U.S. International Family Planning & Reproductive Health: Requirements in Law and Policy

Published: Jun 2, 2026

This fact sheet summarizes the major statutory requirements and policies pertaining to U.S. global family planning/reproductive health (FP/RH) efforts over time and identifies those currently in effect. These laws and policies collectively serve to direct how U.S. funds are spent, to where and which organizations funds are provided, and generally shape the implementation and define the scope of U.S. global FP/RH activities. It includes U.S. laws and annual requirements enacted by Congress through appropriations bills (statutory provisions) as well as executive branch policies and guidance specific to FP/RH (policy provisions). Each category lists provisions in chronological order.

Since early 2025, the Trump administration has frozen or eliminated funding for most FP/RH activities, although Congress has continued to appropriate funding for this work. See the KFF fact sheet of the status of FP/RH efforts.

Table 1

Statutory Requirements and Policies for U.S. Global FP/RH Efforts (as of FY 2026)

Provision (Year First Instituted)Issue(s)Applies toStatus
STATUTORY
Helms Amendment (1973)
Prohibits the use of foreign assistance to pay for the performance of abortion as a method of family planning or to motivate or coerce any person to practice abortion. Note: meaning of “motivate” clarified by Leahy Amendment (1994); see below.
Abortion

All foreign assistance authorized under the Foreign Assistance Act of 1961(FAA); all funds under State-Foreign Operations Appropriations (State-Foreign Ops.)Yes, in effect.
Permanent law, amendment to the FAA.
Also included in annual State-Foreign Ops.
Involuntary Sterilization Amendment (1978)
Prohibits the use of funds to pay for involuntary sterilizations as a method of family planning or to coerce or provide a financial incentive to anyone to undergo sterilization.
Voluntarism/
Informed Choice & Consent; Incentives; Involuntary Sterilization
All foreign assistance authorized by the FAA of 1961; all foreign assistance funds under State-Foreign Ops.Yes, in effect.
Permanent law, amendment to the FAA.
Also included in annual State-Foreign Ops.
Peace Corps Provision (1978)
Prohibits Peace Corps funding from paying for an abortion for a Peace Corps volunteer or trainee; beginning in FY 2015, allows for payment in cases where the life of the woman is endangered by pregnancy or in cases of rape or incest.1
AbortionAll Peace Corps fundingYes, in effect.
Included under the “Peace Corps” heading of the State-Foreign Ops.
Biden Amendment (1981)
States that funds may not be used for biomedical research related to methods of or the performance of abortion or involuntary sterilization as a means of family planning.
Abortion; Involuntary SterilizationAll foreign assistance authorized by the FAA of 1961; all foreign assistance funds under State-Foreign Ops.Yes, in effect.
Permanent law, amendment to the FAA.
Also included in annual State-Foreign Ops.
Siljander Amendment (1981)
Prohibits the use of funds to lobby for or against abortion. When initially introduced, the amendment prohibited only lobbying for abortion, but in subsequent years Congress modified the language to include lobbying against abortion as well.
AbortionAll funds under State-Foreign Ops.
 
Yes, in effect.
Included in annual State-Foreign Ops.
DeConcini Amendment (1985)
Requires that U.S. funds be provided to organizations that offer, either directly or through referral to, information about access to a broad range of family planning methods and services. See Livingston-Obey Amendment (1986) below.
Voluntarism/
Informed Choice
All FP funds under State-Foreign Ops.Yes, in effect.
Included in annual State-Foreign Ops.
Kemp-Kasten Amendment (1985)
Prohibits funding any organization or program, as determined by the President, that supports or participates in the management of a program of coercive abortion or involuntary sterilization.
UNFPA Funding; Abortion; Voluntarism/
Informed Choice & Consent; Involuntary Sterilization
All funds under State-Foreign Ops. as well as unobligated balances from prior appropriations actsYes, in effect.
Included in annual State-Foreign Ops.2 each year; Presidents determined that it applied to UNFPA in FY85-FY92, FY02-FY08, FY17-FY20, FY25.
Involuntary Sterilization and Abortion Provision (1985)
Specifies that U.S. foreign assistance funding could be withheld from a country or organization if the president certifies that the use of such funds would violate key provisions of the FAA of 1961 related to abortion or involuntary sterilization (namely the Helms, Biden, and Involuntary Sterilization Amendments).
Voluntarism/
Informed Choice & Consent; Incentives; Abortion; Involuntary Sterilization
All foreign assistance funds under State-Foreign Ops.
 
