spending by Medicare beneficiaries accounted for 39% of Social Security income per person in 2022, on average

In 2022, Medicare beneficiaries spent a total of $6,330 out of pocket on health care costs, on average, including premiums for Medicare and costs for Medicare-covered services and services Medicare doesn’t cover, like dental, vision, and hearing services and long-term services and supports, while average per capita income from Social Security was $16,157 (Figure 1, Appendix Table 1).

Figure 1

Medicare beneficiaries spent 11% of their total per capita income on out-of-pocket health care costs, on average, but 1 in 4 beneficiaries spent at least 21% and 1 in 10 beneficiaries spent 39% or more

Taking into account other sources of income in addition to Social Security, out-of-pocket spending on health care amounted to 11% of total per capita income for Medicare beneficiaries in 2022, on average (Figure 2). Out-of-pocket health care costs represent a smaller share of total income than Social Security income because most beneficiaries have other sources of income, such as pensions, 401ks, or income from savings. In 2022, Social Security income accounted for 29% of total income per Medicare beneficiary, on average. Out-of-pocket spending consumed a larger share of income for some Medicare beneficiaries, with one in four (15 million beneficiaries) spending 21% or more and one in 10 (6 million) spending 39% or more.

Figure 2

The health care spending burden is higher for some Medicare beneficiaries, including those with lower incomes and those ages 85 and older

On average, out-of-pocket health care costs accounted for a substantially larger share of per capita total income among Medicare beneficiaries with lower incomes than higher incomes (34% among beneficiaries with incomes of $10,000 or less vs. 7% among beneficiaries with incomes greater than $50,000) (Figure 3). While Medicare beneficiaries with lower incomes have lower out-of-pocket health care costs than higher income beneficiaries, on average, their out-of-pocket costs account for a larger share of their lower incomes. Assistance from Medicaid and the Medicare Savings Program can help limit out-of-pocket spending for Medicare beneficiaries with the lowest incomes, but not all low-income beneficiaries qualify for or receive help from these programs. Without some form of financial assistance, lower-income beneficiaries may be more likely to forego needed care since they are less likely than higher-income beneficiaries to be able to afford services with high cost-sharing requirements or services not covered by Medicare, like dental services or long-term services and supports.

Medicare beneficiaries ages 85 and older spent a larger share of their income on out-of-pocket health care costs than younger beneficiaries (22% vs. 9% among beneficiaries ages 65-74), on average. Medicare beneficiaries ages 85 and older have much higher average out-of-pocket health care costs than those ages 65-74, largely due to higher out-of-pocket spending on long-term care, which accounts for more than half of total out-of-pocket spending on all services for those ages 85 and older. Beneficiaries in the oldest age cohort also have lower per capita total income than younger aged beneficiaries, on average, likely due in part to lower income from earnings after retirement. (For details on additional demographic groups, see Appendix Table 1 and Table 2).

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Methods

Data on out-of-pocket health care spending is from the Centers for Medicare & Medicaid Services (CMS) Medicare Current Beneficiary Survey, 2022 Cost Supplement File (the most recent year of data available). The sample includes 59.9 million people with Medicare in 2022 (weighted), including beneficiaries in traditional Medicare and Medicare Advantage and those living in the community and in facilities, excluding beneficiaries who were enrolled in Part A only or Part B only for most of their Medicare enrollment in 2022 and beneficiaries who had Medicare as a secondary payer.

The Cost Supplement File links Medicare claims to survey information reported directly by beneficiaries. The file collects out-of-pocket information on inpatient and outpatient hospital care, physician and other medical provider services, home health services, durable medical equipment, long-term and skilled nursing facility services, hospice services, dental services, hearing services, vision services, and prescription drugs.

Survey-reported out-of-pocket payments are those payments made by the beneficiary or their family, including direct cash payments and Social Security or Supplemental Security Income (SSI) checks paid directly to nursing homes. Out-of-pocket spending on premiums is derived from administrative data on Medicare Part A, Part B, Part C (Medicare Advantage), and Part D premiums paid by each sample person along with survey-reported estimates of premium spending for other types of health insurance beneficiaries may have (including Medigap, employer-sponsored insurance, and other public and private sources).

Starting in 2019, the MCBS introduced an imputation method that uses Medicare Advantage encounter data to improve estimation of medical events and costs for Medicare Advantage enrollees and account for unreported Medicare Advantage utilization. Because data for Medicare Advantage enrollees is imputed, estimates of total average out-of-pocket spending in this analysis may be conservative.

Income data are based on both beneficiaries’ self-reported income in the MCBS and estimates from the Urban Institute’s Dynamic Simulation of Income Model (DYNASIM4). DYNASIM4 is a dynamic microsimulation model that projects the population and analyzes the long-term distributional consequences of retirement and aging issues. DYNASIM4 takes into account income from all sources, including Social Security, wages, pensions, and asset income including withdrawals from IRAs. The simulation is aligned to the 2024 Social Security Trustees’ intermediate cost economic and demographic projections.  DYNASIM4 generates average and percentiles of per capita Social Security and total income for specific demographic groups. It calculates average per capita Social Security and total income for married couples by dividing income for the couple by two. KFF adjusts beneficiaries’ self-reported income in the MCBS with estimates from DYNASIM to adjust for under-reporting of income from certain sources.

For average out-of-pocket spending as a share of average per capita Social Security and average per capita total income, this analysis uses average per capita out-of-pocket spending from the MCBS and average per capita Social Security and total income from DYNASIM. Percentile values of out-of-pocket spending as a share of total income (median, 75th, and 90th) are calculated from MCBS data on out-of-pocket spending and DYNASIM-adjusted income values in the MCBS.

This work was supported in part by AARP Public Policy Institute. KFF maintains full editorial control over all of its policy analysis, polling, and journalism activities.

Nancy Ochieng, Juliette Cubanski, and Tricia Neuman are with KFF. Anthony Damico is an independent consultant.

Appendix Tables

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