U.S. Foreign Aid Freeze & Dissolution of USAID: Timeline of Events

Published: Jun 11, 2026

Starting on his first day of his second term in office, President Trump and his administration have taken several executive actions that directly impact U.S. global health efforts. This timeline, which is a companion resource to components of KFF’s Overview of President Trump’s Executive Actions on Global Health, provides a detailed overview of actions, including counter-actions, related to the administration’s efforts to freeze all U.S. foreign aid, dissolve the U.S. Agency for International Development (USAID), which implements most U.S. global health programs, and reorganize the Department of State. It will be updated as needed to reflect additional developments. 


Overview of President Trump’s Executive Actions on Global Health

Published: Jun 11, 2026

Note: Originally published on Jan. 28, 2025, this resource is updated as needed, most recently on June 11, 2026, to reflect additional developments. 

Starting on the first day of his second term, President Trump began to issue numerous executive actions, several of which directly address or affect U.S. global health efforts.* This guide provides an overview of these actions, in the order in which they were issued. The “date issued” is date the action was first taken; subsequent actions are listed under “What Happens/Implications.” See an accompanying timeline of events specific to the foreign aid review and USAID dissolution.

President Trump’s Executive Actions on Global Health

Initial Rescissions Of Harmful Executive Orders And Actions, January 20, 2025
PURPOSE: Initial rescissions of Executive Orders and Actions issued by President Biden.

Among these orders are several that addressed the COVID-19 pandemic and global health security, such as Executive Order 13987 (Organizing and Mobilizing the United States Government To Provide a Unified and Effective Response To Combat COVID-19 and To Provide United States Leadership on Global Health and Security),  which among other things established the National Security Council Directorate on Global Health Security and Biodefense and a Senior Director position to oversee it.
What Happens Next/Implications: Given that most of the provisions in the COVID-19 and Global Health Security actions issued by President Biden are no longer current or relevant, the rescissions of these actions are likely to have minimal effect on government policies. One exception may be the elimination of the Directorate of Global Health Security and Biodefense and its Senior Director at the National Security Council, which were responsible for interagency coordination on global health security matters during the Biden Administration. The elimination of this office echoes a similar move made during the first Trump Administration to eliminate an NSC Directorate for Global Health Security, and raises questions about who and which offices at NSC (and across the government) will fill this coordination role in the new Administration. More rescissions of other Biden administration Executive Actions may be issued at a later date.
Withdrawing The United States From The World Health Organization, January 20, 2025
PURPOSE: To withdraw from the World Health Organization (WHO).
“The United States noticed its withdrawal from the World Health Organization (WHO) in 2020 due to the organization’s mishandling of the COVID-19 pandemic that arose out of Wuhan, China, and other global health crises, its failure to adopt urgently needed reforms, and its inability to demonstrate independence from the inappropriate political influence of WHO member states.  In addition, the WHO continues to demand unfairly onerous payments from the United States, far out of proportion with other countries’ assessed payments. China, with a population of 1.4 billion, has 300 percent of the population of the United States, yet contributes nearly 90 percent less to the WHO.”

ACTIONS: The United States intends to withdraw from the WHO. 
The Presidential Letter to the Secretary-General of the United Nations signed on January 20, 2021, that retracted the United States’ July 6, 2020, notification of withdrawal is revoked.
Executive Order 13987 (Organizing and Mobilizing the United States Government to Provide a Unified and Effective Response to Combat COVID–19 and To Provide United States Leadership on Global Health and Security), which, among other things, called for “engaging with and strengthening the World Health Organization” is revoked.
Assistant to the President for National Security Affairs shall establish directorates and coordinating mechanisms within the National Security Council apparatus as necessary and appropriate to safeguard public health and fortify biosecurity.
The Secretary of State and Director of the Office of Management and Budget shall take actions to pause future transfer of any U.S. funds, support, or resources to WHO; recall and reassign U.S. government personnel or contractors working in any capacity with WHO; and identify credible and transparent U.S. and international partners to assume necessary activities previously undertaken by WHO.
The Director of the White House Office of Pandemic Preparedness and Response Policy shall review, rescind, and replace the 2024 U.S. Global Health Security Strategy.
The Secretary of State shall immediately inform the Secretary-General of the United Nations, any other applicable depositary, and the leadership of the WHO of the withdrawal.
While the withdrawal is in progress, Secretary of State will cease negotiations on the WHO Pandemic Agreement and the amendments to the International Health Regulations, and states that “actions taken to effectuate such agreement and amendments will have no binding force on the United States.”
What Happens Next/Implications: President Trump initiated a process to withdraw from the WHO during his first term in office, a process that takes a year to finalize, and halted funding. This time period was not met when President Biden took office and he reversed this decision and restored funding. Now, after issuance of a formal letter of withdrawal United Nations and WHO, the process will be initiated once again. Such a letter has been issued, indicating that membership will end as of January 22, 2026.Per the Executive Order, U.S. government representatives may not work with WHO. While U.S. representatives attended the Executive Board meeting in February (the U.S. previously held a seat on the Executive Board), no representatives attended the World Health Assembly in May, where world leaders adopted the Pandemic Agreement. On May 30, the White House released details on the President’s Budget Request for FY 2026, requesting eliminated funding for WHO. Further, on June 3, the administration asked Congress to rescind funds previously appropriated for fiscal years 2024 and 2025, including contributions to WHO. However, for both the FY 2026 appropriations and FY2024-25 rescissions, Congress will determine the final funding levels. As the largest donor to WHO providing approximately 16%-18% of the organization’s revenue, the absence of U.S. funding will have an impact WHO’s operations, as will the loss of U.S. technical expertise. See: KFF Fact Sheet and Quick Take

Update: The formal withdrawal of the U.S. government from the WHO became effective on January 22, 2026.
Reevaluating And Realigning United States Foreign Aid, January 20, 2025
PURPOSE: To pause funding and review all U.S. foreign assistance to assess alignment with American values.

The U.S. “foreign aid industry and bureaucracy are not aligned with American interests and in many cases antithetical to American values. They serve to destabilize world peace by promoting ideas in foreign countries that are directly inverse to harmonious and stable relations internal to and among countries.”

“It is the policy of United States that no further United States foreign assistance shall be disbursed in a manner that is not fully aligned with the foreign policy of the President of the United States.”

Calls for:

90-day pause in U.S. foreign development assistance (new obligations or disbursements) to assess programmatic efficiencies and consistency with U.S. foreign policy.
Review of U.S. foreign assistance programs by the responsible department and agency heads under guidelines provided by the Secretary of State, in consultation with the Director of OMB.
Responsible department and agency heads, in consultation with the Director of OMB, will make determinations within 90 days of this order on whether to continue, modify, or cease each foreign assistance program based upon the review recommendations, with the concurrence of the Secretary of State.
New obligations and disbursements may resume for a program prior to the end of the 90-day period if a review is conducted, and the Secretary of State or his designeein consultation with the Director of OMB, decide to continue the program in the same or modified form.  Additionally, any other new foreign assistance programs and obligations must be approved by the Secretary of State or his designee, in consultation with the Director of OMB.
The Secretary of State may waive the pause for specific programs.
What Happens Next/Implications: Almost all global health programs are funded through foreign aid appropriations and are therefore subject to this order. The order temporarily freezes any new U.S. government spending (obligations or disbursements) through these programs, which could interrupt implementation of programs for which funds have not yet been obligated. It also calls for a 90-day review of all foreign aid programs. Key developments are as follows:
On January 24, 2025, A Notice on Implementation of the Executive Order was issued by USAID which, among other things, calls for stop-work orders to be issued for all existing foreign assistance awards (not just new obligations and disbursements). It notes that waivers have been granted for: foreign military financing for Israel and Egypt and emergency food assistance (and related expenses) and, on a temporary basis, salaries and related administrative expenses, including travel, for U.S. direct hire employees, personal services contractors, and locally employed staff. The stop-work order on existing awards halted U.S. global health (and other foreign assistance) programs that were already underway, placing key programs at risk of not being able to provide critical services, and affecting access for individuals on the ground, unless a waiver was received.
On January 28, the Secretary of State  issued a blanket waiver for life-saving humanitarian assistance programs, which also lays out a process for requesting additional waivers (more information is here). This guidance also states that the waiver does not apply to “activities that involve abortions, family planning, conferences, administrative costs [unless associated with waived activities], gender or DEI ideology programs, transgender surgeries, or other non-life saving assistance.”
On February 1, PEPFAR, the global HIV/AIDS program, was granted a limited waiver enabling it to resume or continue “urgent life-saving HIV treatment  services”, defined as a set of care and treatment services and prevention of mother-to-child transmission services.
On February 4, some additional services for other global health programs  – tuberculosis; malaria; acute risks of maternal and child mortality, including severe acute malnutrition; and other life-threatening diseases and health conditions – deemed to be “lifesaving” were also granted a limited waiver to allow them to resume or continue.
On February 6, a lawsuit was filed by Democracy Forward and Public Citizen Litigation Group, on behalf of the American Foreign Service Association and American Federation of Government Employees, challenging the foreign aid funding freeze, the plan to put most staff on leave, and the fact that staff had already been placed on leave; on February 7, they filed a temporary restraining order (TRO). That same day, a temporary restraining order was issued by the U.S. District Court in the District of Columbia preventing the government from placing additional staff on leave or evacuating staff back to the U.S., and requiring reinstatement of all staff already placed on leave, until February 14. The court did not grant a TRO on the funding freeze, on the grounds that the plaintiffs in this case did not demonstrate that the freeze caused them irreparable harm. On February 13, the court extended the TRO through February 21 (further actions are described below, as this case was combined with another for purposes of the court’s consideration).
On February 10, a lawsuit was filed in the U.S. District Court for the District of Columbia on behalf of two U.S. organizations seeking emergency relief from the freeze on funding for foreign assistance (AVAC v. United States Department of State).
On February 11, a lawsuit was filed in the U.S. District Court for the District of Columbia on behalf of several U.S. organizations challenging the executive order and subsequent actions freezing foreign aid and dissolving USAID, and asking the court to temporarily restrain and preliminarily and permanently enjoin Defendants from implementing these actions (Global Health Council v. Trump).
On February 13, the court, in a ruling pertaining to the February 10 and February 11 lawsuits brought by numerous U.S. organizations, issued a TRO preventing the Trump administration from “suspending, pausing, or otherwise preventing the obligation or disbursement of appropriated foreign-assistance funds in connection with any contracts, grants, cooperative agreements, loans, or other federal foreign assistance award that was in existence as of January 19, 2025; or issuing, implementing, enforcing”, or “otherwise giving effect to terminations, suspensions, or stop-work orders in connection with any contracts, grants, cooperative agreements, loans, or other federal foreign assistance award that was in existence as of January 19, 2025.”
On February 14, the parties filed a joint status report proposing an expedited preliminary injunction briefing schedule.
On February 18, the government filed a required status report stating that, despite the TRO, it had the authority to cancel contracts and suspend grant awards.
This was followed by a February 19 request by the February 10 plaintiffs (AVAC v. Department of State) for an emergency motion to enforce the TRO and to hold the defendants in civil contempt.
The defendants filed a required response on February 20, stating that they have not violated the TRO and should not be held in contempt, which was again opposed by the plaintiffs. Also on February 20, the February 11 plaintiffs (Global Health Council v. Trump) filed a response to the defendant’s status report with a motion to enforce the TRO.  The court reaffirmed the TRO on February 20 (but did not hold the defendants in contempt), stating it was prepared to hold a hearing on the preliminary injunction motions in both cases by March 4, 2025 and that the TRO would be in place through March 10, 2025, or the date the Court resolves the preliminary injunction motions, whichever is sooner.
The plaintiffs filed an emergency order to enforce the TRO on February 24, due to continued lack of payment, and the court issued a motion to enforce on February 25. The government appealed, (asking for a stay pending appeal) but this was denied by the court. The government then appealed to the Supreme Court and was granted a stay until February 28 while the case was considered.
On March 5, the Supreme Court denied the government’s request to vacate the federal district court’s TRO, sending the order back to the district court to clarify the government’s obligations for ensuring compliance with the TRO.
On March 6, the federal district court judge ordered the government to release all payments that were due to plaintiffs as of February 13, by Monday, March 10 at 6pm, and on March 10, the federal district court judge preliminarily enjoined the government from taking certain actions related to the foreign aid freeze.
On March 10, Secretary Rubio announced that a six-week review had been completed and that 83% of programs at USAID (5,200 contracts) had been cancelled. That same day, the court  preliminarily enjoined the government from enforcing actions taken to implement the foreign aid freeze (requiring it to reverse any terminations, suspensions, and stop-work orders and to pay for any work completed by February 13). The court stated that the government was “enjoined from unlawfully impounding congressionally appropriated foreign aid funds and shall make available for obligation the full amount of funds that Congress appropriated for foreign assistance programs in the Further Consolidated Appropriations Act of 2024.”
On April 1, the government filed an appeal with the U.S. Court of Appeals for the District of Columbia challenging the preliminary injunction issued on March 10.
On April 17, the administration extended the foreign aid review for another 30 days from the original deadline of April 20, 2025.
On May 2 and May 30, the White House released information on its budget request for FY 2026, proposing significant decreases, and in some cases eliminations, of funding for global health activities. However, Congress will determine the final funding levels.
On June 3, the administration asked Congress to rescind previously appropriated funds for fiscal years 2024 and 2025, including $8.3 billion in foreign assistance, of which at least $1.2 billion was designated for global health. However, Congress will need to approve any potential rescissions.
• On August 13, the U.S. District Court of Appeals for the District of Columbia Circuit partially vacated the March 10 preliminary injunction in the cases GHC v. Trump and AVAC v. State Department which required the government to make congressionally appropriated foreign assistance funds available for obligation. The appeals court ruled that the plaintiffs did not have the authority to challenge the President’s impoundment of funds. Instead, the court ruled that challenges of impoundment should be brought forward by the Comptroller General.
• On August 28, the U.S. District Court of Appeals for the District of Columbia Circuit amended its opinion, clarifying that while plaintiffs did not have the authority to challenge impoundment of foreign assistance funds through the Impoundment Control Act, they could seek relief through the Administrative Procedures Act. Following this amended opinion, plaintiffs in GHC v. Trump and AVAC v. State Department cases motioned for a preliminary injunction in the U.S. district court on September 1. On September 3, the U.S. district court granted the preliminary injunction, ordering defendants to obligate expiring foreign assistance funds before the end of the fiscal year on September 30. On September 4, defendants appealed this preliminary injunction and requested a stay on the preliminary injunction pending the resolution of the appeals case, from both the district court and appeals court. These requests were both denied on September 5. On September 8, defendants requested a stay of the preliminary injunction as it pertained to funds included in the President’s proposed rescissions package from the U.S Supreme Court. On September 9, the Chief Justice of the Supreme Court granted a partial administrative stay of the preliminary injunction, and on September 26, the court granted the partial stay, allowing the administration to rescind the $4 billion that was in rescission package. Further legal proceedings in the case are currently stayed as the parties await the outcome of a separate legal case.