Yes, in effect.
Included in annual State-Foreign Ops.
Livingston-Obey Amendment (1986)
Prohibits discrimination by the U.S. government against organizations that offer only “natural family planning” for religious or conscientious reasons when the U.S. government is awarding related grants. All such applicants must comply with the requirements of the DeConcini Amendment (1985).
Voluntarism/
Informed Choice
All FP funds under State-Foreign Ops.
 
Yes, in effect.
Included in annual State-Foreign Ops.
Leahy Amendment (1994)
Clarifies Helms Amendment (1973) language that uses the term “motivate” by stating that “motivate” shall not be construed to prohibit, where legal, the provision of information or counseling about all pregnancy options.
Abortion; Voluntarism/
Informed Choice
All authorizing and appropriating legislation related to the State Dept., foreign operations, and related programsYes, in effect.
Included in annual State-Foreign Ops.
Timing of Release of UNFPA Contribution Funds (1994)
Not more than half of funding designated for the U.S. contribution to UNFPA is to be released before a particular date (varies by fiscal year).
UNFPA FundingFunds made available to UNFPANo, not in effect.
Sometimes included in annual State-Foreign Ops.
Conditions on Availability of UNFPA Funds (UNFPA Segregated U.S. Contribution Account; UNFPA Does Not Fund Abortions; Prohibition on the Use of U.S. Funds in China by UNFPA) (1994)
States that funds may not be made available to UNFPA unless:
– UNFPA keeps the U.S. contribution to the agency in a separate account, not to be commingled with other funds, and
– UNFPA does not fund abortions (note: language used beginning in FY00).
It also prohibits UNFPA from using any funds from the U.S. contribution in their programming in China.
UNFPA Funding; AbortionFunds made available to UNFPAYes, in effect.
Included in annual State-Foreign Ops.
UNFPA Dollar-for-Dollar Withholding of Amount UNFPA Plans to Spend in China During Fiscal Year (1994)
Reduces the U.S. contribution to UNFPA by one dollar for every dollar that UNFPA spends on its programming in China.
UNFPA FundingFunds made available to UNFPAYes, in effect.
Typically included in annual State-Foreign Ops.
Tiahrt Amendment (1998)
Prohibits the use of targets/quotas and financial incentives3 in family planning projects and requires projects to provide comprehensible information on family planning methods. Protects people who choose not to use family planning from being denied rights or benefits and requires experimental family planning methods be provided only in the context of a scientific study. Intended to “promote voluntarism and prevent coercion in family planning programs,” it specifically prohibits three types of targets: total number of births, number of family planning acceptors, and acceptors of a particular method of family planning.4
Voluntarism/
Informed Choice & Consent; Incentives and Disincentives
All FP funds under State-Foreign Ops.
 
Yes, in effect.
Included in annual State-Foreign Ops.
Reallocation of Funds Not Made Available to UNFPA (2004)
Provides for funds not made available to UNFPA to be reallocated to USAID’s family planning, maternal, and reproductive health activities/services (and, in some years, assistance to vulnerable children and victims of trafficking in persons).5
UNFPA FundingFunds appropriated for UNFPAYes, in effect.
Typically included in annual State-Foreign Ops.
Medically Accurate Information on Condoms (2005)
Ensures that information provided by U.S.-supported programs about the use of condoms is medically accurate information and includes the public