First-Year Rural Health Fund Awards Range From Less Than $100 Per Rural Resident in Ten States to More Than $500 in Eight

Published: Jan 6, 2026

On December 29, 2025, the Centers for Medicare & Medicaid Services (CMS) announced first-year state awards from the $50 billion Rural Health Transformation Program (the “rural health fund”), which is being administered by a new Office of Rural Health Transformation. The rural health fund was created as part of the July 2025 budget reconciliation law, sometimes called the One Big Beautiful Bill, to help offset the impact on rural areas of the law—which includes an estimated $911 billion in federal Medicaid spending reductions over ten years, including an estimated $137 billion in rural areas. All 50 states applied for the rural health fund, and each state received an award. CMS will distribute $10 billion each year from fiscal years 2026 through 2030, beginning this year.

State awards for 2026, the first of five years, average $200 million, ranging from $147 million in New Jersey to $281 million in Texas (Figure 1). Differences in total awards across states in the first year (and most likely in future years) are modest relative to large differences in rural populations and rural health needs more generally. For example, Texas has about thirty times as many rural residents as New Jersey (4.3 million versus about 140,000) but is only receiving about twice as much funding in the first year ($281 million versus $147 million). Differences in total awards across states are relatively modest primarily because half of the rural health fund (50%) is being distributed equally across approved states, regardless of need, as required by law. Because all states have been approved for funding, each is slated to receive $100 million from this half of the fund in 2026 and in each year from 2027 through 2030.

Texas, Alaska and California are receiving the largest total awards in the first year. While Texas and California have the largest and fourth-largest rural populations in the country, respectively, Alaska has the fifth smallest rural population. Alaska likely received a relatively large award at least in part because a portion of the fund was distributed to the five largest states based on land area. New Jersey, Connecticut, and Rhode Island are receiving the smallest awards in the first year. These are all states with relatively small rural populations.


Figure 1


First-year awards per rural resident vary widely across states, ranging from less than $100 in ten states to more than $500 in eight states according to KFF analysis (see Figure 2). State awards are partially, but not closely, tied to rural population, meaning that first-year awards per rural resident are generally relatively small among states with the largest rural populations. For example, Texas has the largest rural population in the country—and the largest total award in the first year—but will receive the smallest payment per rural resident ($66 in 2026). In contrast, states like Rhode Island, New Jersey, and Alaska, with far fewer rural residents, will receive substantially higher amounts per rural resident ($6,305, $1,069, and $990 respectively, with Rhode Island being an extreme outlier). Only a quarter of the $50 billion fund is being distributed exclusively based on measures of state need, with just 5% of the fund that is based on rural population. Other measures of need, according to CMS, include the number of rural facilities, land area, the share of hospitals receiving Medicaid disproportionate share hospital (DSH) payments, and other factors.

First-Year Rural Health Fund Awards Range From Less Than $100 Per Rural Resident in Ten States to More Than $500 in Eight States

While lawmakers created the fund in part to help offset the impact on rural hospitals of cuts under the reconciliation law, CMS has made clear that funding is intended to benefit rural communities more broadly by transforming health care systems. Examples of state initiatives based on the subset of state applications available to the public and abstracts posted on CMS’s website include initiatives related to Make America Healthy Again (MAHA) (such as improving access to healthy foods and preventing and managing chronic conditions), expanding telehealth services and remote patient monitoring, rural workforce development programs, and supporting regional collaboration among providers.

CMS stipulates that payments to hospitals and others for patient care cannot exceed 15% of total funds, though providers could benefit in other ways, such as through investments in existing buildings and infrastructure (restricted to 20% of total funds). It is unclear how much of the money will benefit rural hospitals either directly or indirectly and the extent to which this will offset hospitals’ losses under the reconciliation bill. Moreover, it is not yet clear how much information will be available to the public to track the flow of dollars from states to rural providers and other entities and to evaluate the effectiveness of state initiatives.

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

Medicaid Enrollment and Unwinding Tracker

Published: Jan 5, 2026

Enrollment Data

Note: The data presented below are updated monthly as new Medicaid/CHIP enrollment data become available.

The Medicaid Enrollment and Unwinding Tracker presents the most recent data on monthly Medicaid/CHIP enrollment reported by the Centers for Medicare & Medicaid Services (CMS) as part of the Performance Indicator Project as well as archived data on renewal outcomes reported by states during the unwinding of the Medicaid continuous enrollment provision. The unwinding data were pulled from state websites, where available, and from CMS.

Medicaid/CHIP enrollment trends generally use February 2020 as the baseline month because it was the month prior to the start of the COVID-19 pandemic and implementation of the continuous enrollment provision. During continuous enrollment, which was in place during the three years of the pandemic, states paused Medicaid disenrollments. As a result, when the continuous enrollment provision ended in March 2023, national Medicaid/CHIP enrollment had increased to a record high of 94 million enrollees. Beginning April 1, 2023, states could resume disenrolling people after conducting renewals to verify eligibility for the program, though some states delayed the start of their unwinding periods until May, June, or July 2023. Most states took 12 months to complete unwinding renewals and nearly all states completed renewals by August 2024.

The figures below show Medicaid and CHIP enrollment from February 2020 through the most current month of available data. Some figures also include enrollment for adults and children in Medicaid/CHIP. Key enrollment trends as of September 2025 include:

  • There are 77.1 million people enrolled in Medicaid/CHIP nationally (Figure 1). This represents an 18% decline from total Medicaid/CHIP enrollment in March 2023, but is still 8% higher than Medicaid/CHIP enrollment in February 2020, prior to the pandemic (Figure 2 and Table 1).
  • Several factors likely explain why national Medicaid/CHIP enrollment is higher than pre-pandemic enrollment. The pandemic may have encouraged some people who were previously eligible for Medicaid but not enrolled to newly enroll in the program. During the unwinding, many states took steps to improve their renewal processes, which reduced the number of people who were disenrolled despite remaining eligible. In addition, some states expanded eligibility for certain groups since the start of the pandemic, such as the Affordable Care Act’s (ACA) Medicaid expansion.
  • Medicaid/CHIP enrollment is higher than pre-pandemic levels in all but fourteen states (AK, AR, CO, ID, IA, LA, MI, MT, NH, NM, SC, TN, TX, and WV). Enrollment changes from pre-pandemic baseline vary from a 16% decrease in Montana to a 54% increase in North Carolina (Figure 2). Many of the states with the largest increases in enrollment expanded eligibility since the start of the pandemic. For example, five states (NE, OK, MO, SD, and NC) implemented the Medicaid expansion between October 2020 and December 2023 and Maine increased the income limit for children to qualify for Medicaid.
  • In the 49 states and DC with complete enrollment data by age, there are 36 million children (48%) and 39.3 million adults (52%) enrolled, a change from pre-pandemic (February 2020) enrollment patterns when children made up a slight majority (51%) of Medicaid/CHIP enrollees (Figure 1).
  • Child enrollment in Medicaid/CHIP is below pre-pandemic enrollment in 19 states, while adult enrollment is below pre-pandemic levels in 12 states (Figure 2).
  • There are 69.8 million people enrolled in Medicaid and 7.3 million people enrolled in CHIP (Figure 1). More states report Medicaid enrollment above their pre-pandemic baselines compared to the number reporting CHIP enrollment above the baseline (Figure 2).
National Enrollment in Medicaid/CHIP, February 2020 to April 2025
Cumulative Percent Changes in Enrollment from February 2020 to April 2025
Total Medicaid/CHIP Enrollment, Selected Time Periods

Unwinding Data – Archived

Note: The data on unwinding renewal outcomes presented below were last updated on September 12, 2024; since most states have now completed the Medicaid unwinding, the information will not be updated again.

As of September 12, 2024 and with nearly complete unwinding data for most states: 

  • Over 25 million people were disenrolled (31% of completed renewals) and over 56 million people had their coverage renewed (69% of completed renewals).  
  • Disenrollment rates varied across states from 57% in Montana to 12% in North Carolina, driven by a variety of factors including differences in renewal policies and procedures as well as eligibility expansions in some states.  
  • Among those who were disenrolled, nearly seven in ten (69%) were disenrolled for paperwork or procedural reasons while three in ten (31%) were determined ineligible.  
  • Among those whose coverage was renewed during the unwinding, 61% were renewed on an ex parte, or automated, basis, meaning the individual did not have to take any action to maintain coverage. 

State Data on Renewal Outcomes

The data on unwinding-related renewal outcomes presented in this section rely primarily on monthly reports that states were required to submit to the Centers for Medicare & Medicaid Services (CMS) during the unwinding period. The data also reflect updates to the monthly reports that states submit three months after the original report submission to account for the resolution of pending cases and any other changes in renewal metrics. For 13 states, data were pulled from dashboards or reports published on state websites that provide more complete information, and for a few additional states, updated monthly reports were pulled from state websites because they were more timely than what is reported on the CMS website. 

To view archived data for specific states, click on the State Data – Archived tab.

 

As of August 1, 2024, States Have Reported Renewal Outcomes for Over Eight in Ten People who were Enrolled in Medicaid/CHIP Prior to the Start of the Unwinding

 

Medicaid Disenrollments

  • As of September 12, 2024, at least 25,198,000 Medicaid enrollees had been disenrolled during the unwinding of the continuous enrollment provision. Overall, 31% of people with a completed renewal were disenrolled in reporting states while 69%, or 56.4 million enrollees, had their coverage renewed.
  • There is wide variation in disenrollment rates across reporting states, ranging from 57% in Montana to 12% in North Carolina. A variety of factors contribute to these differences, including differences in renewal policies and system capacity. Some states adopted policies that promote continued coverage among those who remain eligible and/or have automated eligibility systems that can more easily and accurately process renewals while other states have adopted fewer of these policies and have more manually-driven systems. In addition, North Carolina and South Dakota adopted Medicaid expansion and other states increased eligibility levels for certain populations (e.g., children, parents, etc.) during the unwinding, which may have lowered disenrollment rates in these states.

At least <b>24,838,000</b> Medicaid enrollees have been disenrolled with publicly available unwinding data, as of August 1, 2024

 

  • Across all states with available data, 69% of all people disenrolled had their coverage terminated for procedural reasons. However, these rates vary based on how they are calculated (see note below). Procedural disenrollments are cases where people are disenrolled because they did not complete the renewal process and can occur when the state has outdated contact information or because the enrollee does not understand or otherwise does not complete renewal packets within a specific timeframe. High procedural disenrollment rates are concerning because many people who are disenrolled for these paperwork reasons may still be eligible for Medicaid coverage. 

(Note: The first tab in the figure below calculates procedural disenrollment rates using total disenrollments as the denominator. The second tab shows these rates using total completed renewals, which include people whose coverage was terminated as well as those whose coverage was renewed, as the denominator. And finally, the third tab calculates the rates as a share of all renewals due, which include completed renewals and pending cases.)

Of all people who were disenrolled, 69% were terminated for procedural reasons, as of August 1, 2024

Medicaid Renewals

  • Of the people whose coverage has been renewed as of September 12, 2024, 61% were renewed on an ex parte basis while 39% were renewed through a renewal form, though rates vary across states. Under federal rules, states are required to first try to complete administrative (or “ex parte”) renewals by verifying ongoing eligibility through available data sources, such as state wage databases, before sending a renewal form or requesting documentation from an enrollee. Ex parte renewal rates varied across states from 90% or more in Arizona, North Carolina, and Rhode Island to less than 20% in Pennsylvania and Texas. 

Overall, 61% of people who retained Medicaid coverage were renewed through ex parte processes, as of August 1, 2024

Federal Data on Renewal Outcomes

The data presented here are cumulative unwinding metrics published by CMS. These counts and percentages may differ from the above data, which present renewal metrics reported on state websites when state-reported data are more complete.  

Figure 1 below shows cumulative renewal data reported by CMS during states’ unwinding periods. Renewal data for the months after the end of states’ unwinding period are excluded. The data reflect updated unwinding data reported by states three months after the original monthly reports as they become available.   

Cumulative Medicaid Renewal Outcomes for Reporting States through April 2023

For questions about this tracker, please contact KFFTracker@kff.org

State Data – Archived

Note: The state data presented below were last updated on September 12, 2024; since most states have now completed the Medicaid unwinding, the information will not be updated again. 

The data presented here provide state-level data on enrollment trends and renewal outcomes during the unwinding period. Figure 1 shows total Medicaid enrollment by month starting in January 2023 and, once disenrollments resumed in a state, the cumulative percent change in Medicaid enrollment relative to the month before Medicaid disenrollments started (this baseline month will differ across states). Figure 2 shows renewal metrics for each month of a state’s unwinding period (or cumulative data for the unwinding period for some states). 

For total national Medicaid enrollment, click on the Enrollment Data tab.

Related Resources

Resources on unwinding data

Resources on state policies and preparations for the unwinding

Resources on pre-pandemic enrollment patterns and coverage transitions

KFF’s unwinding explainer

Overview of President Trump’s Executive Actions Impacting LGBTQ+ Health

Published: Jan 5, 2026

Editorial Note: This resource was originally published on February 24, 2025, and will be updated as needed 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 health programs, efforts, or policies to meet the health needs of LGBTQ+ people. 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, such as litigation efforts, are listed under “What Happens/Implications.” It is not inclusive of administrative actions that impact LGBTQ+ people that are not directly related to health and health care access, such as efforts related to participation in sport even though those actions might have an impact on well-being. In addition, within the actions examined, only provisions directly related to health and health access are described in table.

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 LGBTQ+ equity including “Preventing and Combating Discrimination on the Basis of Gender Identity or Sexual Orientation” (Executive Order 13988) and “Advancing Equality for Lesbian, Gay, Bisexual, Transgender, Queer, and Intersex Individuals” (Executive Order 14075). The order establishing the White House Gender Policy Council (Executive Order 14020) and several Orders related to diversity, equity, and inclusion were also rescinded, as were orders related to nondiscrimination and equity in schools.
Implications: This order could lead to less oversight, reduced health programing, and fewer policies protecting LGBTQ+ people, which could negatively impact access to care and well-being. Of particular note:

Rescinds orders that had called for LGBTQ+ people’s health equity, the national public health needs of LGBTQ+ people, LGBTQ+ data collection, and nondiscrimination protections, including in health care.

Rescinds orders that had called for nondiscrimination protections for LGBTQ+ young people in school, which could contribute to stigma and worsened mental health.
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, including in sex protections and in agency operations. 
 
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 LGBTQ people’s health 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.”

• Defines male and female based on reproductive cell production. Introduces the term “gender ideology” which is defined to include  “the idea that there is a vast spectrum of genders that are disconnected from one’s sex” and “maintains that it is possible for a person to be born in the wrong sexed body.”

• Directs the Secretary of Health and Human Services (HHS) to provide the U.S. government, external partners, and the public 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 agency forms to exclude gender identity and directs agencies to “take all necessary steps, as permitted by law, to end the Federal funding of gender ideology.”

• Requires that federal funds “not be used to promote gender ideology” and directs agencies to ensure “grant funds do not promote gender ideology.”

• Directs the Attorney General to ensure the Bureau of Prisons revises policies to prohibit federal funds from being expended “for any medical procedure, treatment, or drug for the purpose of conforming an inmate’s appearance to that of the opposite sex.”

• Rescinds multiple executive orders issued by President Biden, including: “Preventing and Combating Discrimination on the Basis of Gender Identity or Sexual Orientation” (13988), “Establishment of the White House Gender Policy Council” (14020) (which is also dissolved), and “Advancing Equality for Lesbian, Gay, Bisexual, Transgender, Queer, and Intersex Individuals” (14075).

• Also directs agencies to rescind certain guidance documents, including, “The White House Toolkit on Transgender Equality”; “The Attorney General’s Memorandum of March 26, 2021 entitled “Application of Bostock v. Clayton County to Title IX of the Education Amendments of 1972,” and range of orders related to LGBTQ+ students in schools.



Implications: This order is broad, directed to all federal agencies and programs. Because federal health programs reach LGBTQ+ people, and some are specifically designed to be inclusive of the LGBTQ+ community, or account for gender identities in addition to biological sex, this Order could widely affect program funding, guidance, and access. It has several possible implications:

The terms used in the Order include several biological and social inaccuracies which could perpetuate misinformation about LGBTQ+ people and transgender people’s health needs. It also takes steps towards ban gender care in certain area, most explicitly in prisons.

Requiring that federal funds are not used to “promote gender ideology” has caused significant confusion. Since this order was issued, there have been multiple reports of HIV programs and community health centers that have lost funding as a result of supporting programs inclusive of transgender people. In addition, there have been reports that some health care facilities paused providing youth with gender affirming care, fearing that federal funding would be withheld according to this and another Order relating to youth access to gender affirming care (see separate entry). (See court decisions below.) Withholding care could lead to negative health outcomes for those that require it.

Data collection and data presentation/distribution have been impacted. At first some data was removed from federal websites, though due to court order this appears to have been restored. If public health messaging and services related to the health needs of transgender people, or other specific populations, are unavailable, this may result in adverse health outcomes such increased disease prevalence, greater difficulty with care engagement, and poor mental health outcomes. There have been reports that gender identity questions will be removed from federal surveys which makes tracking the experiences and well-being of LGBTQ+ people more difficult.

The order directs the HHS Secretary to take action to end gender affirming care through Section 1557 of the Affordable Care Act (ACA), the law’s major nondiscrimination provision, which includes protections on the basis of sex. While the Biden administration interpreted sex protections to include sexual orientation and gender identity, it is expected that the Trump administration will seek to remove these protections, as was the approach during his first term. Despite the Executive Orders and any future guidance, courts could continue to rule that such protections exist in statute.

On March 17th the VA announced that it would phase out providing gender affirming care to comply with this Executive Order. Exceptions include Veterans already receiving hormone therapy from the VA or Veterans “receiving such care from the military as part of and upon their separation from military service” who are eligible for VA health care. The VA will not provide other gender affirming medical services.

The statement writes that historically the VA had provided a range of gender affirming services and “letters of support encouraging non-VA providers to perform sex-change surgeries on Veterans.” These services had been authorized under the now rescinded Veterans Health Administration Directive 1341(4).

There have been multiple legal challenges to this Order with some judicial actions that have paused aspects of implementation:

• On February 4, 2025 a lawsuit was filed in federal court challenging the Order on the grounds that it usurps Congressional  power, violates Sec. 1557 of the ACA, and is unconstitutional and on February 11 a temporary restraining order  and memorandum opinion was issued requiring restoration of webpages, datasets, and any other  resources needed to provide medical care, identified by the Plaintiffs.

• On February 4, 2025, a separate federal lawsuit was filed challenging this Order and the Executive Order on “Protecting Children from Chemical and Surgical Mutilation” (see separate entry), asserting they are openly discriminatory, unlawful, and unconstitutional. On February 13, a federal judge issued a temporary restraining order preventing the federal government from withholding or conditioning funding on the basis of providing this care.

• An additional suit was filed on February 19, 2025 by the National Urban League, National Fair Housing Alliance, and AIDS Foundation of Chicago challenging three Executive Orders: “Ending Radical and Wasteful DEI Programs and Preferencing”, “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” and the “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” as usurping the power of Congress, violating the Constitution and the Administrative Procedures Act, and, seeking declaratory and injunctive relief. In their complaint, plaintiffs highlight the potential harm this Order could bring to people with HIV and LGBTQ+ communities and the programs that serve them.

• On February 20, a separate case was filed in federal court by multiple LGBTQ+ health care and service organizations, challenging the “Ending Radical and Wasteful DEI Programs and Preferencing”, “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” and the “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” Orders claiming they usurp the power of Congress and violate the Constitution. In their complaint, plaintiffs highlight the potential harm this Order could bring to people with HIV and LGBTQ communities and the programs that serve them. On June 9th, 2026, the court issued a preliminary injunction, blocking in part key provisions in this EO and in the DEI EO including those that instruct agencies to remove and cease to issue  materials and “communications…that promote or otherwise inculcate gender ideology” and instructing agencies to “end the Federal funding of gender ideology”; prohibit federal funds from being “used to promote gender ideology,”; and direct agencies and departments to terminate DEI offices and positions, materials, initiatives, performance requirements, and grants or contracts.

• On March 12, 2025 two physician and academic plaintiffs filed a lawsuit challenging the Order and related OPM memo when their articles were removed from HHS’ Agency for Healthcare Research and Quality (AHRQ)’s Patient Safety Network (PSNet), a federal online patient-safety resource. The reason for the removal articles was for their inclusion of passing references to transgender patients. On May 23, a MA district court found the plaintiffs would likely succeed on their constitutional 1st amendment claims and granted a preliminary injunction requiring HHS to republish the censored content.
Ending Radical and Wasteful Government DEI Programs and Preferencing, January 20, 2025
Purpose: To limit diversity, equity, inclusion, and accessibility (DEIA) activities in government and by government contractors and grantees.  
 
Directs each agency, department, or commission head to take the following actions (among others):  
• terminate, to the maximum extent allowed by law, all DEI, DEIA, and “environmental justice” offices and positions…; all “equity action plans,” “equity” actions, initiatives, or programs, “equity-related” grants or contracts… 
• provide the Director of the OMB with a list of all “federal grantees who received Federal funding to provide or advance DEI, DEIA, or “environmental justice” programs, services, or activities since January 20, 2021,” among other actions.  
Implications: As with the other DEIA related Order (see separate entry), these efforts could make reaching populations with unique health needs in culturally competent ways more challenging, including in programs related to LGBTQ+ health and HIV. It could also jeopardized programs and funding for agencies reaching these communities.
There have been multiple legal challenges to this Order:

On February 3, a lawsuit was filed by four diverse plaintiffs challenging the constitutionality of this Order and the Order, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity”.

An additional suit was filed in federal court on February 19, 2025 by the National Urban League, National Fair Housing Alliance, and AIDS Foundation of Chicago challenging this order as well as the “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” and the “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” ” as usurping the power of Congress, violating the Constitution and the Administrative Procedures Act, and, seeking declaratory and injunctive relief. In their complaint, plaintiffs highlight the potential harm this Order could bring to people with HIV and LGBTQ communities and the programs that serve them.

On February 20, a separate case was filed in federal court by multiple LGBTQ+ health care and service organizations, challenging the “Ending Radical and Wasteful DEI Programs and Preferencing”, “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” and the “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” orders claiming they usurp the power of Congress and violate the Constitution.  In their complaint, plaintiffs highlight the potential harm this Order could bring to people with HIV and LGBTQ communities and the programs that serve them. On June 9th, 2026, the court issued a preliminary injunction, blocking in part key provisions in this EO and in the “gender ideology” EO including those that instruct agencies to remove and cease to issue  materials and “communications…that promote or otherwise inculcate gender ideology” and instructing agencies to “end the Federal funding of gender ideology”; prohibit federal funds from being “used to promote gender ideology,”; and direct agencies and departments to terminate DEI offices and positions, materials, initiatives, performance requirements, and grants or contracts.
Ending Illegal Discrimination and Restoring Merit-Based Opportunity, January 21, 2025
Purpose: Order seeks to end federal “preferencing” through DEIA efforts within government and through contracting to the extent that they do not comply with the Administration’s view of civil rights law.

The order is broad and non-specific but includes the following directives:

Orders all executive departments and agencies “to terminate all discriminatory and illegal preferences, mandates, policies, programs, activities, guidance, regulations, enforcement actions, consent orders, and requirements.  I further order all agencies to enforce our longstanding civil-rights laws and to combat illegal private-sector DEI preferences, mandates, policies, programs, and activities.”

Orders agency heads to include in every contract or grant award “a term requiring the contractual counterparty or grant recipient to agree that its compliance in all respects with all applicable Federal anti-discrimination laws is material to the government’s payment decisions for purposes of section 3729(b)(4) of title 31, United States Code; and…A term requiring such counterparty or recipient to certify that it does not operate any programs promoting DEI that violate any applicable Federal anti-discrimination laws.”
Implications: As with the other DEIA related Order (see separate entry), these efforts could make reaching populations with unique health needs in culturally competent ways more challenging, including in programs related to LGBTQ+ health and HIV. It could also jeopardized programs and funding for agencies reaching these communities.

There have been multiple legal challenges to this Order:

On February 3, a lawsuit was filed by four diverse plaintiffs challenging the constitutionality of this and the “Ending Radical and Wasteful Government DEI Programs and Preferencing” Order.

An additional suit was filed in federal court on February 19, 2025 by the National Urban League, National Fair Housing Alliance, and AIDS Foundation of Chicago challenging this order as well as the “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” and the “Ending Radical and Wasteful Government DEI Programs and Preferencing” as usurping the power of Congress, violating the Constitution and the Administrative Procedures Act, and, seeking declaratory and injunctive relief. In their complaint, plaintiffs highlight the potential harm this Order could bring to people with HIV and LGBTQ communities and the programs that serve them.

On February 20, a separate case was filed in federal court by multiple LGBTQ+ health care and service organizations, challenging the “Ending Radical and Wasteful DEI Programs and Preferencing”, “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government” and the “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” orders claiming they usurp the power of Congress and violate the Constitution.  In their complaint, plaintiffs highlight the potential harm this Order could bring to people with HIV and LGBTQ communities and the programs that serve them.
Protecting Children From Chemical and Surgical Mutilation, January 28, 2025
Purpose: Order directs agencies and programs to work towards significantly limiting access to gender affirming care for young people (defined as those under age 19) nationwide.