The 90-day review of foreign assistance was initially supposed to go through April 19, 2025, however, has been granted a 30-day extension. No formal results of the review have been announced.
America First Policy Directive To The Secretary Of State, January 20, 2025
PURPOSE: To put core American interests first in foreign policy.

The foreign policy of the United States “shall champion core American interests and always put America and American citizens first.”

“As soon as practicable, the Secretary of State shall issue guidance bringing the Department of State’s policies, programs, personnel, and operations in line with an America First foreign policy, which puts America and its interests first.”
What Happens Next/Implications: The State Department is responsible for the supervision and overall strategic direction of foreign assistance programs administered by the State Department and USAID, which includes the vast majority of global health assistance. It also directly oversees PEPFAR, the global HIV/AIDS program, and many aspects of global health diplomacy for the U.S. Priorities and approaches for these and other global health programs are likely to be shaped by how the White House and State Department leadership define “America First” foreign policy and American interests, and how that definition is implemented in practice.

Update: On September 18, the State Department released the America First Global Health Strategy, its new vision for U.S. global health engagement. The strategy is built around three pillars — “making America safer, stronger, and more prosperous” — and prioritizes funding for direct service support, such as commodities and health workers, includes plans for country co-investment, and seeks to transition program management operations from U.S. leadership to country ownership. The State Department is entering into multi-year bilateral agreements with recipient countries and implementation of these new agreements will begin sometime in 2026.
Defending Women From Gender Ideology Extremism And Restoring Biological Truth To The Federal Government, January 20, 2025
PURPOSE: To define sex as an immutable binary biological classification and remove recognition of the concept of gender identity.

• The order states that “It is the policy of the United States to recognize two sexes, male and female” and directs the Executive Branch to “enforce all sex-protective laws to promote this reality”. Elements of the order that may affect global health programs are as follows:
Defines sex as “an individual’s immutable biological classification as either male or female”.  States that “sex” is not a synonym for and does not include the concept of “gender identity” and that gender identity “does not provide a meaningful basis for identification and cannot be recognized as a replacement for sex.”
Directs the Secretary of Health and Human Services to provide the U.S. Government, external partners, and the public clear guidance expanding on the sex-based definitions set forth in the order within 30 days.
Directs each agency and all Federal employees to “enforce laws governing sex-based rights, protections, opportunities, and accommodations to protect men and women as biologically distinct sexes, including when interpreting or applying statutes, regulations, or guidance and in all other official agency business, documents, and communications.
Directs each agency and all Federal employees, when administering or enforcing sex-based distinctions, to use the term “sex” and not “gender” in all applicable Federal policies and documents.
Directs agencies to remove all statements, policies, regulations, forms, communications, or other internal and external messages “that promote or otherwise inculcate gender ideology”, and shall cease issuing such statements, policies, regulations, forms, communications or other messages. Directs agencies to take all necessary steps, as permitted by law, to end the Federal funding of gender ideology.
Requires that Federal funds shall not be used to promote gender ideology and directs agencies to ensure grant funds do not promote gender ideology.
Rescinds multiple executive orders issued by President Biden, including: “Preventing and Combating Discrimination on the Basis of Gender Identity or Sexual Orientation” (13988) and “Advancing Equality for Lesbian, Gay, Bisexual, Transgender, Queer, and Intersex Individuals” (14075).
What Happens Next/Implications: This order is broad, directed to all federal agencies and programs. Because PEPFAR, and some other U.S. global health programs, serve people who are members of the LGBTQ community, guidance and implementation could affect the ability of these programs to reach individuals and organizations and provide them with services. In addition, the order will likely result in the removal of existing protections based on sexual orientation and gender identity, which had been provided in agency guidance for global health and development programs. Implementation guidance has been issued and all federal agencies must comply.

Update: On January 27, 2026, citing this order (among others) the Trump administration released details of the “Promoting Human Flourishing in Foreign Assistance (PHFFA)” policy which significantly expands the Mexico City Policy (see below) to also prohibit the promotion of “gender ideology” and to apply to significantly more funding and organizations.
Memorandum For The Secretary Of State, The Secretary Of Defense, The Secretary Of Health And Human Services, The Administrator Of The United States Agency For International Development, January 24, 2025
PURPOSE: To reinstate Mexico City Policy and direct review of programs per the Kemp-Kasten Amendment.

• Revokes President Biden’s Presidential Memorandum of January 28, 2021 for the Secretary of State, the Secretary of Defense, the Secretary of Health and Human Services, and the Administrator of the United States Agency for International Development (Protecting Women’s Health at Home and Abroad).
Reinstates President Trump’s Presidential Memorandum of January 23, 2017 for the Secretary of State, the Secretary of Health and Human Services, and the Administrator of the United States Agency for International Development (The Mexico City Policy).
Directs the Secretary of State, in coordination with the Secretary of Health and Human Services, to the extent allowable by law, to implement a plan to extend the requirements of the reinstated Memorandum to global health assistance furnished by all departments or agencies.
Directs the Secretary of State to take all necessary actions, to the extent permitted by law, to ensure that U.S. taxpayer dollars do not fund organizations or programs that support or participate in the management of a program of coercive abortion or involuntary sterilization.
What Happens Next/Implications: The Mexico City Policy is a U.S. government policy that – when in effect – has required foreign NGOs to certify that they will not “perform or actively promote abortion as a method of family planning” using funds from any source (including non-U.S. funds) as a condition of receiving U.S. global family planning assistance and, when in place under the Trump administration, most other U.S. global health assistance. First announced in 1984 by the Reagan administration, the policy has been rescinded and reinstated by subsequent administrations along party lines since, and expanded over time, including a significant expansion during the first Trump administration; it was widely expected that the President Trump would reinstate it in his second term and expand it further. The memorandum calls for the implementation of a plan to extend the requirements to global health assistance furnished by all departments or agencies; until the plan is ready, the scope of the new memorandum is unknown.

The memorandum also directs the Secretary of State to review programs under the Kemp-Kasten amendment, a provision of U.S. law that states that no U.S. funds may be made available to “any organization or program which, as determined by the [p]resident of the United States, supports or participates in the management of a program of coercive abortion or involuntary sterilization.” It has been used in the past to prevent funding from going to UNFPA. See: KFF Mexico City Policy explainer and related resources and Kemp-Kasten explainer.

Update: On January 7, 2026, the Trump administration announced that it had formally withdrawn from membership and participation in UNFPA, also citing the Executive Order on “Withdrawing the United States from and Ending Funding to Certain United Nations Organizations and Reviewing United States Support to All International Organizations.”

Update: Three interim final rules expanding and implementing the Mexico City Policy, now called the Promoting Human Flourishing in Foreign Assistance (PHFFA) Policy, were issued on January 27, 2026:
Protecting Life in Foreign Assistance
Combating Gender Ideology in Foreign Assistance
Combating Discriminatory Equity Ideology in Foreign Assistance Rules
This latest expansion now includes most non-military foreign assistance and applies to U.S. NGOs, international organizations, and foreign governments, as well as foreign NGOs. In addition to abortion, it also now prohibits the promotion of “discriminatory equity ideology” and “gender ideology.”

Renewed Membership in the Geneva Consensus Declaration on Promoting Women’s Health and Strengthening the Family, January 24, 2025
PURPOSE: To rejoin the Geneva Consensus Declaration.

The United States informed signatories of the Geneva Consensus Declaration of its intent to rejoin immediately. Established in 2020, the declaration, led by the United States, has the following objectives: “to secure meaningful health and development gains for women; to protect life at all stages; to defend the family as the fundamental unit of society; and to work together across the UN system to realize these values.”
What Happens Next/Implications: The Geneva Consensus Declaration, initially crafted and signed by the U.S. – along with 31 other countries at the time – was meant to enshrine certain values and principles related to women’s health and family, including a rejection of the “international right to abortion.”  The Biden administration withdrew from the Consensus in 2021.
Review of and Changes to USAID, January 27, 2025
Reorganization of the Department of State, April 22, 2025
PURPOSE: To review and potentially reorganize USAID “to maximize efficiency and align operations with the national interest,” which may include the suspension or elimination of programs, projects, or activities; closing or suspending missions or posts; closing, reorganizing, downsizing, or renaming establishments, organizations, bureaus, centers, or offices; reducing the size of the workforce at such entities; and contracting out or privatizing functions or activities performed by federal employees.What Happens Next/Implications: Related to but separate from the Executive Order on reevaluating and realigning foreign aid and on the America first policy directive to the Secretary of State, the administration has made changes to and begun a review of USAID, the U.S. government’s international development agency which oversees and/or implements most U.S. global health programs (see, The U.S. Government and Global Health). Key developments are as follows:
On January 27, senior USAID career staff were placed on leave and hundreds of other staff were let go.
On February 2, the USAID website was taken down.
On February 3, the USAID building in DC was closed, which has prevented other staff from accessing it.
The President appointed Secretary of State Rubio as Acting USAID Administrator on February 3. Secretary Rubio has said that the agency has “conflicting, overlapping, and duplicative functions that it shares with the Department of State” and that its systems and processes are not “well synthesized, integrated, or coordinated, and often result in discord in the foreign policy and foreign relations of the United States.” President Trump and other administration officials have called for dissolving the agency altogether. Formal notification of the intent to review the agency was sent by Secretary Rubio to Congress on February 3.
On February 4, a notice was posted on the USAID website stating that on February 7, all USAID direct hire personnel would be placed on administrative leave globally, with the exception of “designated personnel responsible for mission­ critical functions, core leadership and specially designated programs.” The notice also said that staff posted outside the United States would need to return to the U.S. within 30 days.
On February 6, a lawsuit was filed by Democracy Forward and Public Citizen Litigation Group, on behalf of the American Foreign Service Association and American Federation of Government Employees, challenging the foreign aid funding freeze, the plan to put most staff on leave, and the fact that staff had already been placed on leave; on February 7, they filed for a temporary restraining order (TRO). That same day, a temporary restraining order was issued by the U.S. District Court in the District of Columbia preventing the government from placing additional staff on leave or evacuating staff back to the U.S., and requiring reinstatement of all staff already placed on leave, until February 14. The court did not grant a TRO on the funding freeze, on the grounds that the plaintiffs in this case did not demonstrate that the freeze caused them irreparable harm. On February 13, the court extended the TRO through February 21, at which time, the court determined that further preliminary injunctive relief was not warranted and the TRO was ended, allowing the government to dismiss USAID staff.
On February 11, a lawsuit was filed in the U.S. District Court for the District of Columbia on behalf of several U.S. organizations challenging the executive order pausing foreign aid, and subsequent actions freezing foreign aid and dissolving USAID, and asking the court to temporarily restrain and preliminarily and permanently enjoin Defendants from implementing these actions. In a February 13 ruling, a federal court issued a TRO preventing the Trump administration from freezing foreign aid assistance but stated that the proposed injunctions related to USAID were overbroad (in a separate case, the district court ended the TRO on dismissing USAID staff – see above).
On February 13, a lawsuit was filed in the U.S. District Court for the District of Maryland by 26 former and current employees of USAID, suing Elon Musk and DOGE for taking actions to control and dissolve the agency. On February 18, the plaintiffs filed a motion for preliminary injunction. The defendants responded on February 24 and the plaintiffs replied on February 26. On March 18, the court granted a preliminary injunction, requiring the defendants to reverse many of the actions taken to dissolve USAID, and on March 21, the defendants filed an appeal on the preliminary injunction. On March 25, the U.S. 4th Circuit Court of Appeals granted the defendants’ motion for a temporary stay on the preliminary injunction, allowing DOGE to resume its efforts to dissolve USAID, until March 27. The following day on March 28, the court granted defendants’ motion for a stay, clearing the path for DOGE to continue its work dissolving USAID.
On February 18, a lawsuit was filed in the U.S. District Court for the District of Columbia on behalf of the Personal Services Contractor Association (representing USAID personal service contractors) challenging the suspension of foreign assistance and the actions related to USAID, including “steps to dismantle USAID, cripple its operations, or transfer its functions to the State Department without Congressional authorization”. On February 19, the plaintiffs filed a motion for a temporary restraining order. On March 6, the court denied the TRO request.
On March 28, Secretary Rubio announced that the Department of State and USAID have notified Congress on their intent to “undertake a reorganization that would involve realigning certain USAID functions to the Department by July 1, 2025, and discontinuing the remaining USAID functions that do not align with Administration priorities.” Additionally, nearly all the remaining USAID staff received notice that they would be subject to a final reduction-in-force.
On April 22, Secretary Rubio announced the Department of State’s reorganization plan and new organization chart. The plan states that it would consolidate functions and remove non-statutory programs that are “misaligned with America’s core national interests.”
On April 28, a lawsuit was filed by a group of labor unions, non-profits, and local governments challenging the administration’s moves to drastically reshape several federal agencies without congressional approval (American Federation of Government Employees v. Trump). The district court issued a TRO on May 9 and preliminary injunction on May 22 ordering the administration to pause large-scale reductions in force, program eliminations, and other actions related to federal agency restructuring. An emergency motion by the government for a stay pending appeal of the district court’s preliminary injunction was denied on May 30.
On May 2 and May 30, the White House released information on its budget request for FY 2026, noting the reorganization of USAID into the Department of State.
On May 29, the Department of State notified Congress of its reorganization plans, including absorbing USAID’s continued functions.
On June 13, the district court in American Federation of Government Employees v. Trump ruled that the actions of the Department of State, including the reorganization announcement and notification to Congress, were in violation of the preliminary injunction.
On July 8, the U.S. Supreme Court granted the government’s request for a stay of the preliminary injunction pending resolution of the appeals case in American Federation of Government Employees v. Trump, allowing the government to move forward with large-scale reductions to federal agency operations and workforces, including at the State Department.
On April 20, 2026, a congressional notification was sent to Congress outlining plans for USAID to use remaining funds, including $2 billion in FY25 funding from the Global Health Programs (GHP) account, to close out the agency and terminated awards.

While initially created through Executive Order in 1961 as part of the State Department, the Foreign Affairs Reform and Restructuring Act of 1998 established it as an independent agency within the executive branch. As such, the Executive branch does not have authority to dissolve it without Congress, and Congress also requires notification first as well as consultation on any proposed changes.

Update: On July 1, 2025, USAID was dissolved (with most employees being separated from the agency; any remaining personnel were separated by September 2, 2025). Remaining functions/activities were transferred to the State Department.
Withdrawing the United States From and Ending Funding to Certain United Nations Organizations and Reviewing United States Support to All International Organizations, February 4, 2025
PURPOSE: To review United States participation in all international intergovernmental organizations, conventions, and treaties and to withdraw from and end funding to certain United Nations (U.N.) organizations.

The U.S. “helped found” the U.N. “after World War II to prevent future global conflicts and promote international peace and security.  But some of [its] agencies and bodies have drifted from this mission and instead act contrary to the interests of the United States while attacking our allies and propagating anti-Semitism.”
States that the U.S. “will reevaluate our commitment to these institutions,” including three organizations that “deserve renewed scrutiny”:
a) the U.N. Human Rights Council (UNHRC; the U.S. will not participate in and withhold its contribution to the budget of the body),
b) the U.N. Educational, Scientific, and Cultural Organization (UNESCO; the U.S. will conduct a review of its membership in the body within 90 days), and
c) the U.N. Relief and Works Agency for Palestine Refugees in the Near East (UNRWA; reiterates that the U.S. will not contribute to the body).
Requires that within 180 days:
a) the Secretary of State, with the U.S. Ambassador to the U.N., conduct a review of all international intergovernmental organizations of which the U.S. is a member and provides any type of funding or other support, and all conventions and treaties to which the United States is a party, to determine which organizations, conventions, and treaties are contrary to the interests of the United States and whether such organizations, conventions, or treaties can be reformed; and
b) the Secretary of State to report the findings of the review to the President, through the National Security Advisor, and provide recommendations as to whether the U.S. should withdraw from any such organizations, conventions, or treaties.
What Happens Next/Implications: With a long history of multilateral global health engagement, the U.S. is often the largest or one of the largest donors to multilateral health efforts (i.e., multi-country, pooled support often directed through an international organization). It provided $2.4 billion in assessed or core contributions in FY 2024 – 19% of overall U.S. global health funding – as well as more funding in voluntary or non-core contributions.

The U.S. is also a signatory or party to numerous global health-related international conventions, treaties, and agreements; these include those that played a role in the global COVID-19 response (such as the International Health Regulations). It often has participated in negotiations for new international instruments, although the Trump administration indicated in a Jan. 20, 2025, Executive Order, listed above, that the U.S. would no longer engage in the Pandemic Agreement (sometimes called the “Pandemic Treaty”) negotiations.

This Executive Order will have immediate impacts via the ordered actions related to the three U.N. organizations specified, much as the impacts of the Jan. 20, 2025, Executive Order on the World Health Organization (WHO, which initiated U.S. withdrawal from membership and halted U.S. funding) are already being seen. Beyond these, additional impacts of this Executive Order will be determined by the findings and recommendations of the international organizations and conventions review, particularly if U.S. support for or membership in some international organizations is recommended to be reduced or eliminated and if it recommends the U.S. withdraw from any international agreements.

The 180 day review of all international intergovernmental organizations goes through August 3, 2025.

Update: On January 7, 2026, the Trump administration announced that it had formally withdrawn from 66 international organizations, including United Nations entities and non-UN entities.  
Memorandum For The Heads Of Executive Departments And Agencies, February 6, 2025
PURPOSE: The memorandum seeks to “stop funding Nongovernmental Organizations that undermine the national interest and administration priorities”.

The memorandum:
States: it is Administration policy “to stop funding NGOs [Nongovernmental Organizations] that undermine the national interest.”
Directs heads of executive departments and agencies to review all funding that agencies provide to NGOs and “to align future funding decisions with the interests of the United States and with the goals and priorities of my Administration, as expressed in executive action; as otherwise determined in the judgment of the heads of agencies; and on the basis of applicable authorizing statues, regulations, and terms.”
What Happens Next/Implications: This memo aligns with other Executive actions that target federal funding for global health and foreign assistance programs. Implementation of this memo could result in the Administration halting funding to global health NGOs they determine “do not align with administration priorities.” No criteria for how this determination will be made has been provided.

The majority of U.S. global health assistance is channeled through NGOs. In FY22, for example, 62% of U.S. global health funding was provided to NGOs as prime partners (45% to U.S.-based NGOs and 17% to foreign-based NGOs) and others are likely sub-recipients of U.S. assistance.* As such, this Order could have a significant impact on NGOs if it is determined that they do not align with administration policies. *Source: KFF analysis of data from www.foreignassistance.gov.
Addressing Egregious Actions of The Republic of South Africa, February 7, 2025
PURPOSE: To stop U.S. support for South Africa due to its “commission of rights violations in its country or its ‘undermining United States foreign policy, which poses national security threats to our Nation, our allies, our African partners, and our interests.”

“It is the policy of the United States that, as long as South Africa continues these unjust and immoral practices that harm our Nation:
(a)  the United States shall not provide aid or assistance to South Africa; and
(b)  the United States shall promote the resettlement of Afrikaner refugees escaping government-sponsored race-based discrimination, including racially discriminatory property confiscation.”

ACTIONS:
All executive departments and agencies, including USAID, shall, to the maximum extent allowed by law, halt foreign aid or assistance delivered or provided to South Africa, and shall promptly exercise all available authorities and discretion to halt such aid or assistance.
The head of each agency may permit the provision of any such foreign aid or assistance that, in the discretion of the relevant agency head, is necessary or appropriate.
The Secretary of State and the Secretary of Homeland Security shall take appropriate steps, consistent with law, to prioritize humanitarian relief, including admission and resettlement through the United States Refugee Admissions Program, for Afrikaners in South Africa. A plan shall be submitted to the President through the Assistant to the President and Homeland Security Advisor.
What Happens Next/Implications: South Africa receives a significant amount of global health assistance, particularly for HIV/AIDS, from the United States government. The executive order allows the heads of U.S. agencies to permit the provision of foreign aid or assistance under this order at their discretion. On February 10, the U.S. Embassy and Consulates in South Africa announced that PEPFAR would not be impacted by this Executive Order and could continue under the limited waiver already granted to the foreign aid funding freeze. No other exceptions have yet been announced.

The Government of South Africa has issued a statement in response to the Executive Order that, among other things, expresses concern “by what seems to be a campaign of misinformation and propaganda aimed at misrepresenting our great nation.”

Notes and Sources:

*There are several other Executive Actions issued by the President that instruct all government agencies on a variety of topics and as such broadly affect global health program operations but are not specific to global health. These include, for example, Executive Actions withdrawing from the Paris Agreement under the United Nations Framework Convention on Climate Change and ending DEI programs. These are not included in this resource.

Sources: White House, https://www.whitehouse.gov/presidential-actions/; State Department, www.state.gov.

How Medicare Advantage Rebates Disadvantage Medicare’s Stand-Alone Drug Plan Market

Medicare Advantage Rebates Undermine Competition with Stand-Alone Drug Plans by Lowering Medicare Advantage Drug Plan Premiums

Published: Jun 11, 2026

The Medicare Part D prescription drug benefit was designed to offer Medicare beneficiaries the choice of drug coverage from either stand-alone prescription drug plans (PDPs) for people in traditional Medicare or Medicare Advantage prescription drug plans (MA-PDs) that offer both medical and drug benefits, with plans competing on premiums, coverage, and cost sharing. Increasingly, however, PDPs and MA-PDs are competing on uneven terms, in part because the payment system for Medicare Advantage plans enables MA-PDs to lower Part D premiums or reduce Part D cost sharing, making drug coverage from Medicare Advantage plans appear considerably cheaper, or even premium-free, to the beneficiary. The payment advantage for MA-PD sponsors makes it harder for PDP sponsors to compete on premiums, which may be especially challenging when all Part D plan sponsors are facing more cost pressures associated with a redesigned Part D benefit that shifted more costs onto plans and the loss of rebates for selected drugs under the Medicare Drug Price Negotiation program.

The federal government has recently taken steps to mitigate premium increases for Part D coverage, through both a provision in law capping annual growth in the base beneficiary premium to 6% for PDPs and MA-PDs and a temporary premium stabilization demonstration solely for PDPs. While these efforts have helped prevent an increase in the overall average PDP premium, the average premium for drug coverage remains significantly higher for PDPs than for MA-PDs. Recent years have also seen a decline in the average number of PDPs available to beneficiaries, which might make plan comparisons easier but might also make it harder to find an affordable plan that meets an individual’s unique needs. This reduction in the number of PDPs stands in sharp contrast to the MA-PD market where plan offerings have generally been increasing, though they have declined slightly over the past couple of years

This brief discusses the growing instability of the Part D stand-alone drug plan market and how the Medicare Advantage payment system makes it harder to maintain competitive and affordable options in the PDP market.

Takeaways

  • Reflecting shifts in Part D plan availability in recent years, the average Medicare beneficiary now has nearly three times more options for Part D coverage from MA-PDs than from PDPs (32 vs. 11), a substantial change from five years ago when the average beneficiary had 30 PDP options and 27 MA-PD options.
  • In 2026, MA-PD sponsors allocated over $600 in rebates per individual Medicare Advantage plan enrollee, or more than $50 per member per month, for Part D benefit enhancements and premium reductions. Due to rebate-financed Part D premium buydowns, most MA-PD enrollees are in plans charging no premium, including for drug coverage, in 2026.
  • PDP sponsors are also receiving additional temporary premium subsidies through the PDP Premium Stabilization Demonstration, established to prevent substantial PDP premium increases as a result of the Part D benefit redesign. The federal government is providing around $190 in annual premium subsidies per PDP enrollee under the stabilization demonstration in 2026, based on a projected $16 per member per month premium reduction.
  • Under a provision of the Inflation Reduction Act capping annual growth in the Part D base beneficiary premium to 6%, the federal government is providing a higher direct subsidy payment to both PDP and MA-PD plan sponsors to cover their basic Part D benefit costs, relative to what they would have received absent the 6% base premium cap, which helps absorb cost increases under the IRA’s Part D benefit redesign and mitigates premium increases for both PDP and MA-PD enrollees. The 6% base premium cap is projected to reduce the average premium by a similar amount in both markets in 2026.
  • On a per member per month basis, the amount of rebates used by Medicare Advantage plans to buy down MA-PD Part D premiums in 2026 is projected to be over three times greater than the amount of premium subsidies to PDPs under the temporary premium stabilization demonstration—$53 for MA-PDs vs. $16 for PDPs. (These projections are based on 2025 Part D enrollment, not taking into account plan switching or new enrollment for 2026.)
  • The total cost to the federal government of rebates to Medicare Advantage plans used for Part D premium buydowns is 3.5 times more than the amount of subsidies to PDP sponsors under the premium stabilization demonstration in 2026 ($13 billion versus $3.6 billion).

The PDP Market Has Been Shrinking in Recent Years

For Medicare beneficiaries who are enrolled in traditional Medicare, which is somewhat less than half of all people with Medicare, getting Medicare Part D prescription drug coverage means enrolling in a stand-alone PDP, a market that has been shrinking in recent years. Over the last five years, the number of PDPs available to the average beneficiary has decreased from 30 in 2021 to 11 in 2026, reflecting a decline in the total number of PDPs available around the country (Figure 1). By comparison, over this same period, the average number of Medicare Advantage drug plans (MA-PDs) increased from 27 to 32. The number of premium-free (“benchmark”) PDPs available to the average Medicare beneficiary who qualifies for the Part D Low-Income Subsidy (LIS) is even lower, decreasing from 8 benchmark PDPs in 2021 to 2 in 2026. This matters because for low-income Medicare beneficiaries who are eligible for the LIS, enrolling in certain PDPs provides the only guaranteed option for premium-free drug coverage and reduced cost sharing.

The Number of Part D Stand-Alone Prescription Drug Plan Options for the Average Medicare Beneficiary Has Fallen by Half in Recent Years, While Medicare Advantage Drug Plan Options Have Increased (Split Bars)

The Medicare Advantage Payment System Gives MA-PDs a Premium Advantage Compared to PDPs

One factor that has made the PDP market less competitive relative to MA-PDs is a payment system that gives sponsors of MA-PDs a clear advantage in terms of premiums. The Medicare Advantage payment system allows private insurers to retain a portion of the difference between their estimated costs for providing Medicare Part A and Part B services and the maximum Medicare Advantage payment rate. This portion of the federal payment to Medicare Advantage plans is called the “rebate” and it must be used by insurers to reduce the costs of benefits provided under the plan. In the absence of these payments, Medicare Advantage enrollees would face higher costs, including for Part D coverage. To the extent rebates are used to buy down Part D premiums or enhance Part D benefits, they provide a subsidy for Part D coverage to Medicare Advantage enrollees.

In 2026, Medicare Advantage plan sponsors are projected to allocate more than $600 in rebates per enrollee toward enhanced Part D coverage in individual MA-PDs, or just over $50 per member per month. Sponsors of individual MA-PDs use these federal rebates to subsidize Part D coverage by lowering or eliminating their Part D premiums and offering Part D supplemental benefits, including lower or no deductibles for drug coverage and lower cost sharing. Based on the 21 million enrollees in individual MA-PDs, the total amount of rebates from the federal government used for Part D buydowns is $13 billion in 2026.

These rebate subsidies are unavailable to Part D sponsors for PDPs, which means that beneficiaries in traditional Medicare who get Medicare Part D coverage through a PDP typically face higher premiums for their drug coverage than MA-PD enrollees and have far fewer zero-premium options in the PDP market. In 2026, nearly 8 in 10 (79%) MA-PD enrollees in individual plans without low-income subsidies pay no monthly premium for Part D coverage compared to around 3 in 10 (28%) PDP enrollees. For the average Medicare beneficiary in 2026, 21 out of their 32 MA-PD options charge no premium for drug coverage, while 2 out of their 11 PDP options charge no premium.

PDP Sponsors Are Receiving Additional Temporary Premium Subsidies Through the PDP Premium Stabilization Demonstration

The voluntary PDP Premium Stabilization Demonstration, established in 2024 under the federal government’s Section 402 demonstration authority and intended to run for three years, provides additional premium subsidies to sponsors of PDPs to prevent substantial premium increases associated with the Part D benefit redesign. Under the Inflation Reduction Act, the Part D benefit was redesigned to include a new out-of-pocket drug spending cap for Part D enrollees and other changes that significantly shifted costs under the drug benefit from the federal government to Part D plan sponsors, with sponsors paying a larger share of costs above the out-of-pocket spending cap and potentially passing those higher costs along to beneficiaries through higher premiums. The premium stabilization demonstration was targeted to PDP sponsors only, because CMS reported large increases and greater variation in the bids submitted by Part D plan sponsors of PDPs than MA-PDs for drug coverage in 2025, indicating greater variability in the expected impact on basic benefit costs and premiums in the PDP market associated with benefit redesign and other drug pricing cost pressures. In 2026, the federal government is providing around $190 in annual premium subsidies per PDP enrollee under the demonstration, based on MedPAC’s projection of $16 in premium subsidies per member per month in 2026, for a total cost of $3.6 billion.

Both PDP and MA-PD Plan Sponsors Are Receiving Higher Direct Subsidy Payments for Part D Benefit Costs, Which Help Mitigate Premium Increases

The federal government is providing a higher direct subsidy payment to Part D plan sponsors resulting from a provision of the Inflation Reduction Act capping annual growth in the base beneficiary premium to 6%, which helps absorb cost increases under the Part D benefit redesign and also mitigates premium increases. Along with changes to the Part D benefit design and other drug pricing provisions, the IRA capped the increase in the Part D base beneficiary premium to 6%. The base premium is calculated as a share of average plan bids for basic Part D benefits submitted by both PDPs and MA-PDs. As a result of the 6% base premium cap, the federal government is providing a larger direct subsidy payment to both PDP and MA-PD sponsors to cover their basic Part D benefit costs, relative to the level of direct subsidies they would have received without the 6% cap. The cap also has the effect of reducing Part D premiums paid by both PDP and MA-PD enrollees relative to what they would have paid in the absence of the cap (although this 6% cap doesn’t apply to the individual premiums that plans charge). According to MedPAC, the 6% base premium cap is projected to reduce the average premium by a similar amount in both markets in 2026 (as described further below).

The Part D Premium Reduction from Rebates Used by MA-PD Plans is Projected to be Over Three Times Greater Than from the PDP Premium Stabilization Demonstration on a per Member per Month Basis in 2026—$53 vs. $16

Data from MedPAC shows the differential premium impact of the various subsidies provided by the federal government to PDP and MA-PD plan sponsors, with MA-PD premiums substantially lower than PDP premiums as a result. On a per member per month basis, the amount of rebates used by Medicare Advantage plans for Part D premium buydowns in 2026 is projected to be more than three times greater than the amount of subsidies provided to PDPs under the temporary stabilization demonstration—$53 for MA-PDs vs. $16 for PDPs. (MedPAC’s estimates are projections for average monthly premiums per member per month in 2026, based on 2025 enrollment and not accounting for plan switching or new enrollees for 2026.)

After premium subsidies from the 6% base beneficiary premium cap and rebates, the average monthly Part D premium for individual MA-PDs is projected to be $9 per month, compared to an average monthly premium of $44 per month for PDPs, after accounting for the 6% cap and the PDP premium stabilization subsidies (Figure 3). MedPAC’s estimates show that without these extra subsidies, average monthly premiums for MA-PDs and PDPs would be on par with each other in 2026 (with or without the 6% base beneficiary premium cap). (These estimates are MedPAC’s projections for average monthly premiums per member per month in 2026, based on 2025 enrollment and not accounting for new plans, plan changes during open enrollment, or new enrollees for 2026, and therefore differ from other estimates published recently in a separate KFF brief, which are based on March 2026 enrollment and take into account new plans, plan switching, and new enrollees for 2026.)

The Part D Premium Reduction from Rebates Used by MA-PD Plans is Projected to be Over Three Times Greater Than from the PDP Premium Stabilization Demonstration on a per Member per Month Basis in 2026— vs.  (Bar Chart)

For individual MA-PDs, the average monthly premium is projected to be $89 lower in 2026 than it would have been without the subsidies—from $98 per month to $9 per month. Rebate subsidies for Part D premium buydowns account for $53 of the premium reduction and subsidies from the 6% cap account for $36 of the reduction.

For PDPs, the average monthly premium is projected to be $53 lower in 2026 than it would have been without the additional subsidies—from $97 per month to $44 per month. Subsidies from the premium stabilization demonstration account for $16 of the premium reduction, while subsidies from the 6% cap account for $37 of the reduction.

The Total Amount of Medicare Advantage Rebates Used for Part D Premium Buydowns in 2026 is 3.5 Times Greater than Subsidies Provided Through the PDP Premium Stabilization Demonstration

The $13 billion in rebates provided by the federal government to individual Medicare Advantage plans used to buy down MA-PD Part D premiums in 2026 is 3.5 times larger than the $3.6 billion in premium subsidies to PDPs under the premium stabilization demonstration (Figure 2). According to GAO,the cost of the PDP premium stabilization demonstration for the first and second years of operation totaled $9.8 billion ($6.2 billion in 2025 and $3.6 billion in 2026). The cost of the demonstration was lower in 2026 than in 2025 because the Trump administration reduced the level of the premium subsidies provided to PDP sponsors in the second year of the demonstration. By comparison, rebates provided to individual Medicare Advantage plans used for Part D premium buydowns totaled $23.7 billion in 2025 and 2026 ($10.6 billion in 2025 and $13.0 billion in 2026). Between 2020 and 2026, rebates to Medicare Advantage plans to offer enhanced Part D benefits, including premium buydowns, totaled $82.2 billion. (These estimates exclude the aggregate cost of extra direct subsidies provided under the 6% base beneficiary premium cap, but this subsidy is applied equally across all plans.)

In 2026, Rebate Subsidies Provided to Medicare Advantage Plans for Part D Premium Buydowns Totaled  Billion, 3.5 Times More Than the .6 Billion in Demonstration Premium Subsidies to Part D Stand-Alone Drug Plan Sponsors (Grouped column chart)

A continuation of recent trends in the Part D market—fewer PDPs coupled with higher average premiums for PDPs than MA-PDs—could diminish the ability of Medicare beneficiaries in traditional Medicare to find PDPs at a comparatively affordable price, especially for those with modest incomes, which could make enrollment in Medicare Advantage more likely. Although there are some low-premium PDP options in 2026, roughly half of PDP enrollees are in plans charging $10 or more per month and 20% are paying $100 per month or more in 2026. The choice to enroll in a PDP versus an MA-PD plan comes with tradeoffs that extend beyond prescription drug coverage. While Medicare Advantage plans typically charge zero premium beyond the standard Part B premium and offer extra benefits beyond what is covered under traditional Medicare, they also have more limited provider networks and greater use of prior authorization than in traditional Medicare. Greater financial pressure on Part D plan sponsors that results in additional PDP withdrawals could also further reduce premium-free benchmark PDP options for low-income Medicare beneficiaries. Overall, instability in the PDP market has larger implications for the viability of traditional Medicare as an option for beneficiaries nationwide, but especially for beneficiaries who live in rural areas, who are more likely to be enrolled in traditional Medicare and rely more on drug coverage from PDPs than Medicare Advantage plans.

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

Medicare Part D Enrollment, Premiums, and Cost Sharing in 2026

Authors: Juliette Cubanski and Anthony Damico
Published: Jun 11, 2026

Introduction

The Medicare Part D program provides an outpatient prescription drug benefit to 56 million older adults and people with long-term disabilities in Medicare who enroll in private plans, including stand-alone prescription drug plans (PDPs) to supplement traditional Medicare and Medicare Advantage prescription drug plans (MA-PDs) that include drug coverage and other Medicare-covered benefits. This brief analyzes Medicare Part D enrollment and costs in 2026 and trends over time, based on data from the Centers for Medicare & Medicaid Services (CMS).

Highlights for 2026

  • Enrollment in Medicare Part D stand-alone PDPs increased for 2026 to 24.9 million, up from 23.2 million in 2025, mainly due to growth in employer group plans. But Medicare Advantage continues to be the primary source of Part D drug coverage for people with Medicare, with 31.4 million enrollees. Enrollment in the Part D Low-Income Subsidy (LIS) increased in 2026, from 13.1 million to 13.6 million, offsetting a similarly sized decrease in enrollment in 2025.
  • Overall, Part D enrollment is concentrated in a handful of large plan sponsors, with the top 5 firms (UnitedHealth, Humana, Centene, CVS Health, and Health Care Service Corporation) covering nearly three-fourths of Part D enrollees. Centene is the top firm in the PDP market, with more than one-third (35%) of all PDP enrollees, while UnitedHealth is the top firm in the MA-PD market, with 26% of all MA-PD enrollees.
  • The temporary Part D premium stabilization demonstration for stand-alone PDPs continues to work as intended to help stabilize PDP premiums. The average monthly premium for Part D coverage decreased for PDPs in 2026 (from $39 to $36), while increasing modestly for MA-PDs (from $7 to $8). The average monthly premium for Part D coverage in 2026 is more than 4 times higher for PDPs than for MA-PDs, with most MA-PD enrollees in zero-premium plans, which reflects the ability of Medicare Advantage plan sponsors to reduce their Part D premiums using rebates that are not available to PDP sponsors. Nearly 8 in 10 MA-PD enrollees without low-income subsidies pay no monthly premium for Part D coverage in 2026 (not including premiums they may pay for medical benefits), compared to around 3 in 10 PDP enrollees in zero-premium plans.
  • Cost pressures for Part D plan sponsors under the redesigned Part D benefit are likely one factor in higher costs being passed along to both PDP and MA-PD enrollees in the form of higher deductibles and greater use of coinsurance. In 2026, most Part D enrollees pay either the standard $615 Part D deductible or a partial amount. The share of MA-PD enrollees in a plan that charges a deductible for drug coverage in 2026 is 82%, a sharp increase from 2024 when 23% of MA-PD enrollees were in a plan charging a drug deductible. The share of Part D enrollees in a plan charging no drug deductible decreased between 2025 and 2026, from 40% to 18% among MA-PD enrollees and from 15% to 4% among PDP enrollees.
  • Median cost-sharing amounts for covered drugs across different formulary tiers are the same or similar in PDPs and MA-PDs in 2026, but there is some variation in the share of PDPs and MA-PDs charging flat dollar copayments versus coinsurance (a percentage of the drug’s price) for preferred brands and non-preferred drugs. Virtually all PDP enrollees pay coinsurance for preferred brands (97%) and non-preferred drugs (100%), compared to 56% and 89% of MA-PD enrollees. But the use of coinsurance has increased on MA-PD formularies compared to 2025, when 27% of MA-PD enrollees faced coinsurance for preferred brands and 56% faced coinsurance for non-preferred drugs.

Part D Enrollment

The number of Medicare Part D enrollees in stand-alone prescription drug plans increased in 2026, but enrollment remains higher in Medicare Advantage drug plans

More than half (56%) of all Part D enrollees in 2026 are in Medicare Advantage drug plans, continuing a trend of increasing enrollment in Medicare Advantage (Figure 1). At the same time, the overall number of PDP enrollees increased for the third year in a row and is up by 1.7 million since 2025, with most of the growth in employer group PDPs. The modest reduction in overall MA-PD enrollment between 2025 and 2026 (from 31.6 million to 31.4 million) reflects a shift in enrollment among employer group plan enrollees from group MA-PD plans to group MA-only plans with separate PDPs. (These enrollment trends are discussed in greater details in a separate KFF analysis, “Analyzing Changes in Medicare Part D Enrollment for 2026.”)

Medicare Part D Enrollment in Stand-Alone Prescription Drug Plans Increased in 2026, But Enrollment Remains Higher in Medicare Advantage Drug Plans (Stacked Bars)

An even larger share of Part D Low-Income Subsidy enrollees is in Medicare Advantage drug plans than Part D enrollees overall

The Medicare Part D Low-Income Subsidy (LIS) provides financial assistance with drug plan premiums and cost sharing for low-income enrollees. More than two-thirds (68%) of LIS enrollees—9.3 million out of 13.6 million—are enrolled in Medicare Advantage drug plans in 2026 (Figure 2). Nearly half of all LIS enrollees (6.7 million or 49%) are enrolled in Medicare Advantage Special Needs Plans (SNPs), nearly all of whom are in plans designed specifically for dual-eligible individuals (Appendix Table 1). LIS enrollment in MA-PDs has increased over time in tandem with overall enrollment of Medicare beneficiaries in Medicare Advantage plans generally and SNPs specifically.

Part D LIS enrollment overall increased modestly by 0.5 million in 2026, from 13.1 million to 13.6 million, offsetting a similar decrease in LIS enrollment in 2025. This decrease was likely due to Medicaid disenrollment among dual-eligible individuals that stemmed from the unwinding of the Medicaid continuous enrollment provision in place during the COVID-19 pandemic. Medicare beneficiaries with Medicaid coverage (dual-eligible individuals) automatically qualify for LIS, meaning a loss of Medicaid coverage would lead to a loss in LIS unless eligible individuals apply and enroll separately.

More Than Two-Thirds of Beneficiaries Receiving the Part D Low-Income Subsidy Are Enrolled in Medicare Advantage Drug Plans 2026 (Stacked Bars)

Five firms cover nearly three-fourths of Part D enrollees in 2026

Part D enrollment is concentrated in a handful of top plan sponsors, with 5 firms covering 74% of all Part D enrollees in 2026, or 41.9 million out of 56.3 million enrollees (Table 1). One in 5 enrollees (11.8 million) are in Part D plans sponsored by UnitedHealth, including both stand-alone PDPs and MA-PDs, followed by Humana and Centene, each with around 10 million enrollees across both types of Part D plans.

Centene is the top firm in the PDP market, with more than one-third (35%) of all PDP enrollees, followed by CVS Health (16%) and UnitedHealth (15%). UnitedHealth is the top firm in the MA-PD market, with 26% of all MA-PD enrollees, followed by Humana (20%) and CVS Health (10%).

Five Firms Cover Nearly Three-fourths of Part D Enrollees in 2026 (Table)

More than 6 million PDP enrollees—one-third of the total—are enrolled in the lowest-premium PDP in 2026

Among the 10 national PDPs available in 2026, the PDP with the lowest average monthly premium—Wellcare Value Script, at just under $6—has attracted a substantial share of all PDP enrollees, with one-third of PDP enrollees in non-group plans (6.1 million) (Figure 3). Between 2025 and 2026, Wellcare Value Script gained 1.1 million PDP enrollees, as several other national PDPs experienced smaller increases and some PDPs lost enrollment (Appendix Table 2).

More Than 6 Million PDP Enrollees - One-Third of the Total - Are In the Lowest-Premium PDP in 2026 (Split Bars)

The number and share of LIS enrollees in national PDPs vary considerably, which is related to the fact that only 1 of these 10 plans (Wellcare Classic) is a benchmark PDP in all 34 PDP regions, meaning it is available to all Part D enrollees receiving LIS for no premium (4 other PDPs are benchmark plans in some but not all regions) (Appendix Table 3). A majority of all enrollees in Wellcare Classic (82% or 2.2 million) are receiving LIS, along with 60% of enrollees (0.7 million) in HealthSpring Assurance Rx, a benchmark plan in 11 regions, and 36% of enrollees (0.4 million) in Humana Basic Rx Plan, a benchmark plan in 30 regions. In contrast, only 3% of the 6.1 million enrollees in Wellcare Value Script are LIS enrollees; despite its low average premium, this is an enhanced PDP and therefore does not qualify to be a benchmark plan.

Overall, 14% (0.6 million) of the 4.2 million PDP enrollees receiving LIS in 2026 (excluding those in employer group plans) are enrolled in non-benchmark PDPs. LIS enrollees in non-benchmark plans are required to pay a portion of the plan’s premium for the cost of basic benefits that exceeds the LIS benchmark amount in their region or if their plan charges a premium for enhanced benefits.

Part D Premiums

The average monthly premium decreased for PDPs in 2026, but the premium for Part D coverage is still substantially higher for PDPs than for MA-PDs

The temporary Part D premium stabilization demonstration for stand-alone PDPs established by the Biden administration in 2024 and renewed for a second year by the Trump administration in 2025 continues to work as intended to help stabilize PDP premiums, with the average monthly PDP premium decreasing 7% between 2025 and 2026, from $39 to $36. This is despite monthly premium increases in some PDPs of up to $50, the maximum increase allowed in 2026 for plans participating in the premium stabilization demonstration.

On average, PDP enrollees continue to pay substantially more each month for their Part D drug coverage than enrollees in MA-PDs. The $36 average monthly PDP premium is more than 4 times higher than the $8 average monthly premium for drug coverage in MA-PDs (weighted by enrollment) (Figure 4). (The total average premium for MA-PDs, including all Medicare-covered benefits, is $15 per month in 2026.) The weighted average MA-PD premium for Part D coverage increased modestly between 2025 and 2026 (up from $7 to $8). (These estimates are based on enrollment in March 2026 and factor in new plans for 2026, plan changes during open enrollment, and new enrollees, and therefore differ from other estimates published in a separate KFF brief, which are based on MedPAC’s projection of average monthly Part D premiums in 2026 using 2025 enrollment and not factoring in new plans, plan switching, or new enrollees.)

The average premium for drug coverage in MA-PDs is heavily weighted by zero-premium plans because MA-PD sponsors can use rebate dollars from Medicare payments to lower or eliminate their Part D premiums. Rebates to Medicare Advantage plans have tripled since 2015 and now exceed $2,600 per year per beneficiary. 

The Average Monthly Premium for Part D Drug Coverage is More than 4 Times Larger for Stand-Alone Drug Plans Than for Medicare Advantage Drug Plans in 2026 (Grouped column chart)

Within the PDP market, average monthly premiums vary by the generosity of Part D coverage offered by a given plan—namely, whether they are basic or enhanced plans, and the amount of the drug deductible. Enhanced Part D plans offer a more generous benefit than basic plans through lower cost sharing, a lower (or no) drug deductible, or better formulary coverage. In 2026, 58% of PDP enrollees (10.8 million) are in enhanced PDPs, and they face an average monthly premium of $39, 27% higher than the average $31 premium faced by the 42% of PDP enrollees (7.8 million) in basic plans. Only 4% of PDP enrollees are in a plan charging zero deductible, but they face an average monthly premium of $127, while the 78% of PDP enrollees in a plan charging the standard $615 deductible face an average monthly premium of $22. Among MA-PD enrollees, there is considerably less variation in monthly premiums by these measures of plan generosity, which reflects both the large share of MA-PD enrollees in zero premium plans (as described below) and the fact that 94% of MA-PD enrollees are in enhanced plans.

Nearly 8 in 10 MA-PD enrollees without low-income subsidies pay no monthly premium for Part D coverage, while around 3 in 10 PDP enrollees pay no premium

Nearly 80% of MA-PD enrollees without low-income subsidies (79% or 14.3 million) pay no monthly premium for Part D coverage in 2026, compared to 28% of PDP enrollees without LIS (4.0 million) (Figure 5). For the average Medicare beneficiary in 2026, 21 out of their 32 MA-PD options charge no premium for drug coverage, while 2 out of their 11 PDP options charge no premium.

Nearly 80% of MA-PD Enrollees Pay No Monthly Premium for Part D Coverage in 2026 Compared to 28% of PDP Enrollees (Stacked Bars)

Of the 4.0 million non-LIS PDP enrollees paying zero premium, 62% (2.5 million) were enrolled in Wellcare Value Script, which was available for zero premium in 14 out of 34 PDP regions, 10% (0.4 million) in Humana Basic Rx, which was available for zero premium in 21 regions, and another 10% in Humana Value Rx, available for zero premium in 5 regions.

While 79% of non-LIS MA-PD enrollees pay no premium for drug coverage, among the 21% who do, the average monthly premium for drug coverage is $40 per month. Among the 72% of PDP enrollees who pay a monthly premium, their average monthly premium is $57.

Roughly one-third of PDP enrollees without LIS (35%, or 5.1 million) pay premiums above zero but less than $30 per month, but 1 in 5 (20%, or 2.9 million) pay at least $100 per month for their Part D plan (Figure 6). In contrast, less than 1% of non-LIS MA-PD enrollees pay $100 per month or more in Part D premiums.

Out-of-Pocket Costs

The share of MA-PD enrollees in a plan with a drug deductible has increased substantially since 2024; in 2026, most Part D enrollees pay either the standard $615 Part D deductible or a partial amount

Increasing cost pressures for Part D plan sponsors under the redesigned Part D benefit are a likely factor in higher costs being passed along to both PDP and MA-PD enrollees in the form of higher deductibles and greater use of coinsurance (as described below). Among MA-PD enrollees, 82% (16.8 million) are in a plan that charges a deductible for drug coverage in 2026 – a sharp increase from 2024 when 23% of MA-PD enrollees were in a plan charging a deductible (increasing to 60% in 2025) (Figure 6). In 2026, 25% of MA-PD enrollees are in a plan that charges the standard deductible of $615 (up from 3% in 2024 and 12% in 2025) and 57% face a partial deductible. The share of MA-PD enrollees in a plan charging no drug deductible has fallen from 77% in 2024 to 18% in 2026.

There have been comparatively fewer changes in the distribution of PDP enrollees facing different drug deductible levels since 2024. Nearly all PDP enrollees (96% or 18 million) are in a plan that charges a drug deductible in 2026, including more than three-fourths (78%) in a plan that charges the standard deductible of $615 and 18% facing a partial deductible. The share of PDP enrollees facing no drug deductible in 2026 has fallen to 4%, down from 15% in 2025 and 13% in 2024. (These estimates include Part D enrollees receiving Low-Income Subsidies, who do not pay a deductible regardless of whether their plan charges one.)

The Share of MA-PD Enrollees in a Plan with a Drug Deductible Has Increased Substantially Since 2024; In 2026, Most Part D Enrollees Pay Either the Standard 5 Part D Deductible or a Partial Amount (Stacked Bars)

The weighted average drug deductible has increased substantially for MA-PD enrollees since 2024. In 2026, the average Part D deductible is $371 in MA-PDs, up 63% since 2025 ($228) and 481% since 2024 ($64) (Figure 7). For PDP enrollees, the weighted average Part D deductible has increased more gradually but has remained higher than the average Part D deductible for MA-PD enrollees. In 2026, the average Part D deductible is $544, up 11% since 2025 ($491) and 23% since 2024 ($425).

The Weighted Average Part D Deductible Has Increased Substantially for MA-PD Enrollees Since 2024, While Increasing More Gradually, But at a Higher Level, Among PDP Enrollees (Line chart)

In 2026, more Part D enrollees overall face coinsurance rather than copayments for preferred brands and non-preferred drugs

As in previous years, Part D enrollees face low copayments for generic drugs and higher cost-sharing amounts for preferred brands, non-preferred drugs, and specialty drugs regardless of whether they are in PDPs or MA-PDs (Figure 8). Median cost-sharing amounts for drugs covered on preferred generic, generic, and preferred brand tiers are the same or similar in PDPs and MA-PDs, but there is some variation in the share of PDPs and MA-PDs charging flat dollar copayments versus coinsurance (a percentage of the drug’s price) for preferred brands and non-preferred drugs.

Virtually all PDP enrollees pay coinsurance for preferred brands (97%) and non-preferred drugs (100%); among MA-PD enrollees, these shares are 56% and 89%, respectively. However, these rates have increased compared to 2025, when 27% of MA-PD enrollees faced coinsurance for preferred brands and 56% faced coinsurance for non-preferred drugs. The median coinsurance rate for preferred brands is 25% in PDPs and 21% in MA-PDs, and for non-preferred drugs, 34% in PDPs and 38% in MA-PDs.

Median coinsurance for specialty tier drugs (those that cost over $950 in 2026) is higher for MA-PD enrollees than PDP enrollees—28% vs. 25%. Plans that waive some or all of the standard deductible, which most MA-PDs do, are permitted to set the specialty tier coinsurance rate above 25%.

These cost-sharing amounts apply when beneficiaries fill prescriptions in the initial coverage phase of the Part D benefit. Under a provision in the Inflation Reduction Act, beneficiaries no longer face cost sharing in the catastrophic coverage phase of the Part D benefit. In 2026, Medicare beneficiaries pay no more than $2,100 out of pocket for prescription drugs covered under Part D.

Part D Enrollees Face Similar Cost-Sharing Amounts for Some Covered Drugs in PDPs and MA-PDs in 2026, And More Enrollees Overall Face Coinsurance for Preferred Brands and Non-Preferred Drugs (Split Bars)

Among the 10 PDPs offered in most or all PDP regions, most charge $0 for preferred generics but only 1 PDP charges flat copayments for preferred brands and all charge coinsurance for non-preferred drugs

Part D enrollees in 8 of the 10 national or near-national PDPs face a median copayment of $0 for preferred generics, while median copays for drugs on the standard generic tier range from $0 to $10 (Figure 9). For preferred brands, 9 of the 10 PDPs charge coinsurance, with median amounts ranging from 17% to 25%, and only 1 national PDP (Humana Premier Rx) charges a copay. All 10 national or near-national PDPs charge coinsurance for non-preferred drugs, ranging from 29% to 50% at the median, and coinsurance for specialty tier drugs ranging from 25% to 33%.

Among the 10 PDPs Offered In Most or All PDP Regions in 2026, Most Charge alt=

Appendix

Medicare Part D and Part D Low-Income Subsidy Program Enrollment, by Plan Type, 2006-2026 (Table)
Enrollment and Premiums for Medicare Part D Stand-Alone Prescription Drug Plans Offered in Most or All 34 PDP Regions in 2025 and 2026 (Table)
Enrollment in Medicare Part D Stand-Alone Prescription Drug Plans Offered in Most or All PDP Regions in 2026, By Low-Income Subsidy Status (Table)

Tracking Insurer Participation Changes in the ACA Marketplaces in 2027

Published: Jun 11, 2026

As of June 8, 2026, six carriers have announced that they will exit the ACA Marketplaces in plan year 2027, either in some or all states that they are currently offering plans: Cigna Health, CareSource, PacificSource, Scott and White, Providence Health, and Taro Health. These insurer exits, expected to impact roughly a third of states, follow the expiration of the enhanced premium tax credits at the end of 2025, which drove sign-ups to fall by over a million from the 2025 to 2026 Open Enrollment Periods—with further membership declines in the ACA Marketplaces expected as the year progresses. ACA Marketplace enrollment declines affect the size of the potential market for insurers, and, potentially, the risk pool—to the extent that healthier than average enrollees are more likely to drop coverage.

As people leave the Marketplace, insurers may reassess the profitability of their Marketplace participation and decide to pull out in the future. Cigna has decided to leave the individual market in 2027 to focus on other segments given the lack of potential to grow their ACA Marketplace business. Cigna, which reported first-quarter on-exchange enrollment of over 350,000 individuals, will exit the 11 states in which it currently participates both on- and off-exchange. In some cases, multiple insurers are announcing exits in the same state, such as in Indiana, Oregon, and Texas. With fewer insurers participating in the ACA Marketplaces, remaining insurers will have less competition and consumers will be left with fewer choices. For example, after the departure of CareSource and Cigna from Indiana, only three companies will remain in that state’s Marketplace if no other companies enter.

In 2025, an average of 9.6 insurers per state participated in the ACA Marketplaces, but this number has since declined to 9.0 insurers in 2026, driven primarily by the exit of Aetna CVS from the Marketplaces. It is possible that more insurers will announce exits ahead of the 2027 plan year and average insurer participation in the ACA Marketplaces will continue to decline. Despite the number of insurers that have decided to exit the ACA Marketplaces for plan year 2027, at least one insurer (Colorado Access) has indicated that it is entering the market.

While insurer participation in the ACA Marketplaces is not yet fully in focus, there are no signs at this point that there will be “bare” counties with no insurers at all, which was a major concern during an earlier period of instability.

How Has Insurer Participation in the ACA Marketplaces Changed in 2026?

Published: Jun 11, 2026

For the first time since the enhanced premium tax credits were introduced in 2021, insurer participation in the ACA Marketplaces has gone down. This drop follows the expiration of the enhanced premium tax credits at the end of 2025 and is primarily driven by the exit of Aetna CVS from 17 states as well as exits from other insurers. While the average number of insurers per state offering plans in the Marketplaces in 2026 is lower than in the years after the enhanced premium tax credits were established, more insurers are now offering plans than were before the enhanced tax credits.  

Key Findings:

  • The average number of issuers offering plans in the ACA Marketplaces has declined from a record high of 9.6 issuers per state in 2025 to 9.0 issuers per state in 2026.
  • In total, 18 states experienced a net decrease in the number of issuers offering ACA Marketplace plans.
  • Three in 10 counties have fewer participating ACA insurers than last year. In 165 counties, only one issuer is offering plans on the ACA Marketplace, up from 93 counties in 2025.

Insurer Participation

National Level

Figure 1

Nationally, average insurer participation in the ACA Marketplaces has decreased from the record high of 9.6 insurers per state in 2025 to 9.0 insurers per state in 2026. This decrease follows the nationwide departure of CVS from the Exchanges and marks the first time since 2018 that the average number of insurers in the ACA Marketplaces has gone down. Insurer participation on the ACA Marketplaces fell in 2017 with the exit of UnitedHealthcare from most states. In 2018, following several attempts to repeal the ACA in Congress as well as changes to enforcement of the individual mandate and payments for cost-sharing reductions, many more insurers exited or scaled back their participation. As the Marketplace stabilized in the following years, participation in the ACA Marketplaces steadily grew with some insurers returning to the Marketplace and several others expanding their footprints.

One factor that contributes to the number of insurers participating in the Marketplaces is the number of people with coverage. After the introduction of the enhanced premium tax credits in 2021, enrollment in the Marketplaces reached new records. In line with this trend, the number of insurers offering plans in the ACA Marketplaces increased significantly in 2022. Data shows that after the expiration of the enhanced premium tax credits, 2026 Open Enrollment Period sign-ups declined by over one million people relative to last year; and the number of people who pay to maintain and “effectuate” their coverage will likely decline throughout the year. KFF estimates that average effectuated enrollment in the Marketplaces could decline by about five million people from 2025 to 2026.

ACA Marketplace enrollment declines affect the size of the potential market for insurers and, potentially, the risk pool—to the extent that healthier than average enrollees are more likely to drop coverage. As people leave the Marketplace, insurers may reassess the profitability of their Marketplace participation and more may decide to pull out in the future, either fully or in select states. Several insurers have already announced departures for the 2027 plan year. KFF’s Insurer Participation Tracker maps announced insurer exits and entries for 2027.

State Level

On Average, 9 Insurers Participate in Each State's ACA Marketplace (Choropleth map)

The five states with the most insurers offering plans in their ACA Marketplaces in 2026 are Texas (15), New York (12), California (11), Florida (11), and Wisconsin (11). Going into 2026, most states had the same number of issuers participating in their Marketplaces as in 2025.

In 18 states, the number of insurers offering ACA Marketplace plans in 2026 is lower than in 2025. Illinois and Michigan saw the greatest net decrease in the number of carriers, with three fewer insurers participating in their Marketplaces than in 2025.

Four states (Alabama, Iowa, Louisiana, and Washington) experienced a net increase of one insurer. For example, Oscar Health newly joined the Exchange in Alabama and Elevance Health (doing business as Wellpoint) began offering plans in Washington.

The most prominent insurer in the Marketplace is UnitedHealth, which offers Marketplace plans in 30 states. Some of the other major players currently in the Marketplace include Centene Corporation (29 states), Oscar Health (20 states), Elevance Health (18 states), Molina Healthcare (14 states), Cigna Health (11 states), and Kaiser (10 states). CVS, which ran Aetna plans in the ACA Marketplaces, was a significant insurer participating in the ACA Marketplaces in 2025. Before leaving the Marketplace for plan year 2026, CVS Aetna offered plans in 17 states.

Some of the aforementioned insurers are among those with the largest number of enrollees in the individual market (the vast majority of which is made up of people in the Marketplace in 2025). For example, in 2024, 18% of people in the individual market were enrolled in a plan offered by the Centene Corporation and 8% of individual market enrollees were in a plan offered by CVS.

County Level

Figure 3

Even if an insurer remains in a state, it may significantly change its footprint from year to year. Insurers adjust their footprints by expanding into some counties or withdrawing from others. For example, UnitedHealth scaled back its footprint in Kansas from 87% of counties in 2025 to 33% in 2026, and in South Carolina from 72% of counties in 2025 to 37% in 2026. However, it also expanded its service area in Oklahoma, offering plans in 74% of counties in 2026, up from 18% in 2025. Another major player in the ACA Marketplaces, Centene Corporation, went from offering plans in all counties in North Carolina in 2025 to 63% of counties in 2026. This decrease is driven by the exit of WellCare (a subsidiary of Centene) from the North Carolina Marketplace starting in 2026. In Iowa, Centene’s footprint increased from 33% to 59% of its counties going from 2025 to 2026.

165 Counties Have Only One Insurer Offering Plans in the ACA Marketplace (Choropleth map)

In 2026, three in 10 counties saw decreases in the number of insurers participating in the Marketplaces. The counties that experienced the greatest number of insurers leaving were in Wisconsin, which saw two insurers (Chorus Community Health Plan and Molina Healthcare) exiting the ACA Marketplace entirely as well as shrinking presence of others (namely, CareSource and University Health Care and Gundersen Lutheran). Some counties in North Carolina and Michigan also experienced significant declines in the number of participating insurers, with as many as three carriers leaving counties starting in 2026.

In total, 165 counties have only one insurer offering plans in the ACA Marketplaces in 2026. For 90 of these counties, this is a result of insurers not offering plans anymore starting in 2026. For the remaining 75 one insurer counties, the number of carriers offering plans remains the same as in 2025.

There Are 490 Counties Where There Are More ACA Marketplace Insurers Offering Silver Plans Than Bronze Plans (Choropleth map)

Issuers do not always offer bronze plans. By law, every ACA Marketplace insurer must offer at least one silver and gold plan wherever they sell coverage. In 2026, there were 490 counties (predominantly located in New Mexico, Indiana, Mississippi, New Jersey, Texas, and South Carolina) where some participating insurers decided not to offer bronze plans. In these places, the selection of plans for consumers who wish to decrease their premium payments by buying a lower coverage metal level may be reduced. However, for 433 of these 490 counties, at least two insurers offer bronze plans.

Methods

The Qualified Health Plan Individual Medical Landscape File and Robert Wood Johnson Foundation (RWJF) HIX Compare file were used to determine the number of insurers participating in states using the federal platform and state-based Exchanges, respectively. HIOS IDs from these files were mapped to the 2024 MR Submission Template Header to determine the NAIC Code for each insurer, which was then joined with 2025 data from Mark Farrah Associates’ Enrollment by Segment Exhibit (downloaded December 9, 2025) to identify the parent company associated with each insurer. In cases when a parent company is not successfully identified through the MR Submission Template Header and the Enrollment by Segment Exhibit, additional work was done to identify and manually assign either the NAIC code or parent company name for each plan.  Insurer in this analysis refers to parent company, irrespective of the name under which it does business across states.

The following manual additions/changes were also made:

  • Data for New York was adjusted to include Anthem Blue Cross and Blue Shield HP, Anthem Blue Cross HP, and Independent Health.
  • Bronze plans identified to be in San Juan County, Washington after combining the RWJF datasets together were removed.

HIX Compare insurer plan availability is reported by rating area—which may contain multiple counties—in conjunction with insurer participation reported by county. County-level insurer counts of plans in state-based Marketplaces may consequently be overstated when the insurer does not offer a given plan in a county but offers other plans in the same county, notably for plans of a given metal level. Although plan availability can vary within a county (such as by ZIP code), a plan is considered as available if offered anywhere in the county.

Appendix

Appendix Table 1

VOLUME 48

Rare or Unverified Outcomes Shape Vaccine Safety and Gender Care Debates


Highlights

Two recent federal actions, including a memo about alleged COVID-19 vaccine deaths and settlements creating a “detransition clinic,” show how official actions can present uncertain or uncommon outcomes as representative and lend credibility to narratives that go beyond what evidence supports.


Recent Developments

Official Actions Elevate Uncertain or Uncommon Outcomes in Debates Over Vaccine Safety and Gender-Affirming Care

Official actions can elevate unverified or uncommon outcomes in ways that shape public perceptions beyond what evidence suggests. Two developments show how such actions can lend weight to narratives not borne out by evidence, one by overstating a causal link not supported by data, and the other by creating an institution based on a premise research does not support.

FDA Analysis of Pediatric Deaths After COVID Vaccination Shows Weaker Link Than Officials Claimed

A small number of unverified reports became the basis for a claim of definitive, widespread harm when, last November, then-FDA vaccine chief Vinay Prasad told agency staff in an internal memo that at least 10 children had died “after and because of” receiving a COVID-19 vaccine, using that claim to argue for changes to vaccine approval and oversight.

The underlying analysis made public last month, however, found no deaths definitively linked to COVID-19 vaccination. The FDA reviewed 96 reports of child deaths submitted to the Vaccine Adverse Event Reporting System (VAERS) through August 2025. Using WHO criteria and reviews of medical records and death certificates, officials concluded that none were “certain” to be linked to vaccination. Five were classified as “possible” and two as “probable,” but the report notes alternative explanations could not be ruled out. Most cases involved myocarditis, a rare heart inflammation that can also be caused by common infections, including COVID-19 itself.

The original memo presented preliminary findings with a certainty the underlying data did not support and did not reflect the limitations of VAERS, which is not intended to establish causality. The communication of vaccine safety information may be especially consequential at a time when confidence in COVID-19 vaccine safety remains lower than confidence in other childhood vaccines: KFF’s January Tracking Poll on Health Information and Trust found that eight in ten (81%) adults expressed confidence in the safety of MMR vaccines for children, compared to fewer than half (48%) who said the same about COVID-19 vaccines, though views of the COVID-19 vaccines are largely partisan.

Settlements Create “Detransition Clinic” Amid Narratives That Overstate Transition Regret

New efforts related to gender-affirming care for minors have presented cases of “detransition” or transition regret as representative of broader outcomes or a pattern of harm, though research finds both to be uncommon outcomes. Claims about “irreversible harm” often rely on inflated statistics, anecdotal stories, or misleading characterizations of surgeries for minors, which are rare and generally not recommended for younger adolescents. While some transgender people do choose to detransition, specialized clinics are not required to support this care.

Legal settlements reached last month between Texas Children’s Hospital, the Texas attorney general, and the U.S. Department of Justice may implicitly reinforce those narratives by creating what state officials called the country’s first “detransition clinic,” a facility for patients who want to stop or reverse a gender transition. The creation of such a clinic contrasts with research about gender-affirming care in practice. Many youth transition by making easily reversible social changes, like changes in clothing, names, or pronouns. Among transgender people who pursue medical transition, detransition is uncommon and transition regret rates are low. Many who do detransition cite pressure and discrimination rather than regret or a change in gender identity. Major medical associations continue to support gender-affirming care for minors when delivered carefully and with clinical oversight.

By creating a dedicated clinic, the settlements may reinforce narratives that frame regret and detransition as common outcomes. Additionally, DOJ’s involvement adds to the pressure providers have experienced in the face of a range of administration actions aimed at limiting this care, with effects potentially extending beyond Texas. At least 40 health care institutions have walked back such services since January 2025, generally citing external pressure rather than concerns about safety or effectiveness.

Why It Matters: When unrepresentative or unconfirmed cases are presented through official channels as representative of broader patterns of harm, they can appear to carry a credibility that the underlying evidence does not support.


What We’re Watching

Public Health Officials Are Tailoring Measles Vaccination Communication Strategies to Local Contexts Amid Declining Institutional Trust

As the ongoing measles outbreak surpasses 2,030 confirmed cases nationwide this year as of June 4, state health officials are adapting their communication strategies in response to declining trust in public health institutions and vaccines. In Utah, which has seen more than 600 cases since the outbreak began, officials have pursued a strategy of what they call “coordinated autonomy.” State health officials say they are coordinating with local health departments and trusted community figures like religious leaders to carry vaccine messaging, while deliberately avoiding a standardized state-wide response. This decentralized approach that relies on localized decision-making and voluntary behavior was shaped by post-COVID-19 pandemic distrust. According to reporting, Utah officials anticipate that a more coordinated response could backfire in communities where trust in government public health authorities has eroded. In practice, this has meant local health departments tailoring their own outreach. In southwest Utah, for example, officials have used weekly radio spots, press releases, and direct outreach to religious leaders, and focused messaging on asking residents who suspected they had measles to call before visiting a clinic.

Some other states with recent outbreaks, including South Carolina, rolled out a more state-wide, top-down public health response. Top-down approaches typically involve large-scale coordinated campaigns, and in South Carolina, this included mobile clinics, quarantine of unvaccinated individuals exposed to the virus, and structured briefings, alongside community outreach. These measures, while still more targeted than a broad COVID-style response, relied more on statewide coordination and a centralized approach. Cases in Utah have declined and South Carolina’s outbreak has been declared over, but whether and how much the different strategies contributed to those trends is difficult to assess.

The difference in approach represents a broader challenge in public health and vaccine communication that the current low-trust environment has made more difficult to navigate. Community-based approaches, particularly those relying on trusted local messengers, have shown effectiveness at building vaccine confidence in previous outbreaks, especially when messengers adapt to specific community concerns. Top-down approaches have also shown effectiveness at the population level. Research shows these approaches are particularly effective when barriers to vaccination are primarily about access or awareness and when existing infrastructure, like school vaccine requirements and established provider-patient relationships, provides a foundation for outreach. They may be less effective, though, in reaching strongly hesitant or polarized populations. Evidence on what strategies are most effective in the current low-trust environment remains limited.

Why It Matters: As research evolves, the strategies that work in one community may not work in another, and understanding what drives those differences is increasingly relevant to how outbreaks are managed.

Polling Insights: KFF polling has found that public trust in both federal health agencies and state government officials to provide reliable vaccine information has declined since the beginning of the COVID-19 pandemic. Prior KFF polling has also found that trust in state officials for vaccine information varies depending on whether people share the same political party as their state leadership. Democrats living in states with Democratic governors were more likely than Democrats in Republican-governed states to express trust in their state officials for vaccine information (66% v. 42%), as were Republicans living in states with Republican governors compared to Republicans in Democratic-governed states (47% v. 27%). This interplay of partisanship and trust may further impact how the public responds to public health communication strategies on the state and local level.

Split bar chart showing trust in state officials to provide reliable information about vaccines among Democrats and Republicans.

Knowledge Gaps About STIs and STI Prevention Persist

More than 2.2 million cases of chlamydia, gonorrhea, and syphilis were reported nationwide in 2024, 13% higher than a decade ago. Accurate understanding of how sexually transmitted infections (STIs) spread and which can be prevented may help address these rates, but a poll from the Annenberg Public Policy Center shows persistent gaps in knowledge and some enduring misconceptions about common STIs.

Most Americans understand the basics of how STIs spread, correctly identifying common transmission routes, though 1 in 5 (20%) incorrectly said sitting on a toilet seat was a risk. Knowledge about which STIs can be prevented through vaccination was more uneven. Awareness was highest for human papillomavirus (HPV), with 68% correctly identifying that a vaccine exists, though 14% incorrectly said it would lead teenagers to engage in risky sexual behavior. Less than half (42%) were aware that mpox was vaccine-preventable, and for infections with no available vaccine, like HIV and genital herpes, at least half were unsure or incorrectly believed vaccines existed.

Why It Matters: These gaps in public knowledge may contribute to vaccination decisions, even for infections where vaccines are available and recommended. The KFF/The Washington Post Survey of Parents, for example, found that about one in five (19%) parents of children under age 9 (who are not yet eligible for the HPV vaccine) said they would “probably not” or “definitely not” vaccinate their child for HPV, and another one in five (22%) were not sure. In open-ended responses, some parents who said they would not vaccinate their child for HPV cited concerns that the vaccine is associated with unsafe sexual behavior, while others cited concerns over side effects and safety.


AI & Emerging Technology

Researchers Explore Whether AI Can Help Build Resistance to False Health Claims

As about one-third of adults now turn to AI chatbots and other AI tools for health information, researchers are examining both the risks AI poses for the information environment and ways it might be used to counter false health claims. One line of research draws on “cognitive inoculation,” exposing people to weakened forms of misleading claims before they encounter them. The approach can function similarly to a vaccine by helping build resilience to false claims.

A study published this spring tests whether AI can extend that approach through personalized conversation, which has historically been harder to deliver at scale. Researchers built a chatbot to guide users through structured conversations about health-related misconceptions, including about binge drinking and the link between physical activity and mental health. The chatbot presented itself as a believer of these misconceptions and guided users to find evidence refuting them. Researchers compared the chatbot against reading an educational essay and writing refutations of common misconceptions, finding that the chatbot outperformed both alternatives in helping participants maintain confidence in accurate beliefs after exposure to a false claim.

AI is often discussed as a vector for false health claims, but this study offers an early signal that it may also help counter them. The small sample size and narrow focus make the findings difficult to generalize, and more research is needed before drawing broader conclusions.

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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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.

House Appropriations Committee Releases FY 2027 Labor, Health and Human Services, Education, and Related Agencies (Labor HHS) Appropriations Bill & Accompanying Report

Published: Jun 10, 2026

The House Appropriations Committee released its Fiscal Year 2027 Labor, Health and Human Services, Education, and Related Agencies (Labor HHS) appropriations bill on June 4, 2026 and accompanying explanatory report on June 8, 2026.

While most U.S. global health funding is provided to the State Department through a separate appropriations bill (see the KFF budget summary on this funding here), the Labor HHS appropriations bill includes funding for global health programs at the Centers for Disease Control and Prevention (CDC) as well as funding for global health research activities at the National Institutes of Health (NIH). Total global health funding at CDC and NIH through the Labor HHS bill is not yet known, as funding for some programs (i.e. global HIV/AIDS and malaria research) at NIH is determined at the agency level rather than specified by Congress in annual appropriations bills. Funding for global health in the Labor HHS bill remained flat compared to the FY 2026 level as follows:

  • CDC: Funding for global health programs at CDC totals $693 million, flat compared to the FY 2026 enacted level. This total includes funding provided for parasitic diseases and malaria, which the House bill moved to CDC’s Center for Emerging and Zoonotic Infectious Diseases but is included in the total here for comparison purposes. Within CDC, funding for polio and global public health protection were maintained at the FY 2026 level, and all other program areas (global HIV/AIDS, global tuberculosis, measles and other vaccine preventable diseases) were consolidated into the newly established “Global Emerging Infectious Diseases” line. The House report also directs “continued coordination with the State Department’s Bureau of Global Health Security and Diplomacy” on the implementation of the President’s Emergency Plan for AIDS Relief (PEPFAR) and other global health programs, “provides funding to be programmed by the CDC Director to sustain in-country health security capacities with international partners,” as well as “directs CDC to prioritize existing CDC international staffing, and to provide a briefing to the Committee not later than 90 days after enactment of this Act on the status of its engagement with the Department of State, the agency’s current global health workforce capacity, overseas staffing footprint, and plans to bolster core global health security and infectious disease response capabilities.”
  • NIH: Funding for global health research activities at the Fogarty International Center (FIC) at NIH totals $95 million, the same level as the FY 2026 enacted amount.

In addition, Section 235 under the Labor HHS section of the bill specifically states that funding “shall be for the budget activities, and in the amounts specified in the table under each such heading in the report accompanying this Act” instructing the administration to provide the amounts for the areas specified.

See the table below for additional details on global health funding. See other budget summaries and the KFF budget tracker for details on historical annual appropriations for global health programs.

KFF Analysis of Global Health Funding in the FY 2027 House Labor, Health and Human Services, Education, and Related Agencies (Labor HHS) Appropriations Bill & Accompanying Report (Table)

Global COVID-19 Tracker

Published: Jun 10, 2026

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

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.

Analysis of U.S. and Global Fund Funding Reductions in MOU Countries

Published: Jun 10, 2026

Worsening fiscal constraints and changing policy priorities have resulted in significant funding cuts to global health and development programs. While these reductions predated the cuts and disruptions made by the U.S. government last year, they were exacerbated by U.S. actions. The Organisation for Economic Co-operation and Development (OECD) recently reported that international aid fell significantly in 2025, driven primarily by the U.S., and that further declines are likely on the horizon. The health sector has not been immune to these pressures. The U.S. government and the Global Fund to Fight AIDS, Tuberculosis and Malaria (Global Fund), the top two donors1 to global health in low- and middle-income countries, each took actions to reduce funding to countries starting last year and plan to further reduce funding going forward. Under the Trump administration, the U.S., as part of its new America First Global Health Strategy (AFGHS) “MOU” agreements with countries, plans to reduce funding by billions over the next few years. The Global Fund, due to reduced contributions from the U.S. and other donors, is also reducing funding in the same set of countries. Together, the U.S. and Global Fund reductions serve as a “one-two punch” to countries, who will be faced with significantly fewer resources in the coming years.

This analysis assesses the magnitude of these combined funding cuts in 29 U.S. MOU countries between 2026 and 2029, relative to prior funding levels (see methodology for more details). As it shows, the combined decline is estimated to total $4.3 billion– a 24% drop relative to prior funding levels — most of which (77%) is driven by the U.S.  The cumulative cut, taking into account unexpected reductions in 2026, was even larger, reaching $5.8 billion. Moreover, further declines are likely to occur after this period.2 Such funding declines are unprecedented in the modern-day era of global health, which saw the creation of the President’s Emergency Plan for AIDS Relief (PEPFAR), the U.S. government’s flagship global health program, and of the Global Fund in the early 2000s, both of which helped to usher in significant new resources for global health.

Findings

The U.S. government is planning steep funding cuts to countries for health programs. In the 29 MOU countries analyzed, these cuts are estimated to total $3.3 billion by 2029, a 29% drop relative to prior funding levels.

  • Overall, funding in these 29 countries is estimated to decline from $11.3 billion over the prior three-year period (2024-2026) to $8 billion for the next three-year period (2027-2029), a 29% decline. This decline reflects two factors: first, after several years of stable funding for countries, the administration announced significant reductions starting in 2026, relative to prior levels, estimated to be $840 million, or 7%; second, further reductions of $2.5 billion or 23% are planned for 2027-2029 (see Figure 1).
  • Almost all 29 countries will face funding reductions.3 The countries with the biggest reductions in dollar terms are Uganda ($370 million), Mozambique ($356 million), Nigeria ($280 million), and Malawi ($252 million). Reductions range from 1% in Honduras to 82% in Senegal, with 12 countries experiencing reductions of 50% or greater (see Appendix Table 1).
U.S. Funding for Global Health in 29 MOU Countries, by Funding Period (Grouped Bars)

In these same 29 countries, Global Fund support is expected to decline by almost $1 billion over the next three years, a 15% drop compared to the prior period.4

  • Global Fund support will decline from $6.6 billion in the 2024-2026 country allocation period (grant cycle 7, or GC7) to $5.6 billion in the 2027-2029 allocation period (grant cycle 8, or GC8), a decline of $962 million or 15%. This decline is the result of the following two factors: a reduction in the original funding allocated to countries for GC7, due to unexpected shortfalls in donor contributions to the Global Fund (a reduction of $699 million or 11% from the original to revised allocations), and further reductions planned for GC8 due to ongoing funding constraints (a reduction of $263 million or 4% from revised GC7 allocations to GC8 allocations) (see Figure 2).
  • All 29 MOU countries will face Global Fund reductions. The countries with the biggest dollar reductions in GC8 (compared to the original allocations for GC7) are Nigeria ($141 million), Mozambique ($89 million), and the Democratic Republic of the Congo ($83 million). Reductions range from 5% in Niger to 53% in Guatemala (see Appendix Table 2).
Global Fund Allocations in 29 MOU Countries, by Grant Cycle (Grouped Bars)

The combined funding reduction from the U.S. and the Global Fund in these 29 countries is estimated to total $4.3 billion through 2029, a 24% decline (see Figure 3). The U.S. accounts for more than three quarters (77%) of the drop.

  • About half (15) of the MOU countries will experience funding reductions of $100 million or more, with the largest reductions in Mozambique ($445 million), Uganda ($436 million), Nigeria ($422 million), and Malawi ($331 million). Reductions range from 7% in Papua New Guinea to 66% in Senegal (see Appendix Table 3). The cumulative cut, taking into account unexpected reductions in 2026, was even larger, reaching $5.8 billion.
  • In addition to these funding reductions, these countries also face co-financing requirements from both the U.S. and the Global Fund  – with the U.S. requirement occurring for the first time – which could, in some cases, intensify the fiscal impact on recipient countries while offsetting some of the effect of the reductions on global health programs.
Combined U.S. and Global Fund Funding in Prior and Upcoming Funding Periods (Stacked column chart)

Looking beyond 2029, further declines are expected from the U.S., with an uncertain forecast from the Global Fund, as other donor governments are scaling back.

  • The U.S. government plans to scale back funding in these 29 countries by an additional $2 billion in 2030 as it seeks to move programs to country governments (the full cut planned for 2027-2030 is estimated to be $5.3 billion).
  • While the funding envelope for the Global Fund’s next grant cycle (GC9) is not yet known,5 the fiscal environment suggests additional reductions may lie ahead. In addition, five of the 29 MOU countries will transition out of Global Fund eligibility for at least one disease (HIV, TB, or malaria) by the next grant cycle: Botswana, the Dominican Republic, El Salvador, Guatemala, and Honduras.6
  • More broadly, other donor governments (that provide direct aid to countries as well as support for the Global Fund) have also been scaling back their health and development assistance.

Funding declines of this magnitude are unprecedented in the modern-day era of global health, which saw the creation of the Global Fund in 2002 and the launch of PEPFAR in 2003, both of which helped to usher in significant new resources for global health.

  • As such, this next period will mark a significant departure in the global health response, with countries expected to move increasingly away from dependency on external support for health, while simultaneously ramping up their own expenditures. This will likely pose challenges for at least some of these countries, particularly those facing significant co-financing requirements and experiencing or at risk of debt distress and/or fragility or conflict, and will impact the millions of people whose health has benefited from these efforts.

Appendix

U.S. Global Health Funding in 29 MOU Countries: Comparison of Prior Period (Original and Revised, FY24-26) and Upcoming Period (FY27-29) (Table)
Global Fund Allocations in 29 MOU Countries: Comparison of Grant Cycle 7 (Original and Revised) and Grant Cycle 8 Allocations (Table)
Comparison of Changes in Funding (Global Fund, U.S., and Combined) in 29 MOU Countries (Table)

Methodology

To assess the impact of funding changes on countries that receive U.S. and Global Fund funding for global health activities, we analyzed funding in three ways. For the 29 countries with signed MOUs and available data, we compared 1.) U.S. MOU funding to historical U.S. planned and proposed funding amounts, 2.) the Global Fund Grant Cycle 8 (GC8) allocations to Grant Cycle 7 (GC7) allocations (both original and reduced GC7 amounts), and 3.) the combined impact of funding changes to U.S. and Global Fund funding. U.S. planned/proposed funding amounts were obtained from ForeignAssistance.gov for FY24, the FY2025 International Affairs Budget Request for FY25 (and FY26 original amounts), and MOU agreements for FY26 revised amounts. U.S. MOU funding amounts were obtained from U.S. Department of State, U.S. embassy, and Ministries of Health press releases, as well as MOU documents if available. Global Fund allocations were obtained from the Global Fund’s ‘Eligibility, Allocations & Funding’ data: https://archive.theglobalfund.org/eligibility-allocations/.

U.S. Funding Comparison: In countries that have signed bilateral global health agreements with the U.S., we compared U.S. MOU funding to what countries had historically received from the U.S. for global health in prior years. “Original prior period” funding represents FY24-FY26 funding; FY24-FY25 represent requested amounts and FY26 was assumed to remain at the FY25 level. “Revised prior period” funding represents FY24-FY26 funding; FY24-FY25 represent requested amounts and FY26 represent the first year of funding (FY26) provided in the MOUs. Most signed MOUs span a five-year period (FY26-FY30). To match the Global Fund’s three-year grant cycle period, if annual funding amounts were not available, five-year funding was adjusted to estimate a three-year total (for FY27-FY29) and compared to the prior three-years of U.S. proposed funding (FY24-FY26). For countries whose annual MOU amounts are not yet available (all but eight), MOU funding amounts were calculated to be spread evenly throughout the five-year period. Based on the eight MOU countries whose annual funding amounts were available (Cameroon, Ethiopia, Kenya, Liberia, Mozambique, Nigeria, Rwanda, and Uganda, which together account for 70% of U.S. MOU funding over the five-year period), the U.S. provides more funding to countries in earlier years of the MOU agreement, with steeper cuts occurring at the end of the five-year MOU period. While 32 countries to date have signed or indicated an intent to sign MOUs with the U.S., for comparison purposes, this analysis is based on 29 countries, as three (Bolivia, Panama, and the Philippines) have limited data on Global Fund allocations, U.S. historical, and/or planned MOU funding (Bolivia received Global Fund support in GC7 and GC8 but did not receive U.S. funding for global health in FY24-FY25; Panama did not receive Global Fund support in GC7 or GC8 and did not receive U.S. funding for global health in FY24-FY25; and the Philippines received Global Fund support in GC7 and GC8 but did not sign an official MOU but rather a declaration of intent to “establish a framework for health cooperation”).

Global Fund Comparison: In the same set of 29 countries, we compared GC8 allocations to GC7 (both original and reduced) allocations. The GC7 replenishment period was 2023-2025 with the country implementation/allocation period spanning 2024-2026; The GC8 replenishment period is 2026-2028, with the country implementation/allocation period spanning 2027-2029. Some GC7 allocation amounts were reported in source currency and were converted to USD based on the EUR/USD allocation rate for the allocation period, EUR/USD = 0.993542.

Combined Funding (Global Fund + U.S.) Comparison: To assess the combined impact of Global Fund and U.S. funding changes in MOU countries, we compared the sum of the original GC7 allocations and U.S. historical global health funding over the same period (FY24- FY26) with the sum of the GC8 allocations and U.S. MOU funding for the following period (FY27-FY29). If annual U.S. MOU amounts were not available, three-year adjusted totals were used.

Jen Kates currently serves on the board of the Global Fund to Fight AIDS, Tuberculosis and Malaria.


  1. The U.S. government has historically provided a third of the Global Fund’s funding. Even without this amount, however, the Global Fund still ranks as the number two donor to global health. ↩︎
  2. For comparison purposes with the Global Fund’s grant period, this analysis focuses on a three-year funding period. The full scope of most U.S. MOUs encompasses five years. Overall, $20.3 billion ($12.8 billion in U.S. funding and $7.5 billion in country co-financing) has been announced for 32 countries over the next five years (FY26-FY30). Compared to the prior five years (FY21-FY25), U.S. funding would decline by approximately $6 billion or 32%. See the KFF Tracker on America First MOU Bilateral Global Health Agreements for more details on the full scope of the MOUs.  ↩︎
  3. While El Salvador and Papua New Guinea would experience increases in funding compared to the prior three-year period ($4 million or 28% for El Salvador and $1 million or 13% for Papua New Guinea), these countries would still see drops over the full five-year period of the MOU (a 33% reduction in El Salvador and 26% reduction in Papua New Guinea compared to the prior five-year period). See the KFF Tracker on America First MOU Bilateral Global Health Agreements for more detail. ↩︎
  4. More broadly, Global Fund funding to all 103 countries it supports will decline by $2.3 billion in GC8, compared to the original allocations for GC7. ↩︎
  5. The Global Fund raises funding in three-year “replenishment” cycles. The amount raised determines the amount available for country allocations. The replenishment conference for GC9 (2029-2031 replenishment period and 2030-2032 country implementation period) will take place in 2028. ↩︎
  6. The Philippines, which is also a U.S. MOU country but was not included in this analysis, will also transition out of Global Fund eligibility for at least one disease component in the next grant cycle. ↩︎