Directs agencies to rescind and amend policies that rely on guidance from the World Professional Association for Transgender Health (WPATH).

Directs the HHS Secretary to conduct and publish a review of existing literature and best practices related to gender affirming care and gender dysphoria and to “increase the quality of data to guide practices“ in this area.

Directs executive department and agency heads “that provide research or education grants to medical institutions, including medical schools and hospitals”, “in coordination with the Director of the Office of Management and Budget” to “immediately take appropriate steps to ensure that institutions receiving Federal research or education grants end the chemical and surgical mutilation of children” (which is how the Order defines gender affirming care).

Directs the HHS Secretary to take action to end gender affirming care for children “including [through] regulatory and sub-regulatory actions, which may involve the following laws, programs, issues, or documents:
– Medicare or Medicaid conditions of participation or conditions for coverage
– clinical-abuse or inappropriate-use assessments relevant to State Medicaid programs
– mandatory drug use reviews
– section 1557 of the Patient Protection and Affordable Care Actquality, safety, and oversight memoranda
– essential health benefits requirements; and
– the Eleventh Revision of the International Classification of Diseases and other federally funded manuals, including the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition.”

Withdraws Biden Administration “HHS Notice and Guidance on Gender Affirming Care, Civil Rights and Patient Privacy” and directs the Secretary of HHS “in consultation with the Attorney General [to] issue new guidance protecting whistleblowers who take action related to ensuring compliance with this order.”

Directs the Secretary of the Department of Defense to “commence a rulemaking or sub-regulatory action” restrict access to gender affirming care for children in the TRICARE program.

Directs the Director of the Office of Personnel Management to limit access to care in coverage for federal employees’ families by requiring “provisions in the Federal Employee Health Benefits (FEHB) and Postal Service Health Benefits (PSHB) programs call letter for the 2026 Plan Year” that would require eligible carriers to exclude “coverage for pediatric transgender surgeries or hormone treatments…”

Directs the Attorney General to review Department of Justice laws on female genital mutilation and “prioritize enforcement of protections” and “to convene States’ Attorneys General and other law enforcement officers to coordinate the enforcement of laws against female genital mutilation.”

Directs the Attorney General to “prioritize investigations and take appropriate action to end deception of consumers, fraud, and violations of the Food, Drug, and Cosmetic Act by any entity that may be misleading the public about long-term side effects of chemical and surgical mutilation.”

Directs the Attorney General “in consultation with the Congress” “to draft, propose, and promote legislation to enact a private right of action for children and the parents” who have received gender affirming care “which should include a lengthy statute of limitations.

Directs the Attorney General to “prioritize investigations and take appropriate action to end child-abusive practices by so-called sanctuary States that facilitate stripping custody from parents who support the healthy development of their own children, including by considering the application of the Parental Kidnapping Prevention Act and recognized constitutional rights.”

Directs agency heads included in this executive order to “submit a single, combined report to the Assistant to the President for Domestic Policy, detailing progress in implementing this order and a timeline for future action” within 60 Days of its issuance.
Implications: If fully implemented, the Order would broadly and extensively limit access to gender affirming care for young people, across a range of payers and providers. Access to gender affirming care is associated with improved mental health outcomes for transgender people and limiting this care with negative ones, including poorer mental health outcomes. Additional impact includes:

The executive order includes details about sex, gender identity, gender affirming care, and transgender people that conflict with science and evidence. These inaccuracies include suggesting that large shares of youth are seeking gender affirming medical care, that regret rates among those seeking care are high, and conflating “female genital mutilation” and gender-affirming care. This has the potential to promote hostility, stigma, and discrimination, and can lead to care denials.

It seeks to remove Federal reference to one of the standards of evidence-based care for transgender people in the US. Directing the HHS Secretary to develop new guidance without this standard, and in accordance with this and other orders, could limit agency ability to identify standards that adequately meet the needs of transgender people.

It also seeks to condition federal research and education grants on grantees not providing young people with gender affirming care.

There has already been some confusion with certain states and providers looking to preemptively comply with the order and another Order relating to “gender ideology” (see separate entry).

The order lays groundwork for the Administration remove explicit protects for LGBTQ+ people in health care, including with respect to accessing gender affirming care. Specifically, the Order suggests a reinterpretation of sex protections in Section. 1557 of the Affordable Care Act void of explicit protections on the basis of sexual orientation and gender identity.

The order leans on laws and policies unrelated to gender affirming care in an effort to limit access to those services including by erroneously conflating gender affirming care and female genital mutilation, using the FDA regulatory process to limit access, and suggesting kidnapping protections be applied to parents in certain circumstance.

On February 19, 2025, additional guidance was released relating to this order, providing new and refined definition of terms “ which directs the Department of Health and Human Services (the Department) to promulgate clear guidance to the U.S. Government, external partners, and the public, expanding on the sex-based definitions set forth in the Executive Order.”

On February 20, 2025, pursuant to this Order, HHS issued a “Recession of ‘HHS Notice and Guidance on Gender Affirming Care, Civil Rights, and Patient Privacy’ issued by the Biden Administration” which had stated the Administration “stands with transgender and gender nonconforming youth” and that medically necessary for gender affirming care for minors improves physical and mental health. It also reiterated that administration’s view that Sec. 1557 of the ACA includes protections on the basis of sexual orientation and gender identity.

There have been multiple legal challenges to this Order with some judicial actions that have paused aspects of implementation:

On February 4, 2025, a federal lawsuit was filed challenging this Order and the Executive Order on “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to The Federal Government,” asserting they are openly discriminatory, unlawful, and unconstitutional. On February 13, a federal judge issued a temporary restraining order preventing the federal government from withholding or conditioning funding on the basis of providing this care. On March 4th, the court issued a preliminary temporary injunction.

An additional federal lawsuit was filed on February 7th challenging this executive order with a separate temporary restraining order being issued on the 14th preventing the conditioning of federal funds and also applying to a condition linking gender affirming care to female genital mutilation. The restraining order was extended through March 5th on February 26th. 

On June 1, the FBI posted on social media urging the public to “report tips of any hospitals, clinics, or practitioners performing these surgical procedures on children,” despite pediatric gender affirming care being permitted in about half of states and not prohibited by the federal government.
Ending Radical Indoctrination in K-12 Schooling, January 29, 2025
Purpose: Order seeks to end federal “preferencing” through DEIA efforts within government and through contracting to the extent that they do not comply with the Administration’s view of civil rights law.

The order is broad and non-specific but includes the following directives:

Orders all executive departments and agencies “to terminate all discriminatory and illegal preferences, mandates, policies, programs, activities, guidance, regulations, enforcement actions, consent orders, and requirements.  I further order all agencies to enforce our longstanding civil-rights laws and to combat illegal private-sector DEI preferences, mandates, policies, programs, and activities.”

Orders agency heads to include in every contract or grant award “a term requiring the contractual counterparty or grant recipient to agree that its compliance in all respects with all applicable Federal anti-discrimination laws is material to the government’s payment decisions for purposes of section 3729(b)(4) of title 31, United States Code; and…A term requiring such counterparty or recipient to certify that it does not operate any programs promoting DEI that violate any applicable Federal anti-discrimination laws.”
Implications: Should the federal government proceed with conditioning federal funding for schools on whether or not they support transgender students, it could exacerbate existing mental health disparities, contribute to stigma and discrimination, and reduce school connectedness. For example, the policies detailed in the Order could prevent schools from recognizing transgender students’ identities (e.g. their names and pronouns), allow schools to withhold mental health services, to out students to (potentially unsupportive) families, and to restrict facility use and activity participation.
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 [Nongovernmental Organizations] NGOs that undermine the national interest.”

Direct 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 actions; as otherwise determined in the judgment of the heads of agencies; and on the basis of applicable authorizing statutes, regulations, and terms.”
Implications: This memo aligns with other administrative efforts to stop current and future funding from being provided to NGOs that do not align with administrative priorities and could impact funding to health organizations or programs aimed at serving transgender people or research funding inclusive of trans and gender diverse people. It could also potentially impact care for LGBTQ+ people more broadly if services aimed directly at this population are considered DEIA efforts.
DOJ Letter to the Supreme Court: United States v. Jonathan Skrmetti, Attorney, February 7, 2025
Purpose: “To notify the Court that the government’s previously stated views” on a case challenging a state’s ban on gender affirming care “no longer represents the United States’ position.”

Notifies the Court that “following the change in Administration, the Department of Justice has reconsidered the United States’ position in” the case brought by the Biden Administration challenging Tennessee’s ban on gender affirming care for minors. The letter states, that their view is that the Tennessee law being challenged “does not deny equal protection on account of sex or any other characteristic,” which is the question before the Court.

Despite this change in perspective, the Trump Administration encouraged the Court to resolve the questions presented without granting certiorari to the original plaintiffs.
Implications: There are 26 states with bans on gender affirming care for minors and litigation challenging these bans is ongoing. At the request of the Biden Administration, who brought the plaintiff’s case from the lower courts, the Supreme Court agreed to examine whether the Tennessee ban violates Equal Protection constitutional protections under the 14th Amendment. The case was briefed and argued prior to the administration change. Upon taking office, the Trump Administration wrote this letter to the Court stating that the Biden Administration position no longer represented that of the U.S. government but nevertheless asked the court to decide the case. The court will likely issue a decision in the case and technically, the Trump Administration letter should not have bearing on the court’s decision. The court is expected to issue a decision in the case this summer (2025).
Quality and Safety Special Alert Memo on Provision of Gender Affirming Care to Children, March 5, 2025
Purpose: To alert providers to the administration’s approach to children’s access to gender affirming care and serve as notice “that CMS may begin taking steps in the future to align policy, including CMS-regulated provider requirements and agreements…” to limit such care.

The memorandum states:

That “CMS renews its commitment to promoting evidence-based standards through health quality and safety improvement activities, and reminds hospitals and other applicable facilities and providers of the obligation to prioritize the health and safety of their patients, especially children.” It questions evidence around gender affirming care for young people and states “CMS may begin taking steps in the future to adjust its policies to reflect this…”
Implications:

The CMS memo aligns with policies put forward in the Executive Order, “Protecting Children From Chemical and Surgical Mutilation,” related to limiting young people’s access to gender affirming care, provisions of which are subject to a nationwide preliminary injunction (described in above entry). However, this is not explicitly stated in the memo.

On March 6th the Health Resources & Services Administration (HRSA) and Substance Abuse and Mental Health Services Administration (SAMHSA) released additional guidance stating that they would review policies, grants, and programs for consistency with the CMS memo (SAMHSA letter unavailable but described in this filing). HRSA also specifically notes the agency will review its Children’s Hospitals Graduate Medical Education (CHGME) Payment Program for consistency with the memo.

While the memo does not specifically refer to the Executive Order, on March 7th, plaintiffs in a case challenging the order sought enforcement of the preliminary injunction claiming that the CMS memo and HRSA/SAMHSA guidance violate its terms because by “threatening to withhold federal funding, the Executive Orders coerced hospitals into immediately shutting down gender affirming medical care for people under nineteen to avoid potential loss of funds.”

Depending on how future policy is implemented, CMS could seek to significantly limit access to gender affirming care for young people.
National Child Abuse Prevention Month, 2025 April 3, 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 [Nongovernmental Organizations] NGOs that undermine the national interest.”

Direct 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 actions; as otherwise determined in the judgment of the heads of agencies; and on the basis of applicable authorizing statutes, regulations, and terms.”
Implications: The proclamation includes details about gender affirming care and transgender people that conflict with science and evidence, including that children are being “indoctrinated” “with the devastating lie that they are trapped in the wrong body,” referring to gender affirming surgery (which is very rare among young people) as “sexual mutilation surgery,”  and suggesting that such care inhibits “happiness, health, and freedom,” for young people and creates “heartbreak” for parents and families.

By erroneously conflating gender affirming care and abuse, potentially threatens those providing or facilitating access by stating, “we affirm that every perpetrator who inflicts violence on our children will be punished to the fullest extent of the law.”
Ryan White Letter to Awardees and Stakeholders Relating to Gender Affirming Care, April 7, 2025.
Purpose: Reverses a Biden Administration policy that had permitted the Ryan White HIV/AIDS Program to cover certain gender affirming care services as a part of whole person care to transgender people with HIV.

Referring to a policy on gender affirming care from the Biden administration, the letter states that “under the previous administration, certain interpretations of RWHAP’s allowable uses…co-opted the program’s patient centered mission in favor of radical ideological agendas and policies.”

The letter further states “that RWHAP funds shall be marshaled exclusively toward evidence-based interventions proven to combat HIV, sustain viral suppression, and improve the quality of life for those living with the disease” and reaffirms the prohibition on funding services outside the scope of outpatient care, including “surgeries and inpatient care, irrespective of setting or anesthesia”
Implications:

Previously, Ryan White funds were permitted to be used to support gender affirming care within core medical and support service categories, including through the provision of hormones via ADAP programs. Additionally, funds could be used to “provide behavioral and mental health services to clients experiencing gender dysphoria and social and emotional stress related to transgender discrimination, stigma, and rejection.” The policy under the prior Administration prohibited surgery, as does the new one, so that does not represent a change.

Prohibiting use of funds to support certain gender affirming care services may make care engagement more challenging for transgender Ryan White clients. In some cases, gender affirming care may have helped to connect clients with HIV services and thus improve HIV outcomes.
Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance; Clarification, April 11, 2025.
Purpose: HHS issued this notice “to clarify the non-enforceability of certain language that was included in the preamble to—but not the regulatory text of” the final rule on Section 504, “titled ‘Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance.’ The clarification states that language in the preamble concerning gender dysphoria, which is not in the regulatory text, does not have the force or effect of law and cannot be enforced.Implications:

Section 504 prohibits recipients of federal funding, including publicly-subsidized health payers and health care providers who accept Medicare or Medicaid, from discriminating against people on the basis of disability. The Biden Administration’s final rule on Sec. 504 included in the preamble that HHS would “approach gender dysphoria as it would any other disorder or condition. If a disorder or condition affects one or more body systems, or is a mental or psychological disorder, it may be considered a physical or mental impairment.”

This new interpretation could weaken certain protections for transgender and gender non-conforming people.
State Medicaid Director Letter “Re: Puberty blockers, cross-sex hormones, and surgery related to gender dysphoria,”  April 11, 2025.
Purpose: “The purpose of this letter is to ensure that state Medicaid agencies are aware of growing evidence regarding certain procedures offered to children, and to remind states of their responsibility to ensure that Medicaid payments are consistent with quality of care and that covered services are provided in a manner consistent with the best interest of recipients.”

States that “medical interventions for gender dysphoria in children have proliferated” and that “several developed countries have recently diverged from the U.S. in the way they treat gender dysphoria in children.”

CMS reminds states of the following federal Medicaid requirements:

Program “responsibility to ensure that payments are consistent with ‘efficiency, economy, and quality of care.’”

• Requirement for states to “provide such safeguards as may be necessary to ensure covered care and services are provided in a manner consistent with the best interests of recipients.”

• Prohibition on “federal funding for coverage of services whose purpose is to permanently render an individual incapable of reproducing. Federal financial participation (FFP) is strictly limited for procedures, treatments, or operations for the purpose of rendering an individual permanently incapable of reproducing and…prohibited for such procedures performed on a person under age 21.”

• Drug utilization review (DUR) program requirements “to assure that prescribed drugs are appropriate, medically necessary, and are not likely to result in adverse results.”
CMS encourages “states to review their DUR programs to ensure alignment with current medical evidence and federal requirements, including the evidence outlined above.
Notes that “additional guidance on DUR approaches is forthcoming.”
Implications:

Letter appears to encourage states to take steps to limit gender affirming care for youth within their state Medicaid programs and suggests that not doing so could put them out of compliance with federal law. It does not immediately change policy.

Letter misrepresents certain information about gender affirming care including its frequency and the approach in international settings.

Letter leverages a law aimed at addressing discrimination/unwanted sterilizations among people with disabilities to limit gender affirming care.

The letter could lead to changes in state policy-making or make providers and/or employers less likely to cover services which could ultimately lead to more limited access to GAC. 

CMS issued a press release along with the letter. The letter stated “Medicaid dollars are not to be used for gender reassignment surgeries or hormone treatments in minors.”
Department of Justice Memorandum “Preventing the Mutilation of American Children,” April 22, 2025.
Purpose: An internal Department of Justice (DOJ) memorandum seeks to implement, in part, an executive order aimed at limiting minor’s access to gender affirming care (GAC) (see above).

The memo is an internal document that was leaked. It is not law but provides guidance relating to an earlier executive order aimed at limiting minor access to gender affirming care (see above). The memo reportedly:

The internal document was leaked and is not law but provides guidance relating to an earlier executive order aimed at limiting minor access to gender affirming care.

Puts providers “on notice” that “it is a felony to perform, attempt to perform, or conspire to perform female genital mutilation (“FGM”*) on” minors and states that the FBI “alongside federal, state, and local partners, will pursue every legitimate lead on possible FGM cases.”

States DOJ “will investigate and hold accountable medical providers and pharmaceutical companies that mislead the public about the long-term side effects of chemical and surgical mutilations.”

Directs “investigations of any violations of the Food, Drug, and Cosmetic Act by manufacturers and distributors engaged in misbranding by making false claims about the…use of puberty blockers, sex hormones, or any other drug” in GAC.

Directs “investigations under the False Claims Act of false claims submitted to federal health care programs for any non-covered services related to radical gender experimentation.” Gives example of prescribing puberty blockers to a minor for GAC but reporting the service as being for early onset puberty. States Department will work with whistleblowers “with knowledge of any such violations” under The False Claims Act.

Following prior direction “that Department employees shall not rely on”… the World Professional Association for Transgender Health (WPATH)… “guidelines, and that they should withdraw all court filings” doing so, “expressly extend[s] that direction to all Department employees.” Directs department to “purge all…policies, memoranda, and publications and court filings based on WPATH guidelines.”

Launches “the Attorney General’s Coalition Against Child Mutilation” to “partner with state attorneys general to identify leads, share intelligence, and build cases against…” providers “…violating federal or state laws banning female genital mutilation and other, related practices…[and] support the state-level prosecution of medical professionals who violate state laws “prohibiting gender affirming care.

Instructs Office of Legislative Affairs to draft legislation “creating a private right of action for children and the parents of children” who have had gender affirming care with “a long statute of limitations and retroactive liability” and work with Congress “to bring this bill to President Trump.”
     
Implications:

The memo directs action but is not law. It seeks to implement an executive order that is, in part, currently enjoined in court.

The memo includes inaccuracies relating to gender identity, gender affirming care, and transgender people that conflict with science and evidence. These inaccuracies include suggesting that being transgender is a harmful medical condition, that large shares of youth are seeking gender affirming medical care, that regret rates among those seeking care are high, and conflating “female genital mutilation” and gender-affirming care. This has the potential to promote hostility, stigma, and discrimination, and can lead to care denials.

Seeks to discredit WPATH’s widely relied on standard of care guidelines which providers look to deliver best practices gender affirming care and is regularly referenced by major medical associations including the American Psychological Association.

While nothing in the memo prohibits provision of gender affirming care, its emphasis on litigation and enforcement of existing law that do not necessarily implicate this care, could have a chilling effect on providers.
     
HHS Report “Treatment for Pediatric Gender Dysphoria: Review of Evidence and Best Practices,” May 1, 2025.
Purpose: To develop an evidence review around pediatric gender affirming medical care as commissioned by the executive order on Protecting Children From Chemical and Surgical Mutilation (see above entry).

“This Review of evidence and best practices was commissioned pursuant to Executive Order 14187, signed on January 28, 2025. It is not a clinical practice guideline, and it does not issue legislative or policy recommendations. Rather, it seeks to provide the most accurate and current information available regarding the evidence base for the treatment of gender dysphoria in this population, the state of the relevant medical field in the United States, and the ethical considerations associated with the treatments offered. The Review is intended for policymakers, clinicians, therapists, medical organizations and, importantly, patients and their families.” Among the report’s findings:

Report concludes that the quality of evidence on the effects of gender affirming intervention is low but also that evidence on harms is “sparse.”

Cites “significant risks” of medical transition, departing from most medical associations and widely used guidelines in the U.S.

In addition to a focus on medical intervention (e.g. surgery, puberty blockers, and hormones) report discusses role of psychotherapy in gender affirming care, supporting the use of psychotherapeutic approaches, including an approach termed “exploratory therapy”, which can include conversion therapy. Conversion therapy is a practice that seeks to change an individual’s sexual orientation or gender identity. These practices contrast with recommendations from major medical associations, which criticize conversion efforts for their lack evidence, ineffectiveness, and because they can cause harm. Additionally, many states ban these practices for the same reasons.
Implications:

Review could be used as support for other actions the administration seeks to take (some described here) aimed at limiting minor access to gender affirming care. Outside experts, including from the American Academy of Pediatrics, have raised concerns that the “report misrepresents the current medical consensus and fails to reflect the realities of pediatric care.”

With respect to therapeutic practices, it could shift how some practitioners approach gender affirming care or potentially provide support to those using conversion related approaches.

The report could also fuel misinformation in other areas, particularly around regret rates (which the report states are high when they are actually very low) and the share of young people seeking a medical transition (which the report states is large, when the share is small).

On May 28, 2025, HHS sent a letter to an unspecified group of providers, state medical boards, and health risk managers urging providers to update treatment protocol to align with the review’s findings and avoid relying on the WPATH Standards of Care (which are seen by gender affirming care providers as valuable and trusted source of guidance.) The letter points to risk but not benefits of gender affirming medical care and highlights the report’s promotion of psychotherapy as an alternative to other medical care.
HHS Letter “Urgent Review of Quality Standards and Gender Transition Procedures” May 28, 2025
Purpose: The letter from the Center for Medicare and Medicaid Services (CMS) is directed at “select hospitals” providing minors with gender affirming care services including puberty blockers, hormones, and surgeries. The aim of the letter is to collect information on the delivery of these services and their associated costs and revenue. CMS states they are collecting this data to “ensure quality standards at institutions participating in the Medicare and Medicaid programs” and because “CMS has an obligation to be a good steward of taxpayer dollar.” 

In the letter CMS asks for information on the following within 30 days:
• consent protocols for children with gender dysphoria, including when parental consent is required
• changes to clinical practice guidelines and protocols in light of the HHS Review (see above entry)
• adverse events, particularly children who later look to detransition
billing codes utilized for gender affirming care
• facility and provider-level revenue and profit margins data related to these services
Implications: If facilities or providers believe HHS is excessively engaged in oversight of their practice of this area of medicine, it could have a chilling effect on willingness to provide these treatments. Depending on what the Administration does with data collected, this effort could represent a significant step in the administration’s aim to limit GAC for minors.

The effort to collect this level of information is likely burdensome for providers, particularly within a 30-day period.

The letter appears to stoke misinformation in its suggestion that there is a lack of parental involvement or consent in the practice of gender affirming care and that regret is a serious problem in this field.

It also appears to question the validity of using federal dollars to provide this care and possibly that delivering these services to minors is a significant cost-burden to the federal government. Because just a small share of the population is transgender, and not all trans people seek medical intervention, costs are likely very low.
CMS Informational Bulletin “Rescission of Guidance on Adding Sexual Orientation and Gender Identity Questions to State Medicaid and CHIP Applications for Health Coverage”  June 5, 2025
Purpose: To rescind a bulletin from the Biden administration that provided state Medicaid programs with guidance on implementing optional sexual orientation and gender identity (SOGI) questions on their applications for coverage.

The Trump administration bulletin states that “CMS no longer intends to collect this information from state Medicaid and Children’s Health Insurance Program (CHIP) agencies as part of Transformed Medicaid Statistical Information System (T-MSIS) data submissions.”
Implications: Collection of SOGI health data plays a role in documenting the health experiences and status of LGBTQ+ people. Data collection can reveal disparities and gaps in access, which can, in turn, inform policy making to address these challenges. Without this data, addressing these disparities is more challenging. SOGI Data collection expanded under the Biden administration and has retracted under the Trump administration.
Final Rule Changing ACA Coverage of Gender-Affirming Care, June 25, 2025.
Purpose: The rule prohibits gender affirming care services from being covered as an Essential Health Benefit (EHB) in ACA plans.
CMS changes how ACA complaint individual and small group plans cover gender affirming care services, which the rule calls “coverage for sex-trait modification.”  Beginning plan year 2026, insurers are prohibited from covering gender affirming care as an essential health benefit (EHB).

Differing from the proposed rule, which offered no definition, HHS defines “sex-trait modification” services to mean “any pharmaceutical or surgical intervention that is provided for the purpose of attempting to align an individual’s physical appearance or body with an asserted identity that differs from the individual’s sex.”
If a state mandates coverage for gender affirming care, the state would be required to defray the cost.

The preamble to the rule clarifies that CMS finds that as non-EHB services, EHB non-discrimination in the ACA do not apply.
Implications: The aim of the final rule aligns with policies expressed in Executive Orders on gender and limiting access to gender affirming care (discussed above), though the agency states the rule does not rely on these orders or their enjoined sections. The agency writes that the purpose of the rule is to ensure that health plans meet the ACA’s “typicality requirement,” that is that EHBs be “equal to the scope of benefits provided under a typical employer plan.” The preamble to the rule discusses debate among commenters about whether inclusion of these services is typical.

The rule does not mean that plans cannot cover gender affirming care services but excluding certain services from coverage as EHBs means that enrollees would not be assured the same cost-sharing and benefit design protections as for services included in the EHB package. Costs accrued for gender affirming care would not be required to count towards deductibles or out-of-pocket maximums and would not be protected from annual or lifetime limits, increasing out-of-pocket liability. Additionally, the portion of premiums attributable to specified gender affirming services would not be eligible for premium tax credits or cost-sharing reductions for low- and moderate-income enrollees.

While CMS does not believe the impact will be significant, some commenters expressed concern that the policy change, particularly its near implementation date for 2026 plan year, could create challenges for issuers, which have already been engaged in (and some completed) rate setting for 2026. They also stated that change would require plans that cover gender affirming care outside of the EHB to complete the necessary backend activities (e.g. changes to claims and utilization management programs and policies) to implement the change, activities that could be more burdensome for smaller issuers.

While HHS states that this rule does not violate various statues (e.g. ACA’s nondiscrimination provisions at Sec. 1557 or typicality requirements, ADA’s Section 505 protections, constitutional equal protections, etc.) and disagrees with those who commented on the proposed rule that HHS lacks legal authority to make these policy changes, the rule could ultimately face legal challenges on these or other grounds.
Federal Trade Commission Request for Information on Gender Affirming Care Practices, July 28, 2025. 
Purpose: The Federal Trade Commission (FTC) issued a request for public comment on “how consumers may have been exposed to false or unsupported claims about ‘gender-affirming care’(GAC), especially as it relates to minors, and to gauge the harms consumers may be experiencing.”

Arguing that GAC has been subject to “potential deceptive or unfair practices involved in this type of medical care,” the agency “seeks to evaluate whether consumers (in particular, minors) have been harmed by GAC and whether medical professionals or others may have violated Sections 5 and 12 of the FTC Act by failing to disclose material risks associated with GAC or making false or unsubstantiated claims about the benefits or effectiveness of GAC.”

As discussed in the RFI, this action comes on the heels of a recent workshop the agency held on the same topic and the agency now seeks comment related to:

• Experiences of individuals and families seeking GAC, including on recommendations made by providers, whether providers described risks/benefits/effectiveness, and whether providers discussed the current policy environment and debates related to GAC, among other issues.

• Whether GAC was obtained and whether individuals experienced benefits/side effects/adverse events, among other issues.

• Detail related to whether providers “made false representations regarding the benefits or effectiveness.”

• Information related to providers making “false representations regarding the benefits or effectiveness” related to GAC
Implications: This activity is likely to have a chilling effect on provider willingness to offer GAC. In addition to the workshop and RFI described above, more than 20 providers have received subpoenas from the DOJ for investigations related to GAC that “include healthcare fraud, false statements, and more.”

The RFI (and surrounding actions) also have the potential to promote misinformation around the risks and benefits of GAC and suggests that providers are using deceptive and unethical positions in delivering GAC on a significant scale, something that has not been demonstrated. Additionally, the RFI states that there is “widespread concern about the harms” related to GAC but does not acknowledge the broad clinical support GAC has as medically necessary treatment for gender dysphoria, including from major U.S. medical associations.
Improving Oversight of Federal Grantmaking, August 5, 2025
Purpose: The Executive Order seeks reform “the process of Federal grantmaking while ending offensive waste of tax dollars.”

The EO aims to overhaul the federal grantmaking and grant review process “to strengthen oversight and coordination of, and to streamline, agency grantmaking to address these problems, prevent them from recurring, and ensure greater accountability for use of public funds more broadly.”  One section of the EO requires agencies to “ensure that…[grants] are consistent with agency priorities and the national interest.” In addition to other actions, agencies are directed to ensure that awards are not “used to fund, promote, encourage, subsidize, or facilitate” certain themes including, “denial by the grant recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic” and “racial preferences or other forms of racial discrimination by the grant recipient, including activities where race or intentional proxies for race will be used as a selection criterion for employment or program participation,” among others.
Implications: This approach to grantmaking could further chill research and grantmaking related to and aimed to supporting transgender and gender diverse people, including that related to health and healthcare. This could impact access to and availability of culturally competent services at the individual level and reduce research and data on transgender and gender diverse communities more broadly. Such research in turn could have been used to inform service delivery and policy making and to address health disparities.
CDC Priorities Statement, September 17, 2025.
Purpose: CDC updated its priorities statement on the agency’s “about” website to include discussion of gender affirming care, parental rights, and DEI (among a range of other topics) not previously included on the site.

With respect to gender affirming care, the agency refers to its “comprehensive review of the evidence and best practices for promoting the health of children and adolescents with gender dysphoria” (see above entry) and states it is  “a CDC priority to protect children from …” gender affirming care “and, to the extent allowable by applicable federal law and any relevant court orders, CDC programs will deprioritize programs that engage in these practices where permissible. CDC funds will also not support the costs of such practices where not required by the law or court order.” Further, CDC states it is an agency “priority to recognize that a person’s sex as either male or female is unchangeable and determined by objective biology, and to ensure CDC programs accurately reflect science, including the biological reality of sex.”

Another stated priority is that “CDC believes parents are the primary decision-makers in their children’s education and should have full authority over what their children are taught” and that school policies “and curricula should emphasize knowledge…without imposing ideas that may conflict with parents’ political, religious, or social beliefs.”
With respect to DEI the statement reads, “to the extent permitted by law, CDC will deprioritize diversity, equity, and inclusion (DEI) initiatives that prioritize group identity over individual merit” and that “CDC has previously invested substantially in ideologically-laden concepts like health equity—mainly on identifying and documenting worse health outcomes for minority populations.”
Implications: The new priorities statement represents are departure from the previous CDC “about” page which was much broader in its description and referenced the agency strategic plan stating that the plan “advances science and health equity and affirms the agency’s commitment to one unified vision— equitably protecting health, safety, and security.”

The new statement could potentially inform grant making and other agency activities such as reporting, recommendations/guidance, data collection, and data presentation. It may also impact CDC research ability to conduct research related to gender affirming care, transgender people, and health disparities. It also may limit the ability of grantees to use CDC resources to provide LGBTQ students with certain types of support or for the agency to provide resources to support LGBTQ youth. Targeting public health approaches to hard hit populations may be more difficult, including for conditions that disproportionately impact LGBTQ+ people, like HIV.

In its description of the HHS report findings on GAC, the CDC statement appears to go beyond what the review itself stated which was that the quality of evidence to support interventions was low and the evidence on harms was “sparse.” The CDC statement writes the review found that provision of gender affirming care to minors is “unsupported by the evidence and have an unfavorable risk/benefit profile.” Neither the report nor the CDC statement reference the well documented benefits associated with gender affirming care.
Proposed Rule Seeking to Amend CMS Hospital Condition of Participation to Prohibit Provision of Certain Gender Affirming Care Services for Young People, December 18, 2025.
Purpose: The proposed rule wouldchange the hospital Conditions of Participation (CoPs) to prohibit most Medicare and Medicaid enrolled hospitals from providing specified gender affirming medical care for youth.

The proposal would prohibit most hospitals (i.e. those covered by section 42 CFR part 482) that accept payments from the Medicare or Medicaid programs (the majority of hospitals in the U.S.) from providing pharmaceutical and surgical services related to gender affirming care to young people under age 18. Prohibited services would include puberty blockers (which delay the onset of puberty), hormone therapy, and surgery (which is very rare among young people). While these services would be prohibited for the purposes of providing gender affirming care, the rule would permit hospitals to provide them to youth when the service is not intended to affirm a person’s gender.

The proposal does not take immediate effect. There is a 60-day comment period from the date of publication in the federal register.
Implications: The aim of the proposed rule aligns with earlier actions (e.g. the Executive Order aimed at limiting access to gender affirming care, letters from HHS to providers/states, etc. (discussed above)).

The  rule applies to facility type (not payer) and therefore, if adopted, would prohibit hospitals from offering gender affirming services to all patients under 18 years old regardless of payer, including youth with private insurance or other coverage and those paying cash, not just those covered by Medicare and Medicaid.

If finalized, the proposed rule would further limit access to gender affirming care nationwide. To the extent that academic research hospitals discontinue provision of care, this could also have implications for research being conducted in these institutions.

See KFF’s overview of this proposed rule: https://www.kff.org/lgbtq/new-trump-administration-proposals-would-further-limit-gender-affirming-care-for-young-people-by-restricting-providers-and-reducing-coverage/
Proposed Rule Seeking to Prohibit Federal Medicaid/CHIP Funds from Covering Gender Affirming Care Services for Young People, December 18, 2025.
Purpose: The proposed rule would prohibit the use of federal Medicaid of CHIP funds from covering pharmaceutical and surgical gender affirming services for young people (under age 18 for those covered by Medicaid and under age 19 for those covered by CHIP). Prohibited services would include puberty blockers (which delay the onset of puberty), hormone therapy, and surgery (which is very rare among young people). Federal funds would be permitted to cover the same services when the service is not intended to affirm a person’s gender. Under the proposal, states would be permitted to use state-only funds to cover the prohibited services.


The proposal does not take immediate effect. There is a 60-day comment period from the date of publication in the federal register.
Implications: The aim of the proposed rule aligns with earlier actions (e.g. the Executive Order aimed at limiting access to gender affirming care, letters from HHS to providers/states, etc. (discussed above)).
The rule applies to federal Medicaid as a payer and therefore restrict reimbursement for care regardless of provider type (e.g. hospitals, primary care providers, endocrinologists, etc.). However, it does not prohibit providers from offering these services
If finalized, the proposed rule would further limit access to gender affirming care nationwide and impact families with lower incomes the hardest. While young people with Medicaid and CHIP coverage could theoretically seek care outside of hospitals without using their insurance, the cost of doing so would likely be prohibitive.
See KFF’s overview of this proposed rule: https://www.kff.org/lgbtq/new-trump-administration-proposals-would-further-limit-gender-affirming-care-for-young-people-by-restricting-providers-and-reducing-coverage/
Proposal to Amend Regulations Implementing Section 504 of the Rehabilitation Act of 1973, to exclude protections related to gender dysphoria, December 18, 2025.
Purpose: The proposed rule seeks to amend federal regulations implementing Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination on the basis of disability in federal and federally funded programs, as it applies to recipients of funding from the Department of Health and Human Services (HHS). It would revise a Biden Administration final rule which, in the preamble, stated that HHS would be willing to view gender dysphoria as covered by Sec. 504 “as it would any other disorder or condition. If a disorder or condition affects one or more body systems, or is a mental or psychological disorder, it may be considered a physical or mental impairment.” The proposed rule would do the opposite, and clarified that the current administration interprets statutory exclusions related to ‘‘gender identity disorders not resulting from physical impairments’’ to encompass ‘‘gender dysphoria not resulting from a physical impairment.’’


The proposal does not take immediate effect. There is a 30-day comment period from the date of publication in the federal register.
Implications: This new interpretation could weaken certain protections for transgender and gender non-conforming people.
(See related April 11, 2025 Notice above.)
Declaration of the Secretary of the Department of Health and Human Services, December 18, 2025.
Purpose: HHS Sec. Kennedy issued a declaration stating certain gender affirming care procedures are “neither safe nor effective as a treatment modality for gender dysphoria, gender incongruence, or other related disorders in minors, and therefore, fail to meet professional recognized standards of health care.” It further stated that “the Secretary ‘may’ exclude individuals or entities from participation in any Federal health care program if the Secretary determines the individual or entity has” delivered services that fail “to meet professionally recognized standards of health care.” However, HHS notes the “declaration does not constitute a determination that any individual or entity should be excluded from participation in any Federal health care program.”Implications: The declaration was issued on the same day that proposed rules aiming to restrict youth access to gender affirming care in the Medicaid program and by hospitals participating in Medicare and Medicaid were released. (See more on the proposed rules in a separate entry below).

The declaration seeks to discredit widely used U.S. standards of care for gender affirming care (i.e. WPATH and Endocrine Society guidelines) and recommendations by major medical associations, instead relying on HHS’s evidence review relating to gender affirming care for minors (see above entry).  It seeks to develop a Secretary-defined standard that would instead find that certain gender affirming services fail to meet professional recognized standards of care and therefore provide a basis for HHS to restrict federal funding to providers offering this care. This diverges from current recommendations which support access to this care and deem it a medical necessity.

While the declaration states that it does not determine that specific individuals or entities “should be excluded from participation in any Federal health care program” and that “any such determination…[would be]…subject to further administrative and judicial review,” it represents an additional effort aimed at restricting federal funding from reimbursing for gender affirming care for minors. As with other efforts, the declaration excepts the same services used in gender affirming care for other medical purposes.

Should the declaration be further implemented, it could increase the limitations on youth access to gender affirming care. The declaration is not limited to payer (as the Medicaid proposed rule is) or to a specific facility type (as the Conditions of Participation rule is). It could apply to any provider receiving federal funds. Even if the declaration is not implemented, it could stoke additional fear among providers who may choose to continue to or newly stop offering these services out of retaliatory fear.

On December 24, 2025, a lawsuit was filed in which 20 states challenged the administration’s authority to issue the declaration, claiming it violates the Administrative Procedures Act and the Medicare and Medicaid statutes and that “the Secretary has no legal authority to substantively alter the standards of care and effectively ban, by fiat, an entire category of healthcare.” 

HHS has since referred mulitple providers to the Office of Inspector General based on the declaration.
Assistant Sec. for HHS Public Health Message on “Evidence-Based Care for Children and Adolescents with Gender Dysphoria”, December 18, 2025.
Purpose: To “inform healthcare providers, families, and policymakers about evidence-based approaches to caring for children and adolescents experiencing gender dysphoria.”

It reviews findings from the HHS review of gender affirming care for youth (see above entry) and summarizes elements of other reviews before recommending that providers refuse to provide pharmaceutical and surgical gender affirming care for young patients, prioritizing instead psychosocial assessment and care. It also recommends providers share with families the administration’s view that there is “weak evidence for medical interventions” and “substantial documented harms” in medically treating gender dysphoria in young people.
Implications: The recommendations made are not binding but add to administrative efforts to reduce access to gender affirming care for young people. They ignore widely recognized benefits associated with gender affirming care access and recommendations of dominant US medical associations and guidelines.
FDA Warning Letters Related to the Sale and Manufacturing of Chest Binders, December 16-18, 2025.
Purpose: To issue warning letters to retailers and manufacturers of chest binders which include marketing language about their use to help alleviate gender dysphoria. The FDA letters, issued to 12 retailers and manufacturers,  state the binders are “misbranded” and that they are medical devices that must be registered with the FDA. In a press release HHS wrote “Breast binders are Class 1 medical devices used for purposes such as assistance in recovery from cancer-related mastectomy.” 

FDA states that these companies “should take prompt action to address any violations identified in this letter. Failure to adequately address this matter may result in regulatory action being initiated by the FDA without further notice.  These actions include, but are not limited to, seizure and injunction.” FDA states “if you believe that your products are not in violation of the FD&C Act, include your reasoning and any supporting information for our consideration as part of your response.”
Implications: The FDA efforts could create financial and logistical challenges for retailers and manufactures of chest binders used by transgender and nonbinary people. These challenges could result in access challenges for consumers, such as those relating to supply and cost.

Tracking Key HHS Public Health Policy Actions Under the Trump Administration

Published: Jan 5, 2026

Note: Originally published on Nov. 12, 2025, this resource is updated as needed, most recently on January 6, 2025, to reflect additional developments. 

Since assuming office for a second term, President Trump and officials in his administration have instituted numerous policy actions through the Department of Health and Human Services (HHS) affecting public health in the U.S. This resource lists and briefly describes key actions in the order in which they were first issued, reported or announced, with subsequent linked actions and related outcomes also included with each entry. As new policy changes occur, they will be added. 

This resource is not meant to be exhaustive of all administration actions related to public health, as many other federal policy changes – including outside of HHS – have public health implications but are not captured here.

Additional KFF resources on administrative actions related to global health, LGBTQ+ health, and mental health and substance abuse are also available.

Date

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Action/Description

January 20, 2025Presidential Executive Orders precipitate removal of some HHS websites and health data.
– In the first days of his second term President Trump issued a number of Executive Orders (EOs), including EOs that revoked many Biden administration orders and programs, and instituted new federal guidance related to “gender ideology,” “diversity, equity, and inclusion (DEI),” and “merit-based opportunities.” These EOs have implications for public health, particularly related to the collection and presentation of data and websites by the federal government. For example, in response to the EOs, HHS began to remove thousands of websites and numerous federal databases with public health information deemed to be related to DEI, LGBTQ, reproductive health, HIV/AIDS research, health disparities, and more, and limited some data collection and analysis in these areas. A lawsuit was filed to reverse these removals, and some information has been restored over time. In September, the administration agreed to restore all previously removed health-focused websites and data to versions that had existed on January 29, 2025.
February 7, 2025NIH announces change to indirect cost rate guidance.
– As part of grants for health research, the National Institutes of Health (NIH) provides “indirect cost” funding to grant recipients, which supports administration and facilities costs at grantee institutions. On February 7, NIH announced it would apply a new 15% “standard indirect cost rate” on all grants, which would apply to any new grants and to existing grants for expenses as of February 10, 2025. This was challenged in federal court and federal judges placed holds on the policy, first through a temporary restraining order affecting 22 states on February 10, a nationwide preliminary injunction on March 5, and a permanent injunction on April 4; prior rates still apply for the time being. The administration appealed the ruling and legal proceedings continue. If implemented, a 15% indirect cost rate would be a much lower rate compared to historical NIH rates and would amount to a significant cut in funding for institutions performing NIH-sponsored health research.
February 13, 2025Robert F. Kennedy, Jr. confirmed as HHS Secretary under President Trump.
– The Senate voted 52-48, along party lines, to confirm Robert F. Kennedy, Jr. as the Secretary of Health and Human Services.
February 13, 2025President Trump issues Executive Order (EO) establishing MAHA policy agenda and MAHA Commission.
– The EO outlines the purpose and objectives of the Trump administration’s Make American Healthy Again (MAHA) efforts. Stating that the U.S. must “re-direct our national focus…toward understanding and drastically lowering chronic disease rates and ending childhood chronic disease,” it directs federal agencies to “aggressively combat” mental health disorders, obesity, diabetes, and other conditions. It also establishes the MAHA Commission to advise the President, naming Secretary Kennedy as Chair. The EO directs the Commission to submit an assessment on how to combat the “childhood chronic disease crisis” within 100 days, and a strategy to address the crisis within 180 days, setting in motion processes to develop further public health strategies and plans (discussed in other entries below). 
February 14, 2025White House, DOGE initiate “reduction in force (RIF)”, including for HHS personnel.
– The EO outlines the purpose and objectives of the Trump administration’s Make American Healthy Again (MAHA) efforts. Stating that the U.S. must “re-direct our national focus…toward understanding and drastically lowering chronic disease rates and ending childhood chronic disease,” it directs federal agencies to “aggressively combat” mental health disorders, obesity, diabetes, and other conditions. It also establishes the MAHA Commission to advise the President, naming Secretary Kennedy as Chair. The EO directs the Commission to submit an assessment on how to combat the “childhood chronic disease crisis” within 100 days, and a strategy to address the crisis within 180 days, setting in motion processes to develop further public health strategies and plans (discussed in other entries below). 
February 14, 2025President Trump issues Executive Order prohibiting federal funding to schools and universities with COVID-19 vaccine requirements.
– The EO requires HHS to work with the Department of Education to prohibit COVID-19 mandates in schools, by issuing guidelines for compliance and barring federal funds from going to any educational agency, K-12 school, or institution of higher education that requires COVID-19 vaccination to attend in-person education programs (educational vaccine mandates are set at the state level). Educational vaccine requirements are set at the state and local levels. At the time the EO was released in February, no state required K-12 students to be vaccinated against COVID-19 while 15 colleges required Covid vaccines for students. However, by March 14, 2025 all of those colleges had ended their COVID-19 vaccine requirements for students.
February 18, 2025Secretary Kennedy announces public health policy priorities during HHS welcome ceremony.
– In his first remarks to HHS staff, Secretary Kennedy announces the public health priorities for his tenure. This include investigating the childhood vaccine schedule, tackling corruption and promoting transparency, and addressing a “chronic disease epidemic” especially in children, which he says may be linked to pesticides, food additives, antidepressants, microplastics, cellphone emissions, and other factors.
February 28, 2025Secretary Kennedy issues new rule ending public comment requirement for HHS grants and contracts.
– The new rule rescinds a prior HHS policy on “Public Participation in Rule Making” (the “Richardson Waiver,” dating back to 1971) and “re-aligns the Department’s rule-making procedures with the Administrative Procedure Act.”  As a result, “matters relating to agency management or personnel or to public property, loans, grants, benefits, or contracts” are exempt from the notice and comment procedures. This removes what had been a key step in the rulemaking process requiring public notification and a comment period. For example, changes to HHS policies related to work requirements for Medicaid and NIH funding would no longer require public comments under the new rule. This could streamline implementation of HHS policy, but also reduce public visibility on changes before they take effect.  Some lawmakers and public health focused groups have asked HHS to return to the prior requirements under the Richardson Waiver. 
March 7, 2025HHS announces that CDC will conduct a study of factors contributing to the rise in autism in the U.S.
– In statements to the press, HHS officials indicate CDC will initiate a study looking at the factors that are contributing to the rise in autism diagnoses in the U.S.. To date, no new CDC study results on this topic have been released though in a related development, in September 2025 President Trump and HHS leadership announced at a press conference and through a White House Fact Sheet that they believe there is a link between acetaminophen (e.g., Tylenol) use in pregnancy to autism (further details provided below). President Trump and Secretary Kennedy both have a history of linking vaccines and autism, even though there is no evidence of such a link.
March 13, 2025Food and Drug Administration (FDA) releases guidance on 2025-2026 influenza vaccine composition.
– The FDA guidance identifies which influenza virus strains manufacturers should use as components of 2025-2026 influenza vaccines. To develop these recommendations, FDA convened meetings of federal scientific and public health experts, including from FDA, CDC, and Department of Defense, but did not consult with the FDA’s Vaccines and Related Biological Products Advisory Committee (VRBPAC) or other professional groups outside the government. FDA had canceled the scheduled VRBPAC meeting on this topic, and the lack of input from outside experts was a break from past years’ practices. In addition, in past years there was active participation and coordination between U.S. federal experts and global technical experts working under the auspices of the World Health Organization (WHO), but official communications with WHO-linked experts has been curtailed since the Trump administration announced in January 2025 that the U.S. was withdrawing its membership from the UN agency.
March 17, 2025NIH initiates termination of numerous grants for HIV prevention and treatment programs.
– The canceled NIH grants include support for researchers investigating use of PrEP, medication used pre-exposure to prevent HIV infections, and programs focused on HIV/AIDS in adolescents and young adults. Even as the first Trump administration supported HIV/AIDS prevention and treatment efforts, including through a highly visible federal effort to “end the HIV epidemic” in the U.S. by 2030, these same programs have now been targeted for cuts (further details below).   
March 17, 2025HHS removes Surgeon General warning declaring gun violence a public health crisis.
– The HHS website was changed, removing a 2024 advisory from the Surgeon General on the public health impacts of gun violence. In addition to removing the Surgeon General’s warning, the administration has rolled back a number of gun safety policies in place during the Biden administration. The White House Office of Gun Violence Prevention, established during the Biden administration was shut down in early 2025. Further, significant numbers of staff at CDC’s Injury Center, which collects data on violent deaths and injuries, and CDC’s Division of Violence Prevention have been let go as part of the Trump administration’s reduction in force efforts.
March 25, 2025HHS and CDC seek to pull back $11 billion in supplemental COVID-19 and public health funding from state and local health departments.
– In a statement, HHS says it intends to pull back $11.4 billion in supplemental funding that had been provided by Congress for state and local public health departments through CDC for pandemic response activities. Following the announcement, on April 1, a group of 23 mostly Democratic-led states sued the Trump administration over the attempt to pull back this funding.  On April 3, a federal judge placed a temporary block on the administration’s actions, and on May 16, another federal judge indefinitely blocked the administration from enacting its funding pull back for the states that are part of the lawsuit. As of late August 2025, almost 80% of the funds initially targeted for cuts by the Trump administration had been restored for the 23 states that won in court. However, funding has not been restored to the remaining states, the majority of which are Republican-led.
March 27, 2025HHS announces a major re-organization and job cuts plan.
– HHS announces plans for a major restructuring of the department, in accordance with President Trump’s February 26 EO on “Implementing the President’s ‘Department of Government Efficiency’ Workforce Optimization Initiative.” The announcement says HHS will create an Administration for a Healthy America (AHA), which would combine several existing HHS offices including the Office of the Assistant Secretary of Health (OASH, which contains the Surgeon General’s Office), the Health Research and Services Administration (HRSA), the Substance Abuse and Mental Health Services Administration (SAMSHA), the Agency for Toxic Substance and Disease Registry (ATSDR), and the National Institute for Occupational Safety and Health (NIOSH). In addition, the Administration for Strategic Preparedness and Response (ASPR) at HHS would be moved under CDC. The announcement also says HHS will reduce its workforce by eliminating 10,000 full-time positions. Combined with other reduction in force efforts, a total of 20,000 HHS workers are expected to lose their jobs.

On May 5, a coalition of 19 Democratic-led states and the District of Columbia filed a lawsuit against the mass firing of federal health workers and re-organization of HHS. On May 10, a court ordered a temporary pause on sweeping federal firings at HHS and other agencies. On July 1, a federal judge blocked mass firings at HHS, saying they are likely unlawful. However, on July 8 the Supreme Court overturned the lower court decisions, allowing the Trump administration to proceed with job cuts. As of August it is estimated that over 20,000 jobs at HHS have already been cut, meaning the administration already met its initial workforce reduction goal.

Regarding re-organization, some organizational changes have been implemented at HHS, with major cuts or closures to public health related offices such as the HHS Office of Infectious Diseases & HIV Policy, the HHS Office of Minority Health, and HRSA’s Bureau of Primary Health Care.  However, other proposals such as the formation of an Administration for a Healthy America (AHA), have not yet been implemented. Implementing AHA to the extent proposed is likely to require approval from Congress, though so far Congress has not acted on legislation codifying these proposals.
March 31, 2025HHS withholds portion of Title X family planning service grants. 
– HHS notifies one in five current grantees of the federal Title X family planning program that a portion of their funding would be temporarily withheld. This funding freeze affects all nine Planned Parenthood grantees, in addition to 7 other nonprofit grantees, and it is estimated that a total of 879 clinics (24% of all Title X clinics) in 23 states are affected. After several months, funds were reinstated to some organizations, but the Planned Parenthood grantees have still not had their funding reinstated.
April 1, 2025HHS ends federal support for the “Safe to Sleep” program, which focuses on prevention of infant deaths during sleep.
– The Trump Administration ends federal participation in Safe to Sleep, a national campaign that focused on educating parents of newborns about safer sleeping practices for infants that can prevent death. The program, supported through the NIH’s National Institute of Child Health and Human Development (NICHD) Office of Communications in recent years, had been in existence for over 30 years and had contributed to a major decline in sudden infant deaths. The NICHD office was eliminated on April 1, along with federal support for “Safe to Sleep.”
April 2, 2025HHS requires CDC to reduce contract spending by $2.9 billion as part of DOGE cost reduction efforts.
– According to reports, HHS orders CDC to reduce its contract spending by $2.9 billion by April 18.CDC contract funding has been used to support several services at the agency including security, cleaning, and computers/technology. The sudden requirement to cut this spending by approximately 35% affects CDC operations. 
April 7, 2025HHS Secretary Kennedy announces changes to fluoride policies.
– Secretary Kennedy announces a plan to implement a number of changes to federal policy related to water fluoridation, including stating that CDC will stop recommending water fluoridation as a public health intervention (though to date, HHS and CDC still recommend community water fluoridation). In addition, Kennedy says the defunct Community Preventive Services Task will be revived and reconvened, with a goal of studying and making recommendations about water fluoridation. Kennedy also called on states to ban fluoride in their drinking water. Already this year Utah and Florida have banned community water fluoridation, the first states ever to do so.
April 17, 2025FDA informs Pfizer/Moderna that mRNA COVID vaccines will require an expanded warning label about myocarditis.
– In letters sent April 17, the FDA informs Pfizer and Moderna they must alter the warning labels for their COVID-19 mRNA vaccines to include expanded risks for myocarditis and pericarditis. Previously, the warning labels for these vaccines noted risks for these conditions for those aged 18 to 24 years (Moderna) and 12 to 17 years (Pfizer). However, updated labels are required to include new language saying “the observed risk of myocarditis and pericarditis following vaccination with mRNA COVID-19 vaccines has been highest in males 12 through 24 years of age” and that “persistence of abnormal cardiac magnetic resonance imaging (CMR) findings that are a marker for myocardial injury was common.”  According to FDA, the labels must also include more information about these conditions and their health risks.  Since the letters were sent, the companies have complied with the new FDA requirements. FDA approved the updated label language on June 25.
April 22, 2025FDA and HHS announce measures to phase out use of petroleum-based food dyes.
– FDA and HHS announce a series of steps the federal government will take to remove petroleum-based synthetic dyes from the U.S. food supply. These actions include initiating a process to revoke federal authorization for two such dyes and planning phase-outs by the food industry for others. In addition, the government will support research on food additives and children’s health and authorize natural alternative coloring options. Under the current plan, the phase-outs will occur through voluntary action taken by food companies.
May 1, 2025HHS announces a $500 million investment in a “next generation universal vaccine platform.”
– HHS and NIH announce that $500 million in funding will be directed to a new effort  to develop a “universal vaccine platform for pandemic-prone viruses.” The platform uses inactivated whole viruses, and is part of a broader federal effort to develop universal vaccines called “Generation Gold Standard.” The funds for this new investment appear to be re-purposed vaccine development funds from the Biden Administration’s NextGen initiative to develop next generation COVID-19 vaccines.
May 2, 2025White House Releases FY 2026 President’s Budget Request calling for major fundings cuts at HHS.
– The White House released an outline of the administration’s budget request for FY2026 and on May 30, the White House submitted the full Budget Request for FY2026 to Congress. The request proposes steep cuts to the HHS budget, including cuts for CDC, HRSA, SAMHSA, NIH, eliminating the Hospital Preparedness Program at ASPR, and reducing funding and cutting some programs focused on HIV/AIDS research and response. The budget request also asks Congress for $500 million to support a new “Administration for a Healthy America (AHA)” and MAHA-related priorities. The President’s Budget Request is only a proposal, as it is Congress that ultimately decides how much money the federal government appropriates. So far, Congressional spending bills for FY2026 have not included cuts to HHS of the magnitude requested by the President, and Congress has not provided the requested $500 million for AHA though budget negotiations continue.   
May 5, 2025White House Executive Order restricts funding and increases oversight for “gain of function” research at HHS.
– In an EO titled “Improving the Safety and Security of Biological Research” the White House cites concerns with federally funded “gain-of-function” (GOF) research on biological agents and states the Biden administration allowed dangerous GOF research to occur without sufficient oversight. The EO directs the Secretary of HHS to coordinate with other relevant Executive branch offices to establish guidance to end federal funding of “foreign entities” where GOF is being undertaken or in countries lacking oversight of GOF research. The EO requires the relevant Executive offices to submit updated policies and guidance for all federally supported GOF-related research, and to develop a strategy for managing risks of non- federally funded GOF research. The full implications of the EO are not yet clear, as the Executive branch offices must develop and implement specific guidance and regulations. According to outside experts, potential benefits of the EO include more transparency and stricter enforcement of dangerous research, while potential risks include hindering beneficial research that is not GOF and researchers choosing to curtail beneficial research to avoid potential repercussions under evolving federal restrictions.
May 20, 2025FDA leaders announce clinical trials will be needed for approval of certain new COVID vaccine formulations.
– In a medical journal article, FDA leaders indicate that going forward, for federal approval of new or updated COVID-19 vaccines (“boosters”) for use in individuals who are not considered at higher risk (defined as persons 65 or older or those with certain health conditions), will require vaccine makers to present evidence from randomized, placebo-controlled trials that demonstrate safety and efficacy. The announced policy is a departure from prior years when FDA did not require new trial data to authorize or approve boosters, but instead allowed approvals based on immune response evidence. The new policy could hinder investments by pharmaceutical companies in developing new COVID vaccine formulations, given the greater expense and time required to conduct new, full clinical trials.
May 22, 2025MAHA Commission Report on childhood chronic disease published.
– The first official report from the MAHA Commission (established by the February 13 EO discussed above) discusses factors contributing to a “chronic disease crisis” for U.S. children and provides a “call to action”. The report highlights four main drivers of the crisis: poor diet (primarily due to consumption of ultra-processed foods), exposure to chemicals, lack of physical activity and chronic stress, and “overmedicalization (excessive use of prescription drugs, such as antidepressants). The report calls for federal agencies to “close critical research gaps and guide efforts to better combat” these issues. It also says the MAHA Commission will develop and release a strategy in August (discussed below). The report expanded on the ideas initially outlined in the February EO and provided more details on Secretary Kennedy’s priorities to address chronic disease in children. There was some criticism of the report after its publication, with experts questioning some of the evidence and conclusions and pointing out significant errors and studies cited that did not exist, which indicated that artificial intelligence was likely used to help write the report. 
May 23, 2025Administration ends NIH funding for several HIV vaccine research projects. 
– NIH notifies two grant recipients working on broadly neutralizing antibody research for HIV vaccines of the cancelation of their funding.  The canceled grants supported early-stage vaccine development research that uses a different approach than other HIV vaccine candidates. Some other HIV vaccine candidates remain in the development pipeline and clinical trials continue, but the absence of this early-stage research could jeopardize the development of additional candidates going forward.
May 27, 2025HHS Secretary Kennedy announces CDC will no longer recommend COVID vaccines for healthy pregnant women and children.
– In a video post on X, Secretary Kennedy announces “the COVID vaccine for healthy children and healthy pregnant women has been removed from the CDC recommended immunization schedule.” The announcement was a departure from the typical process for changing vaccine recommendations, which includes review and input from the Advisory Committee on Immunization Practices (ACIP) and a notification from the CDC Director. Initially, the implications of changing CDC guidance without ACIP input were unclear given that no-cost insurance coverage for vaccination is linked to ACIP and CDC recommendations. On May 30, CDC changed the language on its website for COVID-19 vaccines, removing its prior recommendation for pregnant women to be routinely vaccinated and stating that healthy children 6 months to 17 years old could be vaccinated in consultation with health care providers/parents – a recommendation known as “shared decision-making,” which would mean insurance would still have to cover such vaccinations. On July 7, a coalition of professional medical organizations filed a lawsuit against HHS over the new COVID-19 vaccine recommendations, saying the department did not follow federal procedures in making the change and also mislead the public on the issue (on January 6, 2026, a federal court confirmed these plaintiffs have standing to challenge HHS’s actions on the COVID-19 vaccine recommendations, allowing the case to proceed to arguments). On August 19, independent expert groups, including the AAP, issued their own recommendations for COVID vaccines in infants and young children in contrast with CDC’s new recommendations.  On Aug 22, ACOG issued their own recommendations for pregnant patients.
June 9, 2025HHS Secretary Kennedy announces removal of all sitting members of ACIP.  
– In a post on X and a subsequent HHS press notice, Secretary Kennedy announces that all 17 sitting members of the CDC’s Advisory Committee on Immunization Practices (ACIP) are dismissed, to be replaced with new members selected by the Secretary. Kennedy says the move is “prioritizing the restoration of public trust above any specific pro- or anti-vaccine agenda.” The HHS Secretary does have the discretion to remove and nominate ACIP members, though no previous Secretary has dismissed all ACIP members at once. In a subsequent X post on June 11, Kennedy announces the nomination of eight new members to ACIP, several of whom have been critical of COVID-19 vaccines and have expressed concerns about harms caused by vaccinations more generally. In a later press release from September 15, HHS announces five more members to be appointed to ACIP, including several with a history of criticism of COVID-19 vaccine policies. 
June 17, 2025FDA announces National Priority Vouchers for expedited regulatory review of new drugs that support “U.S. national interest.
– FDA announces a Commissioner’s National Priority Voucher (CNPV) program, which can be “redeemed by drug developers to participate in a novel priority program” that shortens regulatory review time from 10-12 months to 1-2 months. FDA says it will determine the availability of vouchers for companies that are aligned with the “national health priorities” of: addressing a health crisis in the U.S.; delivering more innovative cures for the American people; addressing unmet public health needs; and, increasing domestic drug manufacturing as a national security issue. On October 16, FDA announced the first nine CNPV recipients, and on November 6, announced six more recipients.  The impact of this new priority voucher program on speeding drug approvals and onshoring drug manufacturing capacity is as yet unclear. In addition, there are several other existing priority review processes at FDA so adding another could strain FDA staff capacity at the same time there has been significant reductions in FDA’s staff and budget.  These strains have already slowed FDA review times in general.
June 18, 2025FDA approves lenacapavir – a new HIV prevention drug.
– FDA approves Gilead Sciences’ lenacapavir, a new injectable PrEP drug that has been shown to be highly effective at preventing HIV infection, and which requires just one dose every 6 months, making it the first ever twice-a-year drug option for HIV prevention. In September, CDC issued clinical guidance for use of injectable lenacapavir as PrEP, though that guidance did not include reference to transgender people, a group intentionally included in the clinical trials and at increased risk of HIV. FDA’s approval also precipitated a review by the World Health Organization (WHO) and on October 6, WHO pre-qualified lenacapavir for prevention of HIV. WHO pre-qualification can speed regulatory approval for the drug in many low- and middle-income countries with a high burden of HIV/AIDS and can also allow for global health mechanisms like the Global Fund to Fight AIDS, Tuberculosis and Malaria to procure the drug.
June 25-26, 2025The newly reconstituted ACIP makes recommendations and policy changes related to RSV and influenza vaccines, and designates new workgroups on hepatitis B, MMRV, and the childhood immunization schedule.
– ACIP votes to recommend respiratory syncytial virus (RSV) injections for babies and RSV vaccine for people 50 and older, and a ban on the use of thimerosal in multi-dose influenza vaccine vials. ACIP also agrees to stand up three new workgroups that will review the U.S. childhood vaccination schedule, hepatitis B guidance, and combination MMRV vaccine.  Subsequently, on July 3, CDC issued new RSV guidance that mirrored ACIP recommendations. On July 23, Secretary Kennedy enacted ACIP’s recommendation on thimerosal, rescinding federal recommendations for any influenza vaccines containing thimerosal (a change that only affects a very small percentage of the overall influenza vaccine market that is comprised of multidose vials).
July 1, 2025HHS alters program requirements and withholds funding from sex education and teen pregnancy prevention programs.
– HHS notifies all Teen Pregnancy Prevention (TPP) program grantees and Personal Responsibility Education Program (PREP) grantees in 46 states and territories that their material must align with President Trump’s executive orders, including those that ban the promotion of gender inclusivity, risk losing federal funding. TPP is a national grant program that funds grantees to replicate, develop, test, and evaluate evidence-based approaches to prevent teen pregnancy, while PREP awards grants to state agencies to use evidence-based models in educating adolescents on both abstinence and contraception. In August, the Trump administration cancelled a $12.3 million PREP grant to California after state officials refused to revise curricula in compliance with the EOs. In September 2025, 16 states and D.C. sued HHS alleging that the new PREP grant conditions are unlawful, unconstitutional, and harmful to gender diverse youth. Similarly, a federal judge blocked the HHS policy changes for TPP in October 2025.
July 2, 2025CDC deactivates its emergency response for H5N1 influenza (bird flu) and limits tracking and reporting of data on bird flu infections in humans and animals.
– CDC ends its emergency response for H5N1 bird flu in the U.S., which had been active since April 4, 2024. CDC reports the change is due to a decline in animal infections and no reports of human cases since February 2025. CDC also says data on the number of people tested for H5N1 will be reported only monthly, and no further data on infection rates in animals will be reported on the CDC website. Even so, reporting from states showed the number of H5N1 cases in birds, which had declined over the summer, began to increase again in fall 2025. However, much of the federal research and response efforts for H5N1 have been closed down or significantly limited following funding and staff cuts and a prolonged government shutdown. The limited federal tracking and reporting of H5N1 infections can slow identification of outbreaks and potentially slow response times.
July 9, 2025HHS Secretary Kennedy cancels a scheduled meeting of the U.S. Preventive Services Task Force (USPSTF).
– Secretary Kennedy cancels a meeting of the USPSTF several days before it was scheduled to take place, with no reason given and no re-scheduled meeting date provided. Typically, the task force meets three times a year, though no meeting has yet occurred under Secretary Kennedy. USPSTF is responsible for reviewing and recommending preventive health services. USPSTF recommendations have implications for what services insurers must cover with no cost-sharing, under the Affordable Care Act (ACA). Such services can include screening tests, behavioral counseling, and medications that can prevent diseases and illness (other than vaccines, which are tied to ACIP recommendations). However, along with other parts of the ACA, USPSTF has faced court challenges. On June 27 (prior to Kennedy’s cancelation of the meeting), while the Supreme Court ruled the ACA requirement that insurers cover USPSTF-recommended services is indeed constitutional, it also found that the HHS Secretary has the power to add and remove USPSTF members at will, which underscores the possibility that Secretary Kennedy may choose to dismiss some or all of the existing USPSTF members and appoint new members (as Kennedy has done with ACIP), or simply not name any new members, and has the power to choose not to adopt USPSTF recommendations. In light of Kennedy’s cancellation and the Supreme Court ruling, 104 public health focused organizations called on Congress to “protect the integrity of the USPSTF” through legislative action. The subsequent USPSTF meeting was scheduled to occur in November but that was also canceled, with HHS citing the government shutdown as the reason. 
July 31, 2025FDA announces new safety label requirement for opioid pain medications.
– The FDA says will require safety labels on opioid medications so that users can better understand that risks of long-term opioid use. The updated labels should include a summary on the risk of addiction, misuse, and overdose, treatment guidance and the risk of higher doses, how to safely discontinue opioid use, drug interactions, digestive complications, and overdose reversal medications. Drug companies received notification letters and have 30 days to submit updated labels for review.
July 31, 2025HHS Secretary Kennedy swears in Susan Monarez as CDC Director.
– In a statement welcoming the newly Senate-confirmed CDC Director, Secretary Kennedy says Monarez has “unimpeachable scientific credentials” and he has “full confidence in her ability to restore the CDC’s role as the most trusted authority in public health.” However, 28 days later (on August 27) the White House removed Monarez from her position at CDC. According to Kennedy, she was removed because he lost trust in her ability to serve as CDC Director and to implement the policies of the Trump Administration. According to Monarez, she was removed because she would not provide “blanket approval” for vaccine policy changes in advance and would not fire, as requested by Kennedy, CDC employees without cause. On August 28, Secretary Kennedy announced in a letter to CDC staff that Deputy Health and Human Services Secretary Jim O’Neill would serve as acting CDC Director.
August 1, 2025Newly announced CDC policy prevents outside professional medical and public health organizations from participating in working group meetings of ACIP.
– Officials at HHS notify professional medical organizations such as the American Academy of Pediatrics (AAP), the American Medical Association (AMA), the American College of Obstetricians and Gynecologists (ACOG), and others that they will be excluded from joining ACIP working group discussions going forward. Professional groups representing medical doctors and other stakeholders in vaccine policies have long participated as non-voting members, including in ACIP working groups. Working groups are typically responsible for helping review available data about topics prior to ACIP meetings, and helping develop recommendation language for ACIP to vote on, as well as other activities in support of ACIP. While the outside groups can be present and can participate in full ACIP meetings, the new policy removes them from providing any input through working groups.
August 5, 2025HHS announces a “coordinated wind down” of $500 million in federal funding for mRNA vaccine research
– HHS announces that it will cancel and begin to wind down mRNA vaccine development activities funded through the Biomedical Advanced Research and Development Authority (BARDA). In total, HHS reports it is canceling 22 projects worth nearly $500 million because “these vaccines fail to protect effectively against upper respiratory infections like COVID and flu…Going forward, BARDA will focus on platforms with stronger safety records and transparent clinical and manufacturing data practices.”  mRNA COVID-19 vaccines are effective in preventing severe illness and death from the disease, and mRNA vaccine technology has potential applications for other infectious diseases, as well as chronic diseases like cancer. The cancellation removes the bulk of U.S. federal funding for mRNA research, leaving questions about future progress by the U.S. in this area of vaccine technology.
August 15, 2025HHS reinstates the defunct Task Force on Safer Childhood Vaccines.
– The original Task Force on Safer Childhood Vaccines, a federal panel created by Congress in 1986 “to improve the safety, quality, and oversight of vaccines” was disbanded in 1998, but HHS announces that the group will be re-instated at NIH with participation from officials at FDA, CDC, and other government agencies. The goal of the reconstituted Task Force will be “the development, promotion, and refinement of childhood vaccines that result in fewer and less serious adverse reactions than those vaccines currently on the market, and improvements in vaccine development, production, distribution, and adverse reaction reporting” to help increase federal oversight and investigation of vaccine injuries.  The Task Force will come together to develop recommendations to be submitted to Congress within two years, with updates every two years after. Reinstatement of this panel has been a goal of anti-vaccine advocates for years, including the Children’s Health Defense, the anti-vaccine organization Secretary Kennedy founded, which supported a lawsuit earlier in 2025 against Kennedy that sought to require him to reconvene the Task Force.
August 27, 2025FDA approves COVID-19 vaccines for 2025-2026, while limiting scope of approval to certain ages and risk profiles.
– FDA approves updated COVID-19 vaccines for 2025-2026, but also limited the approval to persons 65 and older and those between 18 and 64 with a health condition that puts them at higher risk for severe disease. Previously, the FDA had approved the use of vaccines for all ages (over 6 months) regardless of risk profile.
September 9, 2025MAHA Commission releases strategy to address childhood chronic disease.
– A new MAHA Commission strategy document outlines actions the federal government is taking or plans to take to address childhood chronic disease in the U.S. These include “more than 120 initiatives” that together represent “the most ambitious national effort ever to confront childhood chronic disease,” and which outline a “blueprint for the entire government” to address chronic disease. Elements of the strategy include: changing federal science and research priorities, reforming dietary guidelines, changing nutrition and food regulations through reducing additives and ultra-processed foods, and improving effort to raise public awareness about chronic disease. The strategy highlights the risks of vaccine injuries, fluoride in drinking water, among many other areas.
September 18, 2025Secretary Kennedy renews the declaration of the national opioid crisis as a public health emergency.
– In a declaration on an HHS website, Secretary Kennedy renews the declaration of the opioid crisis as a national public health emergency (PHE).  The opioid crisis was initially declared a public health emergency in 2017; renewal is required every 90 days to continue the PHE.
September 19, 2025Secretary Kennedy announces that the FDA will launch a new review of mifepristone.
– Secretary Kennedy announced that the FDA will undergo a review of the current Risk Evaluation and Mitigation Strategy (REMS) for mifepristone, due to new evidence including an April 2025 report from the Ethics and Public Policy Center (EPPC) which claims that mifepristone has a higher rate of adverse events than previously reported. This report has drawn criticism due to methodological flaws and lack of transparency regarding its data sources.
September 19, 2025ACIP makes several new recommendations related to MMRV and COVID-19 vaccines
– In its September 18-19 meeting, ACIP members vote on several new recommendations including to no longer recommend the combination MMRV (measles, mumps, rubella, and varicella) vaccine for children under the age of 4 and instead to recommend that children in this age group receive measles, mumps, and rubella (MMR) vaccine separately from the varicella vaccine (V). In addition, ACIP members vote to change what had been a universal COVID-19 vaccine recommendation (except for HHS’ recent change for healthy children and pregnant women) to “shared clinical decision-making”, including for those 65 and older, along with a recommendation for new language on risk-benefit for COVID-19 vaccinations. ACIP’s recommendations were adopted by CDC on October 6. While the separate MMR+V vaccines had been recommended as preferred by the CDC for many years, the combination MMRV provided an option for parents to reduce the number of injections their children receive. Now, insurers will no longer be required to cover this vaccine at no-cost. The new COVID-19 vaccine recommendations mean people of all age groups are now recommended to have an interaction with a health care provider (which could include a doctor, nurse, or pharmacist) to determine whether getting a COVID-19 vaccination is recommended for them. If that determination is made, insurers must cover the vaccine at no-cost, although it is possible that some consumers may face challenges in accessing providers in the first place or demonstrating that they have consulted with a medical provider seeking vaccination in some cases.    
September 22, 2025President Trump and Secretary Kennedy announce new actions to address autism spectrum disorder in the U.S.
– In a press conference and via an HHS press statement and Fact Sheet, President Trump and HHS Secretary announce several actions to address the issue of autism spectrum disorder (ASD) in the U.S. This includes FDA authorization for leucovorin, a treatment option for some children with autism, a regulatory change that will allow state Medicaid programs to newly cover leucovorin for the indication of ASD. President Trump and Secretary Kennedy also highlight what they say are risks of acetaminophen use during pregnancy and association with autism. The press release notes “HHS wants to encourage clinicians to exercise their best judgment in use of acetaminophen for fevers and pain in pregnancy by prescribing the lowest effective dose for the shortest duration when treatment is required.”  In his remarks, President Trump also implicated childhood vaccines as a potential risk factor for autism, though no new evidence was presented and that link has already been repeatedly and conclusively ruled out. In a subsequent press statement on September 22, HHS announced FDA was initiating a labeling change for leucovorin, and a safety label change for acetaminophen to include information about the “potential risks of acetaminophen so patients can make a more informed decision.” Public health groups and experts criticized the conclusions linking acetaminophen use in pregnancy and autism, and expressed doubts about leucovorin as a treatment for autism. President Trump’s remarks also precipitated a lawsuit filed on October 28 in Texas against the maker of Tylenol.
September 30, 2025FDA approves a new generic mifepristone product.
– The FDA approved Evita’s Solutions application for a generic version of mifepristone.   The approval included a reminder that the generic mifepristone is subject to the same  Risk Evaluation and Mitigation Strategy (REMS) as the brand-name.
September 30, 2025HHS awards $60 million in grants to support prevention of falls and related programs for older adults and those with disabilities.
– Secretary Kennedy announced 59 new grants totaling $60 million is being awarded to states, territories, tribes, and local organizations supporting older adults and Americans with disabilities, including programs for “preventing falls among seniors, managing chronic conditions…and funding dementia-capable programs.”
October 10, 2025Trump Administration fires thousands of HHS employees, including hundreds at CDC, during federal government shutdown.
– In the midst of a government shutdown and an ongoing federal funding impasse in Congress, the White House Office of Personnel and Management says over 4,000 federal workers are to be fired. At HHS, over a thousand workers are notified that they have lost their jobs, with most of those losses concentrated at CDC. Some of those job losses were reversed over the next few days, with HHS officials stating some notices were sent in error. Even so, as of October 14 it is estimated that about 600 CDC employees remain fired, including staff in areas such as injury prevention, health statistics, and Congressional relations. There is a question about whether such firings during a government shutdown are legal, and groups representing federal workers have filed lawsuits to halt these mass layoffs.
October 31, 2025FDA announces new restrictions on ingestible fluoride products for children.
– FDA announces new enforcement actions “to restrict the sale of unapproved ingestible fluoride products for children” and sends letters to health care professionals warning about the risks associated with these products. The actions come after FDA conducted a review and published a scientific evaluation of these products. In the announcement. FDA says it will be developing a “fluoride research agenda” and “the first national oral health strategy” for the U.S. in partnership with NIH and other HHS agencies.
November 10, 2025FDA announces a warning label change on hormone replacement therapy (HRT) products for addressing symptoms of menopause.
– In a press release, a fact sheet, and a live press event, FDA leaders announce that they will initiate the removal of broad “black box” warnings from HRT products for menopause. The FDA also announces approvals for two new drugs for menopausal symptoms. According to the FDA, women have been “under-utilizing approved therapies” since the “black box” warnings about risks associated with the drugs were placed on these products over 20 years ago. Labels will be rewritten with guidance saying that there are long-term health benefits if HRT is begun within 10 years of the onset of menopause.
November 19, 2025CDC changes language on its website to say a link between vaccines and autism cannot be ruled out.
– A CDC website providing information to the public on Autism and Vaccines, is changed to include language saying “studies have not ruled out the possibility that infant vaccines cause autism.” The new site also discusses the “state of the evidence” on common childhood vaccines and supposed links to autism. The new language is a reversal from previous CDC statements saying “vaccines do not cause autism,” and contradicts the long established scientific consensus that there is no link between vaccines and autism. The new CDC webpage language has been criticized by professional medical organizations such as the American Medical Association and the American Academy of Pediatrics, as well as autism organizations such as Autism Speaks and the Autism Science Foundation.
November 21, 2025CDC staff ordered to end all monkey research programs, potentially affecting development of prevention tools for HIV and other infectious diseases.
– According to reports, CDC staff are ordered to halt its monkey research program by the end of 2025. This program has helped develop HIV prevention tools such as pre-exposure prophylaxis (PrEP) and microbicides, as well supported prevention research for other infectious diseases.
November 28, 2025Internal FDA communication proposes stricter federal requirements for testing and approving vaccines.
– According to reports, the head of FDA’s Center for Biologics Evaluation and Research (CBER), which is responsible for regulating vaccines, issues an email to staff proposing new, stricter federal requirements for vaccine testing, evidence, and approval. The email states that in the future FDA will “demand pre-market randomized trials assessing clinical endpoints for most new products” and that FDA “will not be granting marketing authorization to vaccines in pregnant women” without this kind of evidence. Newly developed pneumonia, influenza, and COVID-19 vaccines are specifically mentioned as vaccines that would be subject to these new requirements. The rationale given for this policy change is a new analysis of vaccine safety data indicating “COVID-19 vaccines have killed American children,” though no evidence to support that statement is provided in the email.
December 5, 2025ACIP votes to end recommendation that all newborns receive hepatitis B vaccine dose at birth
On the second day of the Advisory Committee on Immunization Practices’ (ACIP) December 4-5 meeting, members vote to end a long-standing recommendation that all newborns in the U.S. receive a dose of hepatitis B vaccine. The committee now recommends parents of infants born to mothers who test negative for hepatitis B consult with their provider to help decide if and when their child should receive the first hepatitis B dose. ACIP continues to recommend that infants born to mothers who test positive for hepatitis B, or whose hepatitis B test status is unknown, receive the first hepatitis B vaccine dose at birth. A recommendation from ACIP becomes part of the official CDC immunization schedule once it is adopted by the CDC director.
December 30, 2025HHS ends certain requirements for state reporting of immunization data to the Centers for Medicare and Medicaid Services (CMS).
December 30 letter from the Centers for Medicare and Medicaid Services (CMS) informs state health officials that starting in 2026, states will no longer be required to report several measures related to immunization status to CMS. Specifically, CMS removes the following from its “Child and Adult Core Sets”: “Childhood Immunization Status”, “Immunizations for Adolescents”, “Prenatal Immunization Status: Under Age 21”; and “Prenatal Immunization Status: Age 21 and Older.” In addition, in its letter CMS informs state health officials it will “explore options to facilitate the development of new vaccine measures that capture information about whether parents and families were informed about vaccine choices, vaccine safety and side effects, and alternative vaccine schedules” and “how religious exemptions for vaccinations can be accounted for.” Data reported by states and included in the Child and Adult Core Sets are used by Medicaid and CHIP to monitor access to and quality of health care for their beneficiaries, so an absence of this data could make monitoring immunization coverage in this population more challenging.
January 5, 2026HHS announces changes to the federal childhood vaccination schedule that reduce the number of routinely recommended vaccines
Health and Human Services (HHS) issues a memo implementing major changes to the government’s recommended vaccination schedule for children. Under the new guidelines, there are vaccines for 11 diseases recommended for all children, down from 17 diseases a year ago. In addition to COVID-19 (which HHS stopped recommending for all children back in October 2025), the new schedule no longer recommends routine vaccinations for five other diseases: rotavirus, COVID-19, influenza, hepatitis A, hepatitis B, and meningococcal. These vaccines have been moved from routine recommendation to “shared clinical decision making,” a process that is “individually based and informed by a decision process between the health care provider and the patient or parent/guardian.”  The HPV vaccine remains recommended for routine vaccinations, though under the new guidelines HHS reduces the number of recommended doses of HPV drops from two or three (depending on age of initial vaccination) to one. Coverage for all of these immunizations should remain the same through public and private insurance mechanisms.

Payment Rates for Medicaid Home Care Ahead of the 2025 Reconciliation Law

Authors: Alice Burns, Maiss Mohamed, and Molly O'Malley Watts
Published: Jan 5, 2026

Key Questions

Long-standing workforce challenges in Medicaid home care (also known as home- and community-based services or HCBS) impact care for the over 5 million people who use these services. Shortages and high turnover rates among the direct care workforce reflect demanding work and low wages, particularly among home care workers (who are direct care workers that provide HCBS). This issue brief describes states’ ongoing efforts to respond to shortages of home care workers and how they pay these workers, finding that increased payment rates are a key component of states’ efforts to address workforce shortages.

Such shortages could increase as states will face tough choices about how to absorb Medicaid cuts stemming from the 2025 reconciliation law, which is estimated to reduce federal Medicaid spending by $911 billion over the next decade. When faced with fiscal pressures in the past, states have responded with restrictions on home care, and as a result of the reconciliation law, states may again face significant pressures to cut Medicaid payment rates, offer fewer covered benefits, or restrict eligibility. The Medicaid cuts could also affect access to health coverage among home care workers because over one-in-three workers in home care settings are enrolled in Medicaid. Reduced access to health coverage among the workforce could exacerbate other challenges.

Workforce challenges may also worsen in future years because of changes in immigration policy. Nearly one-in-three home care workers are immigrants, and the Trump Administration’s intensified immigration enforcement and restrictive policies are deepening anxiety and fear among immigrants of all statuses. KFF survey data finds that 13% of immigrants have avoided going to work since January 2025 because of concerns about drawing attention to someone’s immigration status, a number which rises to 40% among people who are likely to be undocumented immigrants. Fewer immigrants overall and potentially lower rates of employment among immigrants could reduce the size of the home care workforce. With more limited immigration, there will be fewer workers overall to care for an aging population.

Amidst this evolving landscape, this issue brief describes Medicaid payment rates for home care and other workforce supports that are in place in 2025, before the majority of the 2025 reconciliation law provisions start taking effect. This issue brief is one of several reporting the data from the 23rd KFF survey of officials administering Medicaid home care programs in all 50 states and the District of Columbia (hereafter referred to as a state), which states completed between April and July 2025. The survey was sent to each state official responsible for overseeing home care benefits (including home health, personal care, and waiver services for specific populations such as people with physical disabilities). All states except Florida responded to the 2025 survey, but response rates for certain questions were lower. States generally completed the survey prior to enactment of the 2025 reconciliation law. Survey findings are reported by state and waiver target population, although states often offer multiple waivers for a given target population. Key takeaways include:

  • All responding states reported taking actions to address workforce shortages, with most states raising payment rates (Figure 1).
  • All states reported shortages of home care workers, most frequently among direct support professionals, nursing staff, personal care attendants, and case managers.
  • Most (41) states reported permanent closures of home care providers within the last year.
  • Among the 34 states that reported time-based payment rates for personal care providers, more than half pay less than $20 per hour.
Increasing Provider Payment Rates Was States' Most Common Strategy to Support the Medicaid Home Care Workforce in 2025

How are States Addressing the Workforce Challenges in Home Care?

All responding states reported workforce shortages in 2025, with the most common shortages being among direct support professionals (48 states), followed by nursing staff (47 states) and personal care attendants (46 states) (Figure 2, Appendix Table 2). States were asked if they had shortages of each type of provider but were not provided with a definition of “shortage.” Most states also reported shortages in case managers (44 states), home health aides (41 states), certified nurse aides (39 states), community-based mental health providers (38 states), and occupational, physical, and speech therapy providers (30 states). In some cases, states may not have reported a shortage of a particular type of provider because that type of service is not offered through their home care program.

All Responding States Reported Shortages of Home Care Workers in 2025

All states reported shortages for more than one type of provider, and 43 states reported shortages among five or more provider types. Such shortages may reflect low compensation coupled with demanding working conditions. In the spring of 2024, home care providers participating in KFF focus groups reported that their jobs had high physical demands and mental demands that were often “overwhelming.” The groups described their wages as low, particularly given the demands of their jobs; and how staffing shortages made their jobs harder because they may not know if they would be able to leave work at the end of their shift. In survey responses, states attributed shortages to low reimbursement rates, lack of qualified providers, and high turnover rates.

Within the last year, 41 states reported permanent closures of home care providers, which were most common among adult day health programs (28 states), followed by group homes (23 states), assisted living facilities, and the enrollee’s home (22 states each) (Figure 3, Appendix Table 3). States were asked if there were any permanent closures of providers that offer services for Medicaid enrollees based on the location in which the providers deliver care. For a setting such as an assisted living facility or group home, a closure could reflect either the closure of an assisted living facility or the closure of a home care agency that sent workers into facilities and group homes. States were not asked to provide a reason for the closures. Some states reported closures of supported employment providers (12 states), home health agencies (11 states), and community mental health providers (5 states). Most states reported closures among more than one type of provider: 35 states reported closures among two or more provider types, and 26 states reported closures among three or more provider types.

41 States Reported Permanent Closures of Medicaid Home Care Providers in 2025

All responding states reported taking actions to address provider shortages, with 48 states increasing payment rates, 38 states developing or expanding worker education and training programs, and 24 states offering incentive payments to recruit or retain workers (Figure 1, Appendix Table 1). Less common initiatives included establishing or raising the state minimum wage (20 states), offering worker retention bonuses (20 states), and offering paid sick leave for workers (18 states). States also reported other types of initiatives to strengthen the workforce, including initiatives allowing people to receive paid care from family members. For example, Oregon created a new 1915(c) waiver that allows parents of minor children to be paid for providing attendant care to their child. States’ actions to address provider shortages in 2025 were similar to those in 2024.

All but 11 states use managed care to provide at least some home care, and in over half of the states with managed care, fee-for-service payment rates impact the payment rates that managed care plans pay home care providers. Out of the 39 states that use managed care to provide at least some home care, 20 states reported that the fee-for-service payment rates represent the minimum amount that plans must pay providers, 2 states, Michigan and Wisconsin, reported that the rate represents the maximum payment rate for managed care plans, 11 states reported that the fee-for-service rates do not affect payments by private plans, and 6 states responded that the answer was unknown or did not respond to the question.

How Much do States Pay for Medicaid Home Care?

KFF asked states to report their average hourly rate paid to two types of home care provider agencies (personal care agencies and home health agencies) and three types of specific home care providers (personal care providers, home health aides, and registered nurses), but many states were unable to report all rates (Appendix Table 4). The number of states that responded to the survey but did not provide hourly payment rates or reported that payment rates were unknown was 4 for personal care agencies and 32 for home health agencies. Many states also did not provide payment rates for specific provider types: For registered nurses and home health aides, more than half of states did not provide hourly payment rate information or reported that payment rates were unknown.

Starting July 2026, states are required to report detailed payment rates for personal care, home health, and other services, per the provisions of the Biden Administration final Access rule (see Box 1). In addition to reporting payment rates for certain home care services, starting in 2030, states must demonstrate that at least 80% of the payments went to compensation for providers, also described as “direct care workers.” Meeting that requirement will require states to know both agency and provider payment rates. Among the states that were able to report payment rates, only 15 could report payment rates for personal care agencies, home health agencies, personal care providers, and home health aides, all of which would be required under the rule. Those 15 states include states that reported a mix of hourly and non-hourly rates, which makes comparisons between provider and agency rates more complicated. These challenges highlight the difficulties states face as they implement the requirements in the new rule, which will take effect in July 2026 (Box 1).

Box 1: Biden Administration Final Access Rule’s Provisions on Home Care

On May 10, 2024, the Biden Administration released a final rule aimed at helping to ensure access to Medicaid services, which has several notable provisions aimed at increasing transparency and improving access to Medicaid home care, increasing home care payment rates, and addressing home care workforce challenges. Although the 2025 reconciliation law delayed other Medicaid rules until 2034, it did not address the final rule on access to Medicaid services.

The rule cites workforce shortages as a major contributor to home care access barriers among Medicaid enrollees. To address those access barriers, the rule requires states to implement the following requirements. Some of the rules take effect as early as 2026, which means guidance to states about how to implement the requirements could emerge soon.

• Starting July 2026, states must report state hourly payment rates for personal care, homemaker services, home health aide services, and habilitation and publish that information on the state website. If states rates vary across provider types, geographies, or other factors, the states must report each of those rates.

• For each type of payment rate, the disclosures must also include the number of Medicaid paid claims and the number of Medicaid enrollees who received the service within the calendar year.

• States must establish an interested parties advisory group (IPAG) comprised of direct care workers, Medicaid enrollees and their representatives, and other interested parties. The IPAG will meet at least every two years to advise and consult on the sufficiency of current and proposed payment rates for personal care, homemaker services, home health aide services, and habilitation.

• Starting July 2030, states must ensure that at least 80% of payments to Medicaid providers for designated home care go directly to compensation for direct care workers. Designated home care include personal care, homemaker services, home health aide services, and habilitation. States may adopt separate standards for small providers or exempt small providers that meet reasonable criteria.

Beyond payment rates, the Access rule includes other requirements aimed at increasing access to home care. Starting July 2027, states will be required to report the number of people on waiting lists for services and the average amount of time from when homemaker services, home health aide services, or personal care services are initially approved to when services begin and the percentage of authorized hours that are provided. The proposed rule also includes provisions that would strengthen requirements around person-centered planning and needs assessment, create new requirements around incident management, establish requirements for people to file grievances if they are receiving home care from the state Medicaid program, and require states to report on nationally-standardized quality measures.

The home care payment-related requirements are one component of a broader emphasis on addressing Medicaid payment rates. The Access rule also requires states to report all fee-for-service Medicaid payment rates on state websites, and to compare various service-specific rates to those of Medicare. A companion rule on Medicaid managed care requires states to submit an annual payment analysis comparing managed care plans’ payment rates to Medicare payment rates for selected services.

States reported many reasons why it was difficult to report payment rates, including the following.

  • Some states reported that services were bundled together in various ways and therefore, the payment rates were not distinguishable.
  • Among states with managed care, some states responded that they did not know the payment rates for agencies because the services were paid for by managed care plans and they did not have access to those payment rates.
  • Other states responded that they knew the payment rates for agencies but not what the agencies paid their home care workers. Multiple states reported that they do not “dictate” what agencies pay to providers or that individual providers negotiate their own payment rates with the agencies.

In addition to having difficulty reporting payment rates, many states reported different payment rates for personal care across different waivers, and the waiver payment rates often differ from the payment rates for personal care provided through the state plan. When states reported multiple payment rates for personal care, KFF used the median of those payment rates in the analysis.

The payment rates to home care providers show considerable variation and are somewhat higher than those reported by other organizations on account of differences in reporting and provider categorization (Figure 4). KFF’s survey estimates that median payment rates to providers are $19 per hour for personal care providers, $41 for home health aides, and $70 for registered nurses. It is difficult to compare those numbers to other sources of data for the following reasons.

  • Other organizations group classes of providers together differently. PHI reports that in 2024, the median rate for home care workers was $17 per hour and $18 per hour for residential care aides. The Bureau of Labor Statistics reports $17 per hour for home health and personal care aides in 2024.
  • Other organizations include payment rates for workers regardless of the source of payment whereas KFF rates only reflect the Medicaid rates. Medicaid often covers more intensive personal care services than other payers, which may contribute to the higher rates.

Payment rates to home health agencies are generally larger than those to personal care agencies, but there is considerable variation in both (Figure 4). Among states reporting hourly rates, the rates for home health agencies range from $25 to $159 whereas those for personal care agencies range from $14 to $44. Those states reported that the median hourly payment to home health agencies was $51 and $26 for personal care agencies. Between 2024 and 2025, the median payment rates for personal care agencies and most other provider types increased marginally.

There is Considerable Variation in Payment Rates for Medicaid Home Care, Across States and Provider Types

Among states able to report any payment rate data, payments for personal care workers range from below $15 to over $30 per hour (Figure 5, Appendix Table 4). Rates for home health aides are somewhat higher than those of personal care workers, reflecting the additional training requirements for such workers. Among the states with payment rates for home health aides in the highest category, some states reported that the rates were per visit or per day (which is noted in Appendix Table 4). There were other states with particularly high payment rates that did not report providing rates per visit or per day, but the rates may still reflect a non-hourly payment basis.

Payment Rates for Home Care Vary Across States and Type of Provider

Appendix Tables

States’ Use of Strategies to Increase the Number of Medicaid Home Care Workers in 2025

States' Use of Strategies to Increase the Number of Medicaid Home Care Workers in 2025

States’ Responses to Whether They Were Experiencing Workforce Shortages by Type of Worker in 2025

States' Responses to Whether They Were Experiencing Workforce Shortages by Type of Worker in 2025

States Reporting Permanent Closures of Home Care Providers in 2025, by the Location in Which Services are Offered

States Reporting Permanent Closures of Home Care Providers in 2025, by the Location in Which Services are Offered

States’ Hourly Payment Rates for Home Care Agencies and Workers in 2025

States' Hourly Payment Rates for Home Care Agencies and Workers in 2025

Medicaid Home Care (HCBS) in 2025

Authors: Maiss Mohamed, Alice Burns, and Molly O'Malley Watts
Published: Jan 5, 2026

Key Questions

Many older adults and people with disabilities require assistance with self-care such as bathing, dressing, and eating. Help with such services is known as “long-term care” and may be provided in institutional settings such as nursing facilities or in people’s homes and the community, including assisted living facilities. Four-in-ten adults incorrectly believe that Medicare is the primary source of coverage for low-income people who need nursing or home care, but Medicaid is the primary payer—covering nearly two-thirds of all home care spending in the United States in 2023.

The 2025 reconciliation law is estimated to reduce federal Medicaid spending by $911 billion (roughly 14%) over a decade and may have broad implications for home care, including for the workforce, support for family caregivers, and states’ coverage of services. Over half of Medicaid spending finances care for people ages 65 and older and those with disabilities, the enrollees most likely to use home care and related services, and reductions of this magnitude will leave states with difficult choices to raise new revenues or reduce Medicaid spending. The reconciliation law also established a new type of 1915(c) home care waiver for people who do not need an institutional level of care. Take-up of the new waivers is expected to be low given the cuts to federal Medicaid spending and requirements for states to demonstrate that new waivers will not increase the average amount of time that people wait for existing waiver services. This issue brief provides an overview of what Medicaid home care (also known as “home- and community-based services” or HCBS) is, who is covered, and what services were available in 2025. Over 5 million people receive Medicaid covered home care services annually.

This brief is one of several describing data from the 23rd KFF survey of officials administering Medicaid home care programs in all 50 states and the District of Columbia (hereafter referred to as a state), which states completed between April and July 2025. Other issue briefs from the survey describe the number of people on waiting lists for home care, how states manage home care spending, how home care programs support family caregivers, and payment rates for home care providers. The survey was sent to each state official responsible for overseeing home care benefits (including home health, personal care, and waiver services for specific populations such as people with physical disabilities). All states except Florida responded to the 2025 survey, but response rates for certain questions were lower. Where possible, KFF supplemented survey data with previously reported or publicly available data to provide information for the states that did not respond. Survey findings are reported by state and waiver target population, although states often offer multiple waivers for a given target population. States generally completed the survey prior to enactment of the reconciliation law. Key takeaways include:

  • Nursing facility care is a required Medicaid benefit, but states can choose whether to provide most home care services. A key component of home care is personal care, which helps people who need assistance with self-care (such as bathing and dressing) and household activities (such as taking medications and preparing meals).
  • Medicaid home care can be offered through either the Medicaid state plan or as part of a specialized waiver. All states offer Medicaid home care through waivers, most commonly 1915(c) waivers (47 states).
  • Home care is also offered through 1115 waivers (15 states), personal care offered as a state plan benefit (33 states), or the Community First Choice option, which is also a state plan benefit (10 states, Figure 1).
  • Most states provide Medicaid home care through waivers that offer benefits specifically targeted to people with intellectual or developmental disabilities (48) and people ages 65 and older or who have physical disabilities (46). For such waivers, most states offer multiple waivers for each population: Among states with intellectual or developmental disability waivers, only 16 offer one program, while 18 offer three or more; and among states with waivers serving people ages 65 and older or who have physical disabilities, 24 offer only one program and 10 offer three or more.
  • Waivers’ coverage of different home care services, such as day services, supported employment, and home-based services, vary by the target populations they serve.
All States Offer Medicaid Home Care Through Optional Waiver and State Plan Programs

What programs do states use to provide Medicaid home care?

Unlike institutional long-term care, nearly all home care is optional for states to provide under Medicaid. States are required to offer cover home health—which consists of part-time nursing services; home health aide services; and medical supplies, equipment, and appliances suitable for use in the home—but all other home care services are provided at the discretion of the states. States use various federal legal “authorities,” also known as programs, to offer home care, which are generally categorized as being part of the Medicaid state plan or part of a waiver. If services are provided through a state plan, they must be offered to all eligible individuals. In contrast, services provided under waivers, such as 1115s or 1915(c)s, may be restricted to specific groups based on geographic region, income, or type of disability. Waivers may include a wider range of service types than can be provided under state plans, but states may limit the number of people receiving waiver services. When the number of people seeking services exceeds the number of waiver slots available, states may use waiting lists to manage participation in the waiver.

All states have at least one home care program and many states have multiple programs. Home care is most frequently offered through 1915(c) waivers (47 states) and the personal care state plan benefit (33 states), and less frequently offered through 1115 waivers (15 states) or the Community First Choice option (10 states, Figure 1). KFF estimates that 5.1 million people used Medicaid home care in 2023 compared with only 1.4 million people who used institutional long-term care.

All states offer people assistance with self-care and household activities under the personal care benefit, but they use different programs to do so. The primary home care benefit is personal care, which provides people with assistance with the activities of daily living (such as eating and dressing) and the instrumental activities of daily living (such as preparing meals and managing medication). States most commonly cover personal care through waivers (48 states), followed by the state plan (33 states).

How are people eligible for Medicaid home care?

Most people who are eligible for Medicaid home care qualify on the basis of having a disability or being ages 65 and older. Medicaid eligibility pathways in which eligibility is based on old age or disability are known as “non-MAGI” pathways because they do not use the Modified Adjusted Gross Income (MAGI) financial methodology that applies to children, pregnant individuals, parents, and other non-elderly adults with low incomes. In addition to considering income and age or disability status, non-MAGI eligibility pathways usually require people to demonstrate that they have limited savings and other financial resources (e.g., assets). Because nearly all non-MAGI pathways are optional, eligibility levels vary substantially across states.

Most states allow people with somewhat higher incomes to qualify for Medicaid home care, but income is capped at 300% of the supplemental security income limit ($2,901 per month in 2025) and assets are usually limited to $2,000 per person. Medicaid enrollees who use long-term care must also meet requirements related to their functional needs which are generally measured in terms of the ability to perform activities of daily living such as eating and bathing. Over half of people who use Medicaid home care are also enrolled in Medicare; such people are also known as dual-eligible individuals

In 2025, states operated over 300 different programs for Medicaid home care, many of which targeted a specific population. Most programs (259) were operated through 1915(c) waivers with 15 operated through 1115 waivers. The most common waiver programs target people with intellectual or developmental disabilities (48 states) and people who are ages 65 and older or have physical disabilities (46 states). States are likely to offer multiple waiver programs for the most common target populations, but states with less common waivers, such as those serving people with traumatic brain or spinal cord injuries or mental health conditions, typically only offer one program per target population.

Each year, some states’ waiver programs change, but in general, the trend has been towards offering more waivers. In 2025, only one state, Oregon, had new waivers and no states eliminated waivers. In Oregon, there is a new 1115 waiver for people who are ages 65 and older or have physical disabilities that provides in-home support services and support for family caregivers and a new 1915(c) waiver that allows parents of minor children with disabilities to be paid for providing attendant care to their child.

States Vary in the Number of Waiver Programs Offered for Different Target Populations

What services does Medicaid home care cover?

Besides personal care, Medicaid home care covers an array of services to help people with the activities of daily living and the instrumental activities of daily living. KFF asked states about what services they provide through Medicaid home care programs using the Centers for Medicare and Medicaid Services’ list of services, which are categorized in a comprehensive taxonomy. The taxonomy was developed to provide common language for describing home- and community-based services across waivers and state plans. Those services vary widely, including adult day care, supported employment, round-the-clock care, services to support unpaid family or friends who are caregivers, home-delivered meals, and non-medical transportation (Table 1).

All responding states (50) cover supported employment, day services, home-based services, and equipment, technology, and modifications in any home care program (Appendix Table 3). States often also offer other additional services for specific populations that are uniquely tailored to the needs of waiver recipients. Examples of such services reported in the 2025 survey include:

  • Illness support, group counseling, and bereavement counseling in a waiver for children who are medically frail or technology dependent (Colorado);
  • Discovery and career planning, additional residential supports, and community navigators in a waiver for people with intellectual or developmental disabilities (Hawaii);
  • Dental services, permanent supportive housing, and prevocational/community career planning in a waiver for people with intellectual or developmental disabilities (Louisiana);
  • Other speech, hearing, language, occupational, and physical therapies in a waiver for people who are ages 65 and older or have physical disabilities (Texas).

Among the categories defined by the Centers for Medicare & Medicaid Services, the least-frequently covered service was rent and food expenses for a live-in caregiver. For the most common services, there is little change in the number of states offering each type of service in a given year. (The numbers reported for most services are higher in 2025 but in many cases, that reflects a higher state response rate in 2025 than in 2024.)

Interactive DataWrapper Embed

States use waivers that target specific populations to offer tailored benefits, and covered services differ among different types of waivers (Figure 3, Appendix Table 4). Some services, such as equipment, technology and modifications, home-based services, and day services, are covered by most states and in most waiver programs. However, other services are much more targeted to specific populations. Comparing services among the most commonly-offered waivers (those serving people with intellectual or developmental disabilities and people who are ages 65 and older or have physical disabilities), shows some services are widely covered by one type of waiver but not the other. For example, 47 states cover supported employment for people with intellectual or developmental disabilities, but only 15 cover the service for people who are ages 65 and older or have physical disabilities, a population less likely to be working. Alternatively, home-delivered meals are covered by 41 states under waivers serving people who are ages 65 and older or have physical disabilities, but only under 10 states’ waivers serving people with intellectual or developmental disabilities. By enabling states to cover, at times, different services per target population, waivers allow states to customize services to the needs of the specific populations they serve.

Within waivers, states may change the benefit offerings from year to year, highlighting the flexibility that home care waivers offer to states in managing program benefits and spending. Focusing on the most common waivers and benefits, some notable changes between 2024 and 2025 include the following. (Due to variation in the number of states responding to KFF’s survey and changes in the number of waivers offered between 2024 and 2025, comparing the number of states or waivers offering each type of service could be misleading. However, looking at changes in covered services within a specific waiver can illuminate the flexibility available to states.)

  • Oregon began offering coverage of equipment, technology, and modifications for waivers serving people who are ages 65 and older or have physical disabilities, and Idaho now covers case management services for waivers serving the same population.
  • D.C. and South Dakota started offering coverage of non-medical transportation for waivers serving people with intellectual or developmental disabilities, but Illinois and Kentucky no longer cover this service for those waivers.
  • Michigan, Nevada, and Washington began covering day services for waivers serving people with intellectual or developmental disabilities, and Idaho started offering this benefit for waivers serving people who are ages 65 and older or have physical disabilities.
States' Coverage of Medicaid Home Care Services Vary by Target Population

How do states use managed care to provide home care?

All but 11 states use managed care to provide at least some home care (Figure 4). In managed care, states pay managed care plans a set fee—often called a capitation payment—for each person enrolled and the managed care plans are responsible for providing all services to enrollees. Use of managed care to provide home care has been growing over time, with states using managed care to make their Medicaid spending more predictable and to help coordinate the services enrollees use.

All but 11 States Provide Some Medicaid Home Care Through Managed Care Plans

Managed care is more commonly used for home health benefits provided through the state plan or 1115 waivers than for 1915(c) waivers (Figure 5, Appendix Table 5). Among the 15 states with 1115 waivers, 10 use managed care plans to provide at least some home care; and over two-thirds of states use managed care plans to provide at least some home health through the state plan. Fewer than half of states use managed care plans to provide some personal care through the state plan. For 1915(c) waivers, over half of states (26) use managed care plans, 4 more states than in 2024, but managed care was much less common for waivers serving people with intellectual or developmental disabilities—of the 47 out of 51 responding states with such waivers, only 8 provided any of the benefits through managed care.

All States Provide Optional Medicaid Home Care, Many Using Managed Care

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

Appendix Tables

States Offering Medicaid Home Care Through Various Federal Programs

States Offering Medicaid Home Care Through Various Federal Programs

States Offer Medicaid Home Care for Several Target Populations

States Offer Medicaid Home Care for Several Target Populations

States Reporting Coverage of Each Medicaid Home Care Service Under Any Program

States Reporting Coverage of Each Medicaid Home Care Service Under Any Program

States’ Coverage of Medicaid Home Care Services Vary by Target Population

States' Coverage of Medicaid Home Care Services Vary by Target Population

All States Provide Optional Medicaid Home Care, Many Using Managed Care

All States Provide Optional Medicaid Home Care, Many Using Managed Care

Medicaid’s Home Care Support for Family Caregivers in 2025

Authors: Alice Burns, Abby Wolk, and Molly O'Malley Watts
Published: Jan 5, 2026

Key Questions

KFF estimates that 5.1 million Medicaid enrollees use home care, which provides medical and supportive services to help people with the activities of daily living (such as eating and bathing) and the instrumental activities of daily living (such as preparing meals and managing medications). Medicare generally does not cover home care (also known as home- and community-based services or HCBS), and Medicaid paid for two-thirds of home care spending in the United States in 2023.

In Medicaid home care, many people “self-direct” their services, giving them greater autonomy over the types of services provided and who they are provided by; and in some cases, allowing payments to family caregivers. Payments for caregiving can help mitigate the financial struggles family caregivers experience when they are forced to reduce their hours of work or quit their jobs on account of their caregiving duties. KFF focus groups of caregivers found that family caregivers often reported struggling to make ends meet and having to reduce the hours they are working other jobs due to the demands of caregiving. Self-directed services can also help address shortages of paid home care workers, which can be one of the factors placing additional strain on family caregivers. Beyond paying for their caregiving, Medicaid supports family caregivers with services such as training, support groups, and respite care (which is paid care that allows family caregivers to take a break from their normal responsibilities).   

The 2025 reconciliation law, passed on July 4, includes significant changes to the Medicaid program that are estimated to reduce federal Medicaid spending by $911 billion over the next decade. Given the substantial share of Medicaid spending that pays for home care, and the optional nature of most home care programs, cuts to home care programs could occur as states respond to the reductions in federal spending.

Such changes could affect Medicaid supports to family caregivers, all of which are optional for states to provide. A reduction in the availability of those supports could exacerbate challenges for people who need home care and are unable to find other sources of care due to workforce shortages, which may be amplified by the Trump Administration’s intensified immigration enforcement and restrictive policies, since nearly one-in-three home care workers are immigrants. For family caregivers, many may need to continue to provide care without payments and other Medicaid changes could affect access to health coverage. According to AARP’s 2025 Caregiving in the US report, there are over 8 million family caregivers for whom Medicaid is their source of health insurance (13% of 63 million total family caregivers).  

Amidst this background, this issue brief describes the availability of self-directed services and supports for family caregivers in Medicaid home care in 2025, before most provisions in the reconciliation law take effect. The data come from the 23rd KFF survey of officials administering Medicaid home care programs in all 50 states and the District of Columbia (hereafter referred to as a state), which states completed between April and July 2025. The survey was sent to each state official responsible for overseeing home care benefits (including home health, personal care, and waiver services for specific populations such as people with physical disabilities). All states except Florida responded to the 2025 survey, but response rates for certain questions were lower. Survey findings are reported by state and waiver target population, although states often offer multiple waivers for a given target population. Key findings include:

  • All reporting states except Alaska allow Medicaid enrollees to self-direct their home care in at least some circumstances, and among those states, all allow enrollees to select, train, and dismiss their caregivers.
  • All responding states pay family caregivers under some circumstances and provide family caregivers with other types of support, including respite care (Figure 1, Appendix Table 1)
  • Family supports are most widely available for caregivers of people with intellectual or developmental disabilities (I/DD).
All Responding States Pay Family Caregivers Under Some Circumstances

How Many States Allow Medicaid Enrollees to Self-Direct Their Home Care?

Nearly all states allow Medicaid enrollees to self-direct their home care in some circumstances (Figure 2, Appendix Table 2). Self-direction came out of the “consumer-directed” movement for personal care services that started with demonstration programs in 19 states funded through grants from the Robert Wood Johnson Foundation. Today, states may give people the option to self-direct home care through a wide variety of optional home care programs. States most frequently allow self-direction in waivers that serve people with intellectual or developmental disabilities, followed by people who are ages 65 and older or have physical disabilities. Among the 50 states responding to KFF’s survey, Alaska is the only state that reported not permitting self-direction under any of the home care programs. 

Nearly All States Allow Individuals to Self-Direct Home Care Under at Least One Program

Among states that authorize self-direction, all states allow enrollees to select, dismiss, and train workers (Figure 3). The ability to select, train, and dismiss workers is referred to as “employer authority” because it allows Medicaid enrollees (with the help of their designated representatives when appropriate) to decide who will be caring for them. All states with self-directed services programs provide employer authority to enrollees. Most states also allow enrollees to establish payment rates for their caregivers (41) and to determine how much Medicaid funding is spent among the various authorized services (39).

All States with Self-Directed Home Care Programs Allow Enrollees to Select Their Caregivers

How Many States Pay Family Caregivers and Through Which Home Care Programs?

All responding states pay family caregivers through one or more Medicaid home care programs (Figure 1, Appendix Table 1). Family caregivers can generally be paid to provide personal care, which may be offered through several different types of Medicaid home care programs. Personal care may be provided through waivers such as the 1115 or 1915(c) programs, through the Medicaid state plan, or a combination of both. Waiver services tend to encompass a wider range of benefits than the state plan benefit, but waivers are usually restricted to specific groups of Medicaid enrollees based on geographic region, income, or type of disability; and are often only available to a limited number of people, resulting in waiting lists. 

All responding states allow payments to family and friends through one or more waiver programs, but fewer states allow payments to legally responsible relatives. Forty-four states allow payments to legally responsible relatives through waiver programs. Payments to legally responsible relatives are less common than those to other family and friends because of additional legal requirements that pertain to payments to legally responsible relatives (Box 1). Payments to family caregivers are less common through the state plan—allowed by 24 states for other family and friends and by 6 states for legally responsible relatives. States pay family caregivers through the state plan less frequently because fewer states offer personal care through the state plan and because the legal requirements governing state plan services are more restrictive than those governing waiver services. 

While all responding states allow payments to family caregivers, it is unknown what percentage of waiver participants are receiving paid care. KFF asked states, “What percentage of waiver recipients are receiving paid care from their legally responsible relatives/family members who are not legally responsible relatives?” Over two-thirds of states were unable to report the percentage of waiver recipients receiving paid care from either legally responsible relatives or other family members/friends. It is also unknown how often people with paid family caregivers also receive other paid care.

Box 1: What are the legal requirements for paying family caregivers?

Medicaid laws have more complicated requirements for states to pay legally responsible relatives than is the case for other types of family and friend caregivers. The specific legal requirements for paying family caregivers are complicated and differ across home care programs: 

• For personal care offered through the state plan using section 1905 authority, there is a federal prohibition on paying for services provided by spouses and parents of minor children (which comprise most but not all legally responsible relatives). Other family and friends may be paid if they meet applicable provider qualifications, there are strict controls on the payments, and the provision of care is justified (which can be done when there is a lack of other qualified providers in the area). 

• For home care offered through waiver programs, the requirements governing payments to family and friends are like those governing personal care through section 1905 authority. A key difference is that states may pay legally responsible relatives when the services being provided are “extraordinary care,” which is defined as care that exceeds the range of activities a legally responsible relative would ordinarily perform and is necessary to health, welfare, and avoiding institutionalization. 

• For personal care offered through the state plan using one of the section 1915 authorities, states may pay legally responsible relatives using criteria like those of the waiver programs. However, some of those authorities designate a family member to be the recipient’s legal representative and may prohibit payments to legal representatives.  

Payments for family caregivers are most common under waivers for people with intellectual or developmental disabilities (Figure 4, Appendix Table 3). Among the 47 states that responded to the survey and have waivers for people with intellectual or developmental disabilities, all 47 allow payments to family caregivers. There are fewer states with other types of waivers, and not all the other waivers allow payments to family caregivers. Among the 45 responding states with waivers for older adults and people with physical disabilities, 43 pay family caregivers, and among the 21 states with waivers for people with traumatic brain or spinal cord injuries, 19 do.

Among Waivers and Programs, States Are Most Likely to Pay Family Caregivers for People with Intellectual or Developmental Disabilities

In most cases, family caregivers receive hourly wages like those of other employees, but 11 states have adopted programs known as structured family caregiving, in which family members are paid a per diem rate (Appendix Table 4). Structured family caregiving is a Medicaid benefit that supports unpaid caregivers of people who use Medicaid home care through waiver programs. In the structured program, Medicaid pays provider agencies a daily stipend for participants. The agency is responsible for directing a care coordinator or social worker and a nurse to oversee the family caregiver, answer health-related questions, and provide emotional support; conducting home visits about once per month; and passing a fixed percentage of the stipend (usually 50% – 65%) on to the family caregiver. Among the handful of payment rates reported in an overview of the program by the American Council on Aging, payments to family members are around $40 to $70 per day. States reported structured family caregiving programs in the following home care waivers:

  • Older adults and people with disabilities in 9 states (Connecticut, Georgia, Indiana, Louisiana, North Carolina, North Dakota, Ohio, Rhode Island, and South Dakota),
  • People with intellectual or developmental disabilities in 2 states (Indiana and New Hampshire), 
  • Medically fragile children in North Carolina,
  • People with traumatic brain and/or spinal cord injuries in Indiana and
  • People with Alzheimer’s and related disorders in Missouri. 

Although KFF’s survey only includes home care waivers, according to the American Council on Aging, two states offered structured family caregiving as a standalone program: Massachusetts offers it as a state plan benefit through a program for adults in foster care, and Nevada has a standalone waiver to provide the benefit for caregivers of people with Alzheimer’s and related dementias.

What Other Types of Support Does Medicaid Home Care Provide for Family Caregivers?

All responding states provide support for family caregivers—who may be paid or unpaid—and most offer more than one type of support (Figure 5, Appendix Table 5). All responding states reported covering respite care, which provides short-term relief for caregivers, allowing them to rest, travel, attend appointments, or spend time with other family and friends. Other commonly covered benefits include caregiver training (37 states), and counseling or support groups (26 states).

All Responding States Provide Supports for Family Caregivers Through Medicaid Home Care

Respite care may be provided anywhere from a few hours to several weeks at a time. Medicare only covers respite care for people who are receiving hospice care, which is only available for people who are terminally ill and electing to receive comfort care instead of curative care for their illness. That makes Medicaid’s respite care the primary source of coverage for caregivers of people with Medicare and Medicaid. Respite care is offered most frequently under waivers for people with intellectual or developmental disabilities (44 states) and older adults and people with disabilities (44 states).

Daily respite care is offered by the most states (43), followed by institutional respite care (40 states, Figure 6, Appendix Table 6). Daily respite care is available under waivers for people with intellectual or developmental disabilities in 34 states and available in 32 states within waivers for people who are ages 65 and older or have physical disabilities. Twenty-two states provide institutional respite care within waivers for people who are ages 65 and older or have physical disabilities and within waivers for people with intellectual or developmental disabilities. Weekly respite care is the least frequently offered (24 states total), and over half of states (32) report offering other types such as hourly, monthly, or annual.

Among Waivers and Programs, States Are Most Likely to Offer Daily Respite Care

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

Appendix Tables

States’ Policies to Allow Medicaid Home Care Payments to Spouses, Parents of Minor Children, and Other Legally Responsible Relatives for Caregiving

States' Policies to Allow Medicaid Home Care Payments to Spouses, Parents of Minor Children, and Other Legally Responsible Relatives for Caregiving

States’ Policies to Allow Individuals to Self-Direct Medicaid Home Care by Waiver/Program

States' Policies to Allow Individuals to Self-Direct Medicaid Home Care by Waiver/Program

States’ Policies to Allow Medicaid Home Care Payments to Spouses, Parents of Minor Children, and Other Legally Responsible Relatives as well as Family and Friends for Caregiving

States' Policies to Allow Medicaid Home Care Payments to Spouses, Parents of Minor Children, and Other Legally Responsible Relatives as well as Family and Friends for Caregiving

States Offering the Structured Family Caregiver Program, Which Supports Unpaid Caregivers of Persons Who Are Using Medicaid Home Care, and Waivers the Program Is Offered Under

States Offering the Structured Family Caregiver Program, Which Supports Unpaid Caregivers of Persons Who Are Using Medicaid Home Care, and Waivers the Program Is Offered Under

States’ Policies for Offering Different Types of Family Caregiving Supports

States’ Policies for Offering Different Types of Family Caregiving Supports

Types of Respite Care Offered by State and Home Care Program: Daily, Weekly, Institutional, and Other

Types of Respite Care Offered by State and Home Care Program: Daily, Weekly, Institutional, and Other

Policy Changes Bring Renewed Focus on High-Deductible Health Plans 

Published: Jan 5, 2026

The expiration of the Affordable Care Act’s enhanced premium tax credits, along with the passage of the budget reconciliation law, implementation of new Marketplace regulations, and other administrative changes, could bring significant changes to ACA Marketplace enrollment and affordability for the 2026 plan year and beyond. Anticipated increases in what enrollees pay for premiums and new standards for health savings accounts (HSAs) could lead some consumers to consider plan options with lower premiums in exchange for higher deductibles, such as catastrophic or bronze plans. This issue brief examines key features of bronze and catastrophic plans, recent policy changes, coverage and costs, and the complicated choices for consumers.

What are some key features of Marketplace bronze and catastrophic plans?

Affordable Care Act (ACA) qualified health plans (QHPs) are categorized into four “metal levels” based on the overall amount of cost sharing they require: bronze, silver, gold, and platinum, plus catastrophic plans, which are a separate tier of QHPs. Bronze and catastrophic plans offered through the Marketplaces must cover essential health benefits, limit the amount of annual cost sharing for covered benefits ($10,600 for an individual or $21,200 for a family in 2026), cover certain preventive services without cost sharing, and have other ACA-required consumer protections.

There are several notable differences between the characteristics of bronze and catastrophic plans (Table 1). Bronze plans usually have the lowest premiums of all metal levels, but the highest deductibles. Catastrophic plans often, but not always, have even lower premiums than bronze plans, but a higher level of cost sharing. In 2026, bronze plans have an average deductible of $7,476, while catastrophic plans have deductibles equal to the out-of-pocket maximum allowed under the ACA ($10,600 for an individual or $21,200 for a family in 2026).

Both bronze and catastrophic plans can be purchased on or off the Marketplaces, but premium tax credits are only available for metal level plans that are sold on the Marketplace, meaning they cannot be applied to any plans sold off the Marketplace, nor to catastrophic plans. (Cost-sharing reductions— which lower out-of-pocket costs for enrollees with income between 100% and 250% of the federal poverty level (FPL)—are only available for silver plans on the Marketplace.)

Actuarial value — the expected share of health care expenses a plan covers for a standard population — also differs between bronze and catastrophic plans. Bronze plans are currently required to have an actuarial value (AV) between 58% and 62%, though the AV for expanded bronze plans can be as high as 65%. (Regulations finalized in June 2025 would permit an AV as low as 56% for standard bronze plans, but a court ruling has temporarily blocked that provision (and others) from taking effect.) Catastrophic plans, on the other hand, are not required to meet minimum actuarial value targets, except that they must have a lower AV than bronze plans. However, due to the permitted range of bronze actuarial values, the “generosity” of these two types of plans can be similar.

Unlike metal level plans, which can be sold to anyone eligible for Marketplace coverage, catastrophic plans can only be sold to individuals under age 30 or individuals over 30 who qualify for a “hardship” or “affordability” exemption. Consumers may be eligible for the affordability exemption if their lowest cost coverage option available through a Marketplace or employer would cost more than 8.05% of their household income in 2026. A person may qualify for a hardship exemption if they experience one of several examples of financial or domestic circumstances, such as an unexpected natural or human-caused disaster, domestic violence, or bankruptcy.

Comparison of General Features of Bronze and Catastrophic ACA Plans

What recent changes have been made to catastrophic plans and bronze plans?

In September 2025, the Trump administration issued guidance expanding the catastrophic plan hardship exemption to include consumers who are not eligible for premium tax credits or cost-sharing reductions due to their income, chiefly those with incomes below 100% FPL or above 250% FPL, beginning with the 2026 plan year. This change currently applies to individuals in all states except California, Connecticut, Maryland, and the District of Columbia.

Even though those below 100% FPL are ineligible for premium tax credits, they are generally eligible for Medicaid in states that have expanded Medicaid. With varied eligibility criteria in non-expansion states, this population may fall in the coverage gap. While they could theoretically buy a catastrophic plan, they would be unlikely to be able to afford the premium or the very high deductibles.

The administration has begun streamlining the application process for this hardship exemption through HealthCare.gov and its paper applications to make it easier for consumers to enroll in a catastrophic plan. Also, HealthCare.gov now automatically displays catastrophic plans (where available) for consumers age 30 and older if they enter an income above 400% FPL or below 100% FPL. These plans are not currently displayed for consumers with incomes between 250% FPL and 400% FPL.

In addition to the hardship exemption changes, the 2025 budget reconciliation law expanded the availability of health savings accounts (HSAs) on the Marketplace. Previously, only plans that met IRS rules related to minimum annual deductible amounts, out-of-pocket maximums, and other design features were eligible to be paired with an HSA. No catastrophic plans were HSA-eligible. Starting on January 1, 2026, all individual market bronze and catastrophic plans are considered HDHPs and eligible to be paired with an HSA even if the plan does not meet the minimum annual deductible requirement ($1,700 for individual coverage and $3,400 for family coverage in 2026) or the HSA out-of-pocket (OOP) maximum requirement ($8,500 for self-only coverage and $17,000 for family coverage in 2026) for an HDHP. New IRS guidance states that this change applies to all bronze and catastrophic plans, even those not purchased through a Marketplace (“off-exchange”). Other changes to HSA-eligible HDHPs include allowing pre-deductible coverage of telehealth and other remote care services, and allowing individuals covered by certain direct primary care arrangements to be eligible for an HSA.

Separately, congressional Republicans have recently proposed alternatives to continuing the enhanced premium tax credits that would further expand access to HSAs. While precise details vary, they generally propose directing funds to HSAs for eligible consumers enrolled in a catastrophic or bronze Marketplace plan to pay for out-of-pocket expenses. President Trump has also signaled his support for replacing tax credits with direct payments to consumers. None of these proposals has advanced.

What is the availability of and enrollment in bronze and catastrophic Marketplace plans?

An insurer selling QHPs on the Marketplace must offer at least one silver and one gold plan in all the areas where the insurer sells Marketplace coverage. Although Marketplace insurers in most states are not required to offer a bronze plan in all areas, only one county in the US does not have a bronze plan for sale for 2026; the availability of catastrophic plans is more limited. Where catastrophic plans are available, there tend to be fewer plan choices than there are for bronze plans.

In 2026, catastrophic plans are offered in 36 states and the District of Columbia—down from 40 states and the District of Columbia in 2025. The share of Marketplace enrollees with access to catastrophic plans fell from 87% to 76% over the same period.

Enrollees have Few Options for Issuers that Offer Catastrophic Plans in Many States

In 2025 (without the new hardship exemption extension in effect), less than 1% of Marketplace enrollees chose a catastrophic plan, and 30% selected a bronze plan. The highest uptake of catastrophic plans was in the District of Columbia and Minnesota, where about 2% of Marketplace enrollees were in a catastrophic plan in 2025.

How do premiums for bronze and catastrophic plans compare?

In 2026, the average lowest-cost catastrophic Marketplace plan for a 27-year-old individual is $346 per month, a 29% increase from 2025. The average lowest-cost unsubsidized bronze plan (where catastrophic plans are also available) is $369 for a 27-year-old, a 19% increase from 2025. On average, the gap between premiums for unsubsidized bronze and catastrophic plans shrank by $19 per month for a 27-year-old individual from last year. (Differences in where catastrophic plans are offered may have contributed to this change.) The lowest-cost catastrophic Marketplace plans for 2026, where available, are, on average, $23 cheaper per month than the lowest-cost unsubsidized bronze plan for a 27-year-old individual. However, this varies a lot by county. For example, unsubsidized bronze plans offered in more than half of the counties in Oklahoma are over $200 cheaper per month than the cheapest catastrophic plan for a 27-year-old individual. Conversely, all counties in Connecticut have catastrophic plans around $200 a month cheaper than the lowest-cost unsubsidized bronze plan for a 27-year-old individual.

The Trump administration’s expansion of catastrophic plan hardship exemptions was not announced until September, after many insurers had already submitted their proposed rates for the 2026 plan year. As a result, its effect on pricing for bronze and catastrophic plans is unclear and may affect the relative pricing of bronze and catastrophic plans in future years, with more data on which to base premiums.

Even with the hardship exemption expansion, potential enrollees may have difficulty finding affordable coverage options in places where catastrophic plans are available. For a 27-year-old individual earning $45,000 a year (just under 300% FPL), expenditures on premiums would amount to 9% of income; a 50-year-old with the same income would spend 16% on premiums ($7,027 annually) on average.

One of the reasons catastrophic plans have lower premiums, on average, than bronze plans is that catastrophic plans tend to enroll younger and healthier consumers, thus lowering average claims costs per enrollee. Insurers may then be able to offer lower premiums, on average, compared to bronze plans, which may enroll an overall sicker (higher cost) population. Additionally, while all non-grandfathered individual market plans are part of the same general risk pool, for the purpose of the ACA’s risk adjustment program, which redistributes funds from plans with lower-risk enrollees to plans with higher-risk enrollees, catastrophic plans are treated as a separate risk pool from the metal level plans.

What is the outlook for consumers?

Recent policy changes could have wide-reaching implications for Marketplace coverage. As a result of the anticipated expiration of enhanced premium tax credits, out-of-pocket premiums in 2026 are estimated to more than double what subsidized enrollees currently pay annually for premiums, net of tax credits. To help offset these increases, some enrollees may switch to a plan with a higher deductible, while others, such as those with incomes above 400% FPL, who will lose subsidies altogether, may choose to exit the Marketplace.

Changes to HSA eligibility may also influence some Marketplace enrollees’ choice of plan. For plan year 2026, 35% of Marketplace plans sold on HealthCare.gov are HSA-eligible, compared to just 4% in plan year 2025. With all bronze and catastrophic plans now HSA-eligible, some consumers who were enrolled in a gold or silver plan, particularly those with enough income to set some aside into health savings accounts, may choose a bronze or catastrophic plan to take advantage of this change. HSAs offer a triple tax advantage: contributions are tax-deductible; withdrawals are tax-free if used to pay for qualified medical expenses; and investment earnings grow tax-free. Although more people will have access to HSA-eligible HDHPs starting in 2026, higher-income individuals typically have more disposable income to contribute to these accounts than those with lower incomes. Because they are in a higher tax bracket, higher-income enrollees save more money for every dollar contributed to their HSAs. The IRS’s interpretation of the budget reconciliation law’s expansion of HSA eligibility to include off-Marketplace catastrophic and bronze plans may also create new incentives for HSA vendors, who often charge fees for monthly account maintenance, making withdrawals, and other transactions, to market individual plans with HSAs outside the Marketplace.

Additionally, expanded hardship exemptions for catastrophic plans could increase uptake of these plans. The new HealthCare.gov display options for shoppers whose incomes make them ineligible for premium tax credits increase the visibility of catastrophic plans, and the streamlining of the hardship exemption process may make enrolling in these plans easier. More consumers choosing catastrophic plans could have implications for the Marketplace risk pool. To the extent that catastrophic plans pull enough healthy people out of metal level plans or off the Marketplace, premiums for these plans, which would be left with more sick people, could increase in the future.

In an already complex health insurance system, consumer awareness of these policy changes and their implications may be limited. The 2023 KFF Survey of Consumer Experiences with Health Insurance found that many individuals already have trouble understanding various aspects of health insurance. For example, 31% of Marketplace consumers reported difficulty comparing cost-sharing features, and 25% had trouble comparing premiums when presented with different coverage options. The barrage of marketing pitches consumers face during open enrollment (including through internet searches, telemarketing, and social media) can compound the challenges of making an informed decision. Some consumers could unknowingly be directed to off-Marketplace plans, which can be difficult to distinguish from on-Marketplace plans, as the websites can look very similar. While ACA-compliant plans may also be sold off-Marketplace, these websites often also sell non-ACA-compliant plans, which may make plan comparison more difficult for consumers and could result in consumers losing out on premium tax credits who would otherwise be eligible for them if they had purchased a plan on a Marketplace. With few impartial resources, shoppers may feel less confident choosing a plan that best meets their needs or be left with unanswered questions about their specific circumstances.

Lack of understanding of plan options can have far-reaching effects on consumer finances. Price-sensitive consumers shopping for bronze and catastrophic plans can face difficult tradeoffs. While these plans typically have lower premiums than other Marketplace plans, these plans come with higher deductibles. In addition, cost-sharing reductions are only available to enrollees in silver plans. Compared to a bronze plan, a silver plan with cost-sharing reductions often leads to a lower total health expenditure even with a higher premium. If an enrollee has a medical emergency or develops a serious illness, they may be on the hook for substantial out-of-pocket costs. Many Marketplace enrollees are already struggling to afford health care costs. According to a recent KFF poll, about six in ten (61%) Marketplace enrollees report having difficulty affording out-of-pocket costs for medical care. Considering that 37% of all U.S. adults reported that they would not be able to cover a $400 expense with cash or its equivalent—only 5% of the average bronze individual deductible or 4% of the catastrophic individual deductible—many consumers in plans with high deductibles could find themselves scrambling to pay for health care when they need it.

Methods

Premium information for 2026 come from the medical individual market file of the QHP landscape file from CMS for states using the federally-facilitated platform (HealthCare.gov) and from HIX Compare for all other states and the District of Columbia. Analysis of data from HIX Compare assume that all plans are available in all counties in their respective rating areas where the issuer offers at least one plan. To assess plan availability and differences in premiums, county data were weighted by the number of plan selections in 2025. Plan eligibility for health savings accounts was obtained from the plan attributes public use file, which is only available for plans offered on HealthCare.gov

New Trump Administration Proposals Would Further Limit Gender Affirming Care for Young People by Restricting Providers and Reducing Coverage

Published: Dec 22, 2025

On December 18, 2025, the Centers for Medicare and Medicaid Services (CMS) issued two proposed rules that would  further limit youth access to gender affirming care. One rule would change the hospital Conditions of Participation (CoPs) which would prohibit most Medicare and Medicaid enrolled hospitals from providing specified gender affirming medical care for youth (the proposed CoPs rule). The second proposed rule would prohibit federal Medicaid or CHIP funds from covering this care for youth (the proposed Medicaid rule). Despite gender affirming care being considered a best practice model of care and consisting of interventions recommended by major medical associations, if finalized and implemented, the proposed rules would have a sweeping impact, albeit for a small number of young people, significantly limiting their access to these services.  

The rules broadly align with a range of other administrative actions that take a multipronged approach to restrict this care. In particular, the proposed rules follow a January 2025 Executive Order that set a pathway for limiting youth access to gender affirming care and directed the Secretary of Health and Human Services (HHS) to “take all appropriate actions to end” gender affirming care for youth, including in Medicaid, and which specifically identified the CoPs as a possible vehicle for this. Additionally, on April 11, 2025, CMS sent a State Medicaid Director’s letter with the stated purpose of “reminding states of their responsibility to ensure that Medicaid payments are consistent with quality of care and that covered services are provided in a manner consistent with the best interest of recipients” and appearing to encourage states to take steps to limit gender affirming care for youth within their state Medicaid programs. Then, in May 2025, HHS sent a second letter to an unspecified group of providers, state medical boards, and health risk managers urging them to update treatment protocol to move away from provision of gender affirming medical care.

The proposed rules do not take effect immediately. Both have a 60-day comment period following their publication in the federal register. Then, following the comment period, CMS is tasked with considering the comments and could ultimately choose to finalize the proposed rule—either in amended form or as currently written—or elect not to do so. If finalized, both rules will likely face legal challenges, which could further slow implementation.

The Proposed Conditions of Participation (CoPs) Rule

If finalized, the proposed hospital CoPs rule would limit gender affirming care for youth, regardless of payer. The CoPs rule proposes to prohibit certain hospitals (i.e. those covered by section 42 CFR part 482) that accept payments from the Medicare or Medicaid programs from providing identified pharmaceutical and surgical services related to gender affirming care to young people under age 18. Prohibited services would include puberty blockers (which delay the onset of puberty), hormone therapy, and surgery (which is very rare among youth). While these services would be prohibited for the purposes of providing gender affirming care, the rule would permit hospitals to provide them to youth in some scenarios when the service is not intended to affirm a person’s gender.

The changes under the proposed CoPs rule represent a condition based on facility type (not payer) and therefore, if adopted, would prohibit hospitals from offering gender affirming services to all patients under 18 years old, regardless of payer, including youth with private insurance or other coverage and those paying cash, not just those covered by Medicare and Medicaid.  It does not prohibit other types of facilities (e.g. free standing clinics, primary care or specialist providers in other settings) from offering these services (there are a variety of CoPs for providers which are not affected by the proposed CoPs rule).

Hospital Conditions of Participation (CoPs) are currently used to regulate how services can be provided safely and with high quality, rather than prohibiting specific services from being offered altogether. There are a variety of CoPs across different provider types which set standards and requirements, primarily related to quality and safety of care that health care providers must generally meet to participate in and receive reimbursement from Medicare and Medicaid. Hospital CoPs regulate a variety of administrative functions and health care services, including a hospital’s responsibilities to its patients, obligations of the hospital’s governing body, requirements related to emergency preparedness and planning, staffing requirements, minimum medical record requirements, and processes to develop safety procedures and quality improvement plans.  While the proposed rule states that it is offering the revision to existing hospital CoPs regulations to address “the health and safety of children,” there is no medical consensus that gender affirming care represents a safety issue, and using hospital CoPs this way marks a departure from their current function of regulating how services can be performed (e.g., by licensed professionals, with equipment like defibrillators available during surgeries, etc.), rather than which services can be provided.  

Hospital compliance with the CoPs is monitored with detailed surveys conducted by state agencies or accredited organizations (like the Joint Commission on Accreditation of Hospitals). These surveys are conducted during onsite visits to the hospitals; CMS usually gives hospitals time to fix violations.  When hospitals are unwilling or unable to fix violations, CMS issues a termination notice, which happens relatively rarely. Medicare and Medicaid do not reimburse services rendered at terminated hospitals.

If finalized, the rule would apply to most hospitals in the United States. The proposed rule estimates there are a total of “4,832 Medicare/Medicaid certified hospitals” (covered by section 42 CFR part 482) that would be subject to its provisions. The restrictions would also apply to gender affirming care clinics and other clinics if they  operate as a part of a hospital, including at off-campus locations. In 2023, the American Hospital Association identified more than 6,000 hospitals nationwide and it is likely that the large majority of hospitals not covered in the proposed rule and not included in 42 CFR part 482 are facilities such as Critical Access Hospitals and Rural Emergency Hospitals which are small rural facilities that may be less likely to offer gender affirming care. Although the proposal would apply to the large majority of hospitals, it is not clear what share of hospitals currently offer gender affirming care services for youth and many systems have recently stopped offering such services and have cited growing concern about pressure from the federal government (e.g. Los Angeles Children’s cited the “complex and uncertain regulatory environment” and Children’s National the “escalating legal and regulatory risks,” among many other examples).

If the proposed CoPs rule were finalized, most hospitals would be prohibited from providing gender affirming care services for youth.  Although hospitals could in theory stop participating in Medicare and Medicaid to continue providing gender affirming services, it is very unlikely that they would do so given the financial challenges this would present. Nationally, nearly half (44%) of all spending on hospital care comes from Medicare and Medicaid payments. 

Nearly Half (44%) of All Spending on Hospital Care Comes from Medicare and Medicaid Payments

Although the rule would apply broadly to most hospitals, hospitals provide relatively few gender affirming care services and almost no gender affirming surgeries to youth. Accounting for states that already restrict youth access to gender affirming care, the proposed rule estimates the change would impact 8,570 young people. The Williams Institute estimates that there are approximately 724,000 trans identified youth (13-17) in the U.S. This suggests that approximately 1.2% of trans youth in the U.S. receive gender affirming medical services in hospitals and could be impacted by the proposal each year.  As with past research, the CMS finds that most of this care is pharmacologic with surgery being very rare among transgender youth. The proposed rule identifies 85 surgeries in facilities that would be impacted by the rule over the course of one year nationwide. This represents less than 0.0003% of youth under 18 in the United States (based on the denominator of people aged 12 to 18 being 29,600,770 as described in the proposed rule).

Although gender affirming services could still be provided outside of hospitals subject to the proposed CoPs rule, there would be fewer facilities available in a landscape where accessing this care has already become challenging. Many types of gender affirming care sought by young trans people (such as puberty blockers and hormone therapies) can be provided in outpatient settings and therefore received at non-hospital providers. However, patients may need to travel farther and pay more to receive the set of services they need. They may also face challenges finding a specialized pediatric gender clinic offering a cross-specialty integrated care experience as those clinics are often based in hospital settings. Indeed, the proposal states young people may face “difficulty in identifying in-network providers that have available space and longer commute times to these providers” and assumes that 4,285 youth (half of those estimated to be impacted by the proposed rule) would stop receiving care.

The Proposed Medicaid Rule

The proposed Medicaid rule would prohibit the use of federal Medicaid and CHIP funds to cover the specified gender-affirming care services, regardless of the site of care, limiting access for minors who are covered by these programs. The specified services are the same pharmaceutical and surgical services the CoPs proposed rule seeks to bar. Unlike the CoPs proposal, which seeks to limit access at the hospital level (regardless of coverage type), the Medicaid proposal seeks to limit funding for services for youth based on their coverage source (i.e. Medicaid or CHIP) and would therefore restrict reimbursement for care regardless of provider type (e.g. hospitals, primary care providers, endocrinologists, etc.). However, it does not prohibit providers from offering these services. Based on statutory definitions of “minor” the proposed rule would prohibit federal Medicaid reimbursement for this care to those under 18 years of age, while separately administered CHIP programs would limit reimbursement for people through age 18. (CMS is requesting comment on the feasibility of implementing the proposal with these age differences in Medicaid compared to CHIP.) As with the CoPs proposed rule, although Medicaid programs would be prohibited from covering the identified services for gender affirming care with federal funds, programs would be permitted to reimburse for these same services for youth when used for other purposes. Also, similar to the CoPs proposed rule, these health programs could cover other related services such as psychotherapy, which is a common part of gender affirming care services, especially for youth.

Although the proposed rule would prohibit states from using federal Medicaid or CHIP funds to cover gender affirming care, it would not restrict states from covering these services using state-only dollars. It is likely that different states will make different choices about whether or not to cover these services using state funds. Already, some states restrict coverage of gender affirming care in their Medicaid and CHIP programs.

The Medicaid proposed rule (unlike the CoPs proposal) does not offer an estimate on the number of individuals it would impact but it does find that only a very small share of Medicaid/CHIP funds are spent on gender affirming care, likely suggesting low utilization. Although the impact of the proposed Medicaid restrictions would be meaningful for individuals and families, only a very small amount of Medicaid funding is spent on services for which the Medicaid proposed rule would prohibit reimbursement. In the proposed rule, CMS estimates that Medicaid spent about $31 million on the specified services for enrollees aged 18 years and younger in 2023. This represents about 0.003% of all Medicaid spending that year (based on the proposed rule’s spending estimate and FY 2023 total Medicaid spending). Of this total ($31m), CMS finds most of the spending occurred on services provided to older teens, with two-thirds of identified spending (66%) occurring among those 15-18 years old. Notably, this includes some spending for 18-year-olds, some of whom would not be impacted by the proposal. Nonetheless, the agency’s analysis supports the conclusion of other researchers that utilization of gender affirming medical services is relatively rare among adolescents and most spending is nonsurgical. Ninety-two percent (92%) of spending on the specified services for enrollees aged 18 years and younger was nonsurgical and almost all surgical spending (98%) occurred among youth in the 15-18 age group. It is not possible to know how much of this was spent on eighteen-year-olds, a group not impacted by this policy, and the age of majority in most states.

KFF estimates 37% of people under 18 in the United States are covered by Medicaid or CHIP with variation across states. Applying state specific shares of youth enrolled in Medicaid to Williams Institute state level estimates of trans youth (and assuming the coverage distribution among trans youth is similar to youth in general), KFF estimates there to be approximately 270,000 trans youth covered by Medicaid or CHIP. We estimate that, approximately, 138,000 young trans people with Medicaid or CHIP live in a state without a state law prohibiting gender affirming care (and without a state-based Medicaid ban) and could face insurance limitations under the proposed Medicaid rule, if they sought gender affirming care. Notably, not all transgender youth would seek or desire access to the proposed restricted services, and the CoPs rule, along with other research, finds uptake of gender affirming medical services is low. Nonetheless, if finalized, the proposed rule could foreclose on their ability to receive covered care.

While young people with Medicaid and CHIP coverage could theoretically seek care outside of hospitals without using their insurance, the cost of doing so would likely be prohibitive. Families with children covered by Medicaid and CHIP have low to moderate incomes and would face difficulty paying for any uncovered care.

Looking Ahead

As noted earlier, the proposed rules do not take effect immediately. If finalized (following a 60-day comment period), these proposed rules taken together would lead to youth access to gender affirming care being further limited. Patients with the most financial and other supportive resources would have the greatest ability to navigate access (e.g., travel long distances to providers offering these services or have commercial insurance which might cover gender affirming care), whereas those with more limited resources and Medicaid/CHIP coverage, which is by definition insurance for low-income families, could find accessing services the most challenging. The rules would not limit other care for transgender young people.

Losing access to gender affirming care could have meaningful health implications for young people and their families.  Research has demonstrated that young transgender people’s mental health is negatively impacted when this care is denied, including leading to an increased risk of suicidality and that when care is received, well-being is improved. Hospitals with larger gender affirming care programs may also be conducting academic or clinical research on the experiences of and care for young transgender patients. If these hospitals close or limit their services, that may change or eliminate their ability to do this research.

Immediately following their release, the proposals faced criticism from the American Academy of Pediatrics which wrote, “these rules are a baseless intrusion into the patient-physician relationship” and that the association “remains committed to ensuring that all children — including gender-diverse youth and children covered by Medicaid — receive care that is backed by science, delivered with compassion, and offered without political interference.”

There has been significant litigation challenging efforts to limit gender affirming care at both the state and federal level and if finalized, lawsuits challenging these rules would be likely and could happen on multiple grounds (e.g., Constitutional, Administrative Procedure Act (APA), Section 1557 of the Affordable Care Act (ACA), and violations of Medicaid and Medicare statute and/or regulations, etc.). Indeed, the ACLU has already suggested a willingness to challenge these are regulations, stating that “if this administration moves forward with this attempt to enact a national ban on our medical care through coercion, the ACLU will see them in court.” Additionally, multiple state attorneys’ general have stated that they oppose the rule and plan to fight its implementation.

Beyond these two rules, also on December 18th 2025, HHS Secretary Kennedy issued a declaration stating that the same pharmaceutical and surgical  procedures are “neither safe nor effective…and therefore, fail to meet professional recognized standards of health care” (the determination does not apply to these procedures when the service is not intended to affirm a person’s gender). It further noted the HHS Secretary has existing authority to exclude individuals or entities from participation in federal health programs, if the Secretary determines delivered services fail “to meet professionally recognized standards of health care.”  Unlike the two rules, the declaration is not limited to payer (as the Medicaid proposed rule is) or to a specific facility type (as the Conditions of Participation rule is).

On December 24, 2025, a lawsuit was filed in which nearly half of all states challenged the administration’s authority to issue the declaration, claiming it violates the Administrative Procedures Act and the Medicare and Medicaid statutes and that “the Secretary has no legal authority to substantively alter the standards of care and effectively ban, by fiat, an entire category of healthcare.”  On December 30th, HHS announced it had referred at least one hospital to the Office of Inspector General based on the declaration.

Key Data on Health and Health Care for American Indian or Alaska Native People 

Published: Dec 19, 2025

Introduction

American Indian and Alaska Native (AIAN) people experience substantial and enduring disparities in health, health care, and health coverage. While the federal government has a trust responsibility to meet the health care needs of AIAN people, the Indian Health Service (IHS), the primary federal agency charged with upholding the trust responsibility has historically been underfunded and unable to meet their health care needs. AIAN people face challenges accessing health care, including geographic isolation, economic challenges, and limited access to culturally appropriate care that reflect a long history of abuse and mistreatment by the federal government. Proposed cuts to Medicaid could widen health and health care disparities for AIAN people given that Medicaid is a major source of health coverage for AIAN people and funding for IHS and Tribal providers.

AIAN people are often excluded from data and analysis due to smaller population sizes, limiting the visibility and understanding of their health outcomes and the challenges they face in accessing health services and impeding efforts to address their health care needs and reduce disparities. Moreover, aggregate data for AIAN people may mask underlying disparities among Tribes and subgroups of the AIAN population. Data availability may become even more limited going forward, due to the Trump administration’s actions to reduce racial and ethnic data collection and reporting.

To help address gaps in data and information, this brief provides an overview of AIAN people’s health and health care, including by subgroup, where data allow, and differences are statistically significant. It is based on KFF analysis of data from multiple datasets, including the 2019-2023 American Community Survey, the 2023 Behavioral Risk Factor Surveillance System, and the Centers for Disease Control and Prevention (CDC) WONDER online database, as well as the 2023 KFF Survey on Racism, Discrimination, and Health. This report also incorporates analysis from Key Data on Health and Health Care by Race and Ethnicity, which examines 64 measures of health, health care, and social and economic factors that drive health outcomes, across six racial and ethnic groups, including AIAN people. The racial and ethnic group definitions for each table may vary depending on the source of the data. Some data are limited to specific age groups as specified in the notes. Key takeaways include:

AIAN people represent a diverse population, with many identifying with more than one race or ethnicity. As of 2023, approximately 7.2 million people in the U.S. identify as AIAN alone or in combination with another racial or ethnic group. The majority of AIAN individuals identify as AIAN and at least one other race, while about a quarter (1.7 million) identify as AIAN alone. This analysis identifies people based on self-identified race and ethnicity in federal survey data. However, AIAN is also a political and legal classification. This status recognizes over 570 AIAN Tribes as sovereign nations, establishing a government-to-government relationship that dictates the federal government’s trust responsibility, including the provision of health care to AIAN people in federally recognized Tribes.

AIAN individuals experience significant health disparities compared to their White counterparts. People identified as AIAN alone have shorter life expectancies (70.1 vs 78.4 years at birth), higher rates of chronic diseases such as diabetes and asthma, and higher rates of suicide deaths and substance use disorder. About a quarter (26%) of AIAN adults report having fair or poor health status compared to 17% of White adults. Additionally, AIAN people face higher risks during pregnancy, including higher rates of preterm births and infant mortality, as well as the highest rates of pregnancy related deaths across racial and ethnic groups.

Among those under age 65, people who identify as AIAN alone are three times more likely to be uninsured (21%) compared to White people (7%). This coverage gap contributes to challenges in accessing health care. About 22% of adults under age 65 who identify as AIAN alone report not having a personal health care provider, and 43% did not have a dental visit within the past year. Medicaid provides a key source of coverage for AIAN people, helping to mitigate their coverage gaps and serving as the largest third-party payer for the IHS. Medicaid covers roughly one in three (35%) people under age 65 who identify as AIAN alone compared with 15% of their White counterparts, and over half (52%) of AIAN children versus 23% of White children.

AIAN communities face racism and discrimination and substantial social and economic challenges that impact their health outcomes and reflect historical mistreatment and policies. Across measures of discrimination in daily life and health care settings, AIAN adults report the highest frequency of experiencing certain types of discrimination compared to other racial and ethnic groups, while White adults report the lowest frequency. They have a higher poverty rate compared to White people, with about 25% living below the poverty line, and are more likely to experience food insecurity compared to their White counterparts. They also have lower educational attainment levels. Additionally, AIAN people are less likely to own homes and more likely to live in crowded housing conditions compared to White people. These social and economic challenges reflect an array of historical policies implemented by the U.S. government that disadvantaged AIAN communities.

Aggregate data for AIAN people may mask underlying disparities among subgroups since there is a wide variation in experiences and key factors that influence health among AIAN people. Experiences and outcomes vary based on their racial and ethnic composition, where they live, and their Tribal affiliation or Tribal land residency. For example, among AIAN people, uninsured rates and limited English proficiency (LEP) are highest among those who identify as AIAN and Hispanic, creating additional barriers that may impact access to and quality of care. AIAN adults living on Tribal lands are more likely to report having a usual place of care and receiving a flu vaccine (92% and 50%, respectively) compared to AIAN adults living off Tribal lands (82% and 39%, respectively), which may reflect greater proximity to IHS services.

Box 1: Notes on Data and Methods

Components of this analysis are based on data from the 2019-2023 five-year American Community Survey (ACS) and include people who identify as AIAN as defined by the U.S. Census. Except where otherwise specified, we include people who identify as AIAN alone, who are individuals who identify their race solely as AIAN and report non-Hispanic ethnicity.

As noted above, this analysis identifies people as AIAN based on self-identified race and ethnicity. However, AIAN is also a political and legal classification. This status recognizes over 570 AIAN Tribes as sovereign nations, establishing a government-to-government relationship that dictates the federal government’s trust responsibility, including the provision of health care to AIAN people in federally recognized Tribes.

Among AIAN people, data are reported by racial and ethnic subgroup, self-attested Tribal status, Tribal land residency, geographic region, and IHS region, where available, and when differences are statistically significant.

The AIAN racial and ethnic subgroups include AIAN alone, AIAN and White, AIAN and Black, AIAN and Hispanic, AIAN and Asian, and AIAN and two or more other races.

Tribal affiliation is based on whether respondents write the name of an “enrolled or principal tribe” in set aside boxes in the ACS and is only reported among individuals who identify as AIAN alone due to data limitations. In this brief, individuals who report a specific Tribe are defined as Tribally affiliated, and individuals who do not are classified as not Tribally affiliated. People who do not report a Tribe on the ACS may still be Tribally affiliated and not represented in the data.

Tribal land residential status is defined based on whether respondents’ addresses fell within AIAN legal and statistical entities for which the U.S. Census Bureau publishes data. All estimates for Tribal residential status are sourced from a 2023 National Health Statistics Report.

Geographic region is defined using the 4 regions outlined by the U.S. Census Bureau, including the Northeast, Midwest, South, and West.

IHS region is defined using state level groupings commonly used by some federal agencies and in published research. This definition divides the states into six regions: East, Northern Plains, Southern Plains, Southwest, Pacific Coast, and Alaska. While the IHS divides its services into 12 regions, the six-region definition was selected to align with the available geographies in the ACS data file.

Overview of AIAN People in the U.S.

Most AIAN people identify with more than one race and ethnicity. The number of AIAN people who identify with more than one racial or ethnic group has grown over time, likely reflecting some demographic shifts as well as changes in the design of questions used to identify race and ethnicity. As of 2023, there are roughly 7.2 million people in the U.S. who identify as AIAN alone or in combination with another racial or ethnic group. The majority of AIAN people identify as AIAN and at least one other race, while about a quarter of AIAN people identify as AIAN alone (24% or 1.7 million) (Figure 1).

AIAN People Represent a Diverse Population With Many Identifying With More Than One Race or Ethnicity

Overall, about nine in ten (89%) people who identify as AIAN alone indicate they are affiliated with a Tribe, while 11% do not identify a Tribal affiliation (Figure 2). There are over 570 federally recognized Tribes. Tribal enrollment has important implications for access to benefits, since members and descendants of members of federally recognized Tribes have broader access to certain federal programs, including the IHS (Box 2).

Most People Who Identify as AIAN Alone Indicate That They Are Affiliated with a Tribe

Box 2: Overview of the Indian Health Service

The IHS provides health care and disease prevention services to AIAN people through a network of hospitals, clinics, and health stations. In addition to medical care, the IHS provides a wide range of other services, including sanitation and public health functions. In exchange for lands and resources, the federal government provides health services through facilities that are managed directly by the IHS, by Tribes or Tribal organizations under contract or compact with the IHS, and Urban Indian Health programs (UIHP). If facilities are unable to provide needed care, the IHS and Tribes may contract for health services from private providers through the IHS Purchased/Referred Care (PRC) program. However, due to limited funding, services through PRC are often rationed based on medical need, such as emergency care for life-threatening illnesses and injuries. Recent updates to the PRC medical priorities aim to expand coverage for more preventive care services, although some recipients continue to face challenges accessing care. Urban Indian Organizations do not participate in the PRC program and do not receive PRC funding for health services beyond the scope of what they can provide.

Direct services provided through IHS and Tribally operated facilities are generally limited to members or descendants of members of federally recognized Tribes who live on or near federal reservations. Qualified AIAN people receiving services through IHS providers are not charged or billed for the cost of their services. UIHPs serve a wider group of AIAN people, including those who are not able to access IHS or Tribally operated facilities because they do not meet eligibility criteria or because they reside outside their service areas. However, funding to UIHPs is limited to 1% of the IHS budget despite the overall demographic shift of AIAN people away from reservations. To address the needs of AIAN people who live in metropolitan areas, there have been recent recommendations to fully fund UIHP services.

The IHS is a discretionary program with limited funding that relies on Congressional appropriations each fiscal year. This funding process contributes to uncertainty, operations challenges, and, in some cases, disruptions in care if Congress is delayed in passing appropriations. Although the IHS discretionary budget has increased over time, funds are not equally distributed across IHS facilities and remain insufficient to meet health care needs. As such, access to IHS services varies significantly across locations, and AIAN people who rely solely on the IHS often lack access to needed care.

Among people who identify as AIAN alone or in combination, about three in ten (31%) reside in California, Texas, or Oklahoma (Figure 3). The AIAN population is largely concentrated in the Western U.S., at least in part due to forced displacement and relocation (Box 3). The majority of AIAN people (87%) live in metropolitan areas, some live in rural areas, and only 13% reside on reservations or land trusts.

About Three in Ten AIAN People Live in California, Texas, or Oklahoma

Box 3: Historical Mistreatment of AIAN People in the U.S.

The U.S. government has a long history of systemic abuse against AIAN people, including forced historical displacement, broken political treaties, and cultural erasure. Policies like the Indian Removal Act, the establishment of the Federal Indian Boarding Schools, and the Indian Relocation Act of 1956 were aimed to assimilate AIAN people to majority culture and strip them of their Tribes, lands, languages, and their traditions. Further, a history of forced sterilization and policies that separated infants from their families has also eroded trust in health care providers and government institutions.

Health disparities persist due to a lack of data and underfunded health care systems that are rooted in historical neglect and inequities. The legacy of colonization, historical dispossession, and intergenerational trauma continues to impact AIAN communities, worsening health, economic, environmental, and social challenges that reflect ongoing structural inequities and systemic discrimination. Further, differing cultural beliefs and values about health and limited cultural understanding among non-Native providers present additional barriers to accessing health care.

Health Coverage, Access, and Use

Among people under age 65, people who identify as AIAN alone are three times more likely to be uninsured compared to White people (21% vs. 7%) (Figure 4). Among those who identify as AIAN alone, uninsured rates are higher for those who indicate that they are affiliated with a Tribe (23%) compared to those who do not indicate a Tribal affiliation (17%). This may, in part, reflect greater reliance on the IHS for health care among those affiliated with a Tribe. However, the IHS is not insurance, and people relying solely on the IHS may face gaps in care. Among people who identify as AIAN alone or in combination with another racial or ethnic group, uninsured rates are higher among those who identify as AIAN alone (21%) and AIAN and Hispanic (21%), than among those who identify as AIAN and White (11%) (Figure 5). Higher uninsured rates among AIAN people contribute to barriers to accessing and utilizing health care.

Medicaid is a major source of coverage for AIAN people, particularly AIAN children, it is one of the primary ways the federal government honors its federal trust responsibility. Among those under age 65, Medicaid covers over one in three (35%) of those who identify as AIAN alone and nearly one in four (23%) people who identify as AIAN alone or in combination with another race or ethnicity (Figure 5). Medicaid, in combination with the Children’s Health Insurance Program (CHIP), covers over half (51%) of children who identify as AIAN alone. Medicaid is also the largest third-party payer for the IHS, accounting for $1.3 billion out of the total almost $1.8 billion in third-party collections in fiscal year 2025. In contrast to IHS funds, Medicaid funds are not subject to annual appropriation limits and, since Medicaid claims are processed throughout the year, facilities receive Medicaid funding on an ongoing basis for covered services. As such, Medicaid revenues help facilities cover operational costs, including provider payments and infrastructure developments. Notably, during federal government shutdowns, some parts of the IHS that do not receive advance appropriations rely on third-party reimbursement, including Medicaid, to fund services.  

AIAN People are More Likely to be Uninsured Than White People

Uninsured rates among AIAN people vary by where they live. About one in four people under age 65 who identify as AIAN alone and live in the IHS regions of the Southern Plains (26%), Alaska (23%), and the Northern Plains (23%) are uninsured, which is higher compared to other IHS regions (Figure 5). The higher uninsured rate in the Southern Plains region reflects a relatively low rate of Medicaid coverage compared to the national rate (22% vs. 35%), which is largely driven by the fact that two (Texas and Kansas) out of three states in the region have not implemented the Affordable Care Act (ACA) Medicaid expansion to low-income adults. In contrast, the higher uninsured rate in Alaska and the Northern Plains largely reflects a lower rate of private coverage compared to the national rate (31% and 35% vs. 44%). Among people under age 65 who identify as AIAN alone, Medicaid coverage rates are lower in states that have not adopted the ACA Medicaid expansion to low-income adults compared to expansion states (31% vs. 37%). Research finds that while health coverage improved among AIAN people post-ACA, there are stark differences in coverage regionally. In the period following the ACA, AIAN people in the Southwest, West Coast, and Alaska regions experienced the greatest increases in Medicaid and other public health coverage.

Health Coverage Varies Based on Where AIAN People Live

AIAN adults are more likely to report not having a personal provider, not receiving dental care, and not being up to date on their flu vaccine compared to White adults, suggesting barriers to accessing care. About one in five (22%) adults who identify as AIAN alone under the age of 65 report not having a personal provider compared to 16% of White adults (Figure 6). AIAN adults are also more likely to have gone without a dental visit within the past year than White adults (43% vs. 32%) and to not be up to date on their flu vaccine (64% vs. 50%). However, they are not more likely than White adults to report going without a routine check-up in the past 12 months.

AIAN Adults Report Greater Barriers to Accessing Care Than White Adults

Among those who identify as AIAN alone or in combination, those living off Tribal lands generally report more limited health care access and use compared to those living on Tribal lands. AIAN adults who live on Tribal lands are more likely to report having a usual source of care compared to those who live off Tribal lands (92% vs. 82%). About half (50%) of AIAN adults living on Tribal lands report receiving a flu vaccine in the past 12 months compared to about four in ten (39%) AIAN people who live off Tribal lands. About one-third (34%) of AIAN people who live on Tribal lands report having at least one emergency room visit in the past 12 months compared to about a quarter (25%) of AIAN adults who live off Tribal lands. Among AIAN people who live on Tribal lands, 2% report delaying or not receiving mental health treatment due to cost, while 8% of those who live off Tribal lands report the same (Figure 7). The increased access and use of care among those living on Tribal lands may reflect increased access and proximity to IHS or Tribal Health facilities.

AIAN Adults Living on Tribal Lands Report Greater Access and Use of Some Health Services Than Those Living Off Tribal Lands

Health Outcomes

AIAN people have a shorter life expectancy at birth compared to White people (Figure 8). Since 2019, life expectancy has fallen for AIAN people, reflecting the impacts of the COVID-19 pandemic. The existing gap in life expectancy widened between people who identify as AIAN alone and White people from 7 years in 2019 (71.8 vs. 78.8 years) to 8.3 years in 2023 (70.1 years vs 78.4 years).

AIAN Individuals Have Shorter Life Expectancies Compared to Their White Counterparts

Adults who identify as AIAN alone report poorer health status compared to White adults. About a quarter (26%) of AIAN adults report having fair or poor health status compared to 17% of White people, and roughly one in five (22%) AIAN adults report having 14 or more mentally unhealthy days compared to 15% for White people (Figure 9).

About One in Four AIAN Adults Report Fair or Poor Health and About One in Five Report 14 or More Mentally Unhealthy Days

AIAN people fare worse than their White counterparts across multiple measures of birth risks and outcomes. People who identify as AIAN alone have higher shares of preterm births compared to their White counterparts (12% vs. 9%), low birthweight births (9% vs. 7%), and births for which they received late or no prenatal care (13% vs. 5%) (Figure 10). The birth rate among teens who identify as AIAN alone is more than two times higher than the rate for White teens (Figure 11). AIAN infants have a mortality risk that is twice as high as that of White infants (9.2 vs. 4.5 per 1,000 live births) (Figure 12).

AIAN People Fare Worse than Their White Counterparts Across Pregnancy-Related Measures
The Birth Rate Among AIAN Teens is More Than Two Times Higher Than the Rate Among White Teens
AIAN Infants Have a Higher Mortality Rate Than White Infants

Chronic Diseases

AIAN people have higher rates of certain conditions than their White counterparts. Adults who identify as AIAN alone are more likely to have asthma than White adults (15% vs. 10%) (Figure 13). AIAN adults also have higher rates of obesity than White adults. Among children, the prevalence of asthma was not significantly different between AIAN and White children, with 12% of AIAN children and 9% of White children reporting having asthma.

AIAN Adults Have Higher Rates of Asthma Than White Adults

AIAN people have the highest rate of diabetes across racial and ethnic groups, with 18% of adults who identify as AIAN alone reporting being told by a doctor they have diabetes compared to 11% of White adults. Researchers suggest that higher diabetes prevalence among AIAN people may be linked to historical forced relocation, changes to traditional lifestyles, and reliance on government food assistance programs. AIAN people are about two times more likely to die from diabetes compared to White people (41.5 vs. 19.8 per 100,000) (Figure 14). In contrast, AIAN adults have similar rates of heart disease to White adults (8% vs. 7%) and lower heart disease mortality rates than White people (138.3 vs. 169.1 per 100,000). However, it is important to note that race misclassification on death certificates is particularly common for AIAN people and likely leads to underestimates of AIAN mortality rates, with research showing that at least 30% of individuals who identify as AIAN alone are misclassified on their death certificates.

Overall, AIAN People are Twice as Likely to Die From Diabetes Than White People But are Less Likely to Die From Heart Disease

Rates of diabetes and heart disease mortality vary by census region among people who identify as AIAN alone. Geographically, among AIAN people, rates of death due to diabetes range from 19.6 per 100,000 in the Northeast to 54.1 per 100,000 in the Midwest. Heart disease deaths range from 69.7 per 100,000 in the Northeast to 151.2 per 100,000 in the Western U.S. (Figure 15). Regional differences in mortality could in part reflect differences in health coverage and access in each region. However, a range of other factors may contribute to regional differences, including environmental, lifestyle, and socioeconomic factors.

Rates of Deaths by Chronic Diseases Vary by Region For AIAN Adults

AIAN people are more likely than White people to be diagnosed with HIV or AIDS, the most advanced stage of HIV infection. In 2022, the HIV diagnosis rate for people who identify as AIAN alone was about two times higher than the rate for White people (10.6 vs. 5.3 per 100,000). Similar patterns are observed in AIDS classification rates, the most advanced stage of HIV, reflecting barriers to treatment. People who identify as AIAN alone have higher AIDS classification rates than White people (4.1 vs. 2.3 per 100,000) (Figure 16).

AIAN People are More Likely Than White People to be Diagnosed with HIV or AIDS

Cancer

Differences in rates of cancer incidence are mixed between AIAN and White adults. People who identify as AIAN alone have lower rates of cancer incidence than White people overall, and across most leading types of cancer examined. However, AIAN people have higher incidence rates of colon and rectum cancer than White people (43.3 vs. 36.0 per 100,000) (Figure 17). Further, other data show that AIAN people have the highest rates of liver cancer incidence across racial and ethnic groups.

AIAN People Have Lower Rates of Cancer Incidence Than White People For Most Leading Types of Cancer

Cancer incidence rates among people who identify as AIAN alone vary across IHS regions. Rates of cancer incidence range from 304.4 per 100,000 in the Southwest to 635.3 per 100,000 in the Southern Plains (Figure 18). Rates of lung and bronchus, and prostate cancer are highest in the Northern Plains (105.9 and 128.8 per 100,000, respectively) and lowest in the Southwest (15.4 and 57.1 per 100,000, respectively). Alaska Native people have the highest colorectal cancer incidence and mortality rates in the world, which may in part be due to lower receipt of screening. This regional variation may reflect a variety of environmental, lifestyle, and socioeconomic factors.

Rates of Cancer Incidence Vary by Type and Across Region Among AIAN People

Consistent with their lower incidence rates, AIAN people have lower rates of cancer mortality than White people for all cancers as well as across most leading cancer types (Figure 19). However, as of 2023, people who identify as AIAN alone and White people have similar rates of death due to colon and rectum cancer (13.1 and 13.0 per 100,000, respectively).

AIAN People Have Lower Rates of Overall Cancer Mortality Than White People

Suicide and Substance Use Disorder

AIAN people have the highest rates of deaths by suicide across all racial and ethnic groups. In 2023, people who identify as AIAN alone have higher rates of deaths by suicide than White people (23.8 vs. 17.6 per 100,000) (Figure 20). Additionally, AIAN adolescents have the highest rates of deaths by suicide across all racial and ethnic groups. Research finds that suicide is the second leading cause of death for high school-aged AIAN adolescents. Rates of deaths by suicide increased by 139% for AIAN adolescent females and 71% for AIAN adolescent males between 1999 and 2017, however, recent data show that these rates declined between 2021 and 2023. Studies have shown that the high rates of suicide are associated with AIAN youths’ high likelihood of having adverse childhood experiences combined with historical intergenerational trauma as a result of colonization and structural discrimination.

AIAN People Have Higher Rates of Death by Suicide Compared to Their White Counterparts

Deaths by suicide vary by region among people who identify as AIAN alone. AIAN people in the Western U.S. experience the highest rate of deaths by suicide (31.6 per 100,000), while AIAN people in the Northeast experience the lowest rate of deaths by suicide (9.6 per 100,000) (Figure 21). Deaths by suicide are higher among AIAN people than White people in all regions except the Southern U.S.

Deaths by Suicide Vary by Region Among People Who Identify as AIAN Alone

AIAN people report the highest prevalence of substance use disorder (SUD) in the past year compared with other racial and ethnic groups. AIAN people also experience the highest rates of drug overdose death, including the highest rates of opioid-related deaths in 2023. The high rates of opioid-related deaths likely reflect the low uptake of medication treatment services among AIAN people. Among those ages 12 years and older, over a quarter (27%) of people who identify as AIAN alone report experiencing substance use disorder in the past year, compared to 19% of White people (Figure 22). Similar shares of AIAN people (12%) and White people (14%) report experiencing alcohol use disorder.

About A Quarter of AIAN People Report Experiencing a Substance Use Disorder

AIAN people are about twice as likely to die from a drug overdose compared to White people (65 vs. 33.1 per 100,000) in 2023 (Figure 23). Alcohol-induced deaths are also higher among people who identify as AIAN alone in 2023 compared to White people. AIAN people have the highest rate of alcohol-induced deaths and the fastest growing rate of alcohol-induced deaths compared to other racial and ethnic groups, nearly doubling in the past 10 years. Increases in alcohol deaths among AIAN people follow worsening trends in other areas related to behavioral health, where AIAN people have both the highest and fastest-growing rates of suicide and overall drug overdose deaths.

AIAN People Have Higher Death Rates Due to Drug Overdose and Excessive Alcohol Use Compared to White People

Experiences with Racism and Discrimination

Racism is an underlying driver of health disparities. Research has shown that exposure to racism and discrimination can lead to negative mental health outcomes and certain negative impacts on physical health, including depression, anxiety, and hypertension. Across measures of discrimination in daily life and health care settings, AIAN adults report the highest frequency of experiencing certain types of discrimination compared to other racial and ethnic groups, while White adults report the lowest frequency.

AIAN adults are more likely to report certain experiences with discrimination in daily life compared with their White counterparts. Based on KFF survey data from 2023, more than a quarter of AIAN adults (28%) say that they received poorer service than other people at restaurants or stores at least a few times in the past year, higher than the share of White adults who say the same (16%) (Figure 24). Similarly, about four in ten (42%) AIAN adults say that people have acted as if they think they are not smart at least a few times in the past year, higher than the one-quarter (26%) of White adults who say the same. Further, about one in five (19%) AIAN adults say people acted as if they were afraid of them at least a few times in the past year, compared to 9% of White adults. Cumulatively, at least half of AIAN (58%) adults say they have experienced one of these forms of discrimination at least a few times in the past year compared to about four in ten (38%) White adults (Figure 24).

AIAN Adults Are More Likely Than White Adults to Report Experiences of Discrimination

AIAN adults report having less frequent positive and respectful interactions with health care providers than White adults. KFF survey data from 2023 also show that AIAN adults (18%) are about twice as likely as White adults (8%) to say their health care providers explained things in a way they could understand just some of the time, rarely, or never in the past three years. Similarly, about one in four AIAN adults (24%) say their health care providers understood and respected their cultural beliefs just some of the time, rarely, or never, compared with about one in ten White adults (12%). They also are more likely than their White counterparts to say their providers did not frequently involve them in decision-making about their care during their visits in the past three years (Figure 25).

AIAN Adults Report Less Frequent Positive Interactions With Health Care Providers Than White Adults

Social and Economic Factors that Influence Health

There is wide variation in the share of AIAN people reporting LEP among racial and ethnic subgroups. Among people who identify as AIAN in combination with another race or ethnicity, LEP ranges from 30% of people who identify as AIAN and Hispanic to one percent or less of AIAN and Black, and AIAN and White people (Figure 26).  Having LEP can contribute to difficulty accessing health coverage and care and negatively impact quality of care and health outcomes.

English Proficiency Varies Across AIAN Racial and Ethnic Subgroups

AIAN people have lower educational attainment than their White counterparts, but there is significant variation among AIAN people by racial and ethnic subgroups. Among adults ages 25 and older, 16% of people who identify as AIAN alone have a bachelor’s degree or higher, compared to 39% of White people. The share with a bachelor’s degree or higher is similar among those who identify as AIAN and Hispanic (17%), but it rises to over a quarter among those who are AIAN and Black (26%), and AIAN and White (27%), and to over four in ten (42%) of those who identify as AIAN and Asian. Additionally, AIAN people living off Tribal lands are twice as likely to have a bachelor’s degree or higher compared to AIAN people who live on Tribal lands (18% vs. 9%) (Figure 27). Researchers have found that some of the educational attainment gap can be explained by a lack of culturally relevant coursework in traditional educational settings.

About One in Six AIAN People Have a Bachelor's Degree or Higher

While most people who identify as AIAN alone are in a working family, they are less likely than White people to live in a family with at least one worker (85% vs. 95%). The share living in a working family also varies among AIAN people by racial and ethnic subgroup. More than eight in ten AIAN people who identify as AIAN alone (85%) or AIAN and Black (87%) are part of a working family, while more than nine in ten people who identify as AIAN and Hispanic (95%) and as AIAN and Asian (94%) live in a working family (Figure 28).

More Than Eight in Ten AIAN People Live in a  Family With At Least One Worker

AIAN people are more likely than White people to live in a family with an income below poverty, although there is variation among racial and ethnic subgroups of AIAN people. Among AIAN people, poverty rates are lower among those who identify as AIAN and Asian (11%), and AIAN and White (14%), while they rise to about one in five among AIAN and Hispanic (18%) people and about a quarter among AIAN and Black (23%) people, and people who only identify as AIAN alone (25%) (Figure 29).

Poverty Rates Vary Among AIAN People by Racial and Ethnic Subgroup

AIAN people are nearly twice as likely to experience food insecurity compared to their White counterparts. People who identify as AIAN alone (23%) are more likely to be in a household that experienced food insecurity compared to White people (12%) (Figure 30).  Food insecurity among AIAN people is closely linked to historical federal policies that removed and relocated AIAN people and disrupted their connection to traditional lands, foods, and cultural practices.

Food Insecurity Rates Are About Twice as High Among AIAN People Compared to Their White Counterparts

AIAN people are less likely to own a home than White people (62% vs. 77%). Lower rates of homeownership among AIAN people may reflect insufficient housing supply and a lack of access to affordable capital. Rates of home ownership vary among AIAN people by racial and ethnic subgroup. Nearly seven in ten AIAN and White (69%) people own a home, while about six in ten people who identify as AIAN alone (62%), and people who identify as AIAN and Asian (62%) own a home. The home ownership rate drops to about half or lower among people who identify as AIAN and Hispanic (52%) or AIAN and Black (43%) (Figure 31).

AIAN Households Have Lower Homeownership Rates Than White Households

AIAN people are more likely to live in “crowded” housing compared to White people. About 16% of people who identify as AIAN alone and one in ten (12%) people who identify as AIAN alone or in combination with another race or ethnicity report living in crowded housing, compared to 3% of White people. “Crowded housing” is defined as housing with more than one occupant per room (not counting bathrooms, porches, balconies, hallways, or unfinished basements, etc.). Among AIAN people, the share of people living in crowded housing ranges from 5% for people who identify as AIAN and White to about one in five (22%) for people who identify as AIAN and Hispanic (Figure 32). Living in multigenerational households is more common among AIAN people, and family connection is important to health and well-being, which may contribute to higher shares reporting “crowded housing” arrangements and may reflect cultural preferences or choices rather than a housing challenge.

AIAN People Are More Likely Than White People to Live in Crowded Housing

Emerging research also highlights a number of protective social factors that can support better health outcomes in AIAN communities. Strong family and community networks, access to culturally competent care, the prioritization of traditional food systems, and the preservation of language and cultural practices have all been shown to promote resilience and improve well-being. Strengthening these protective factors alongside efforts to address structural barriers can help reduce health disparities for AIAN people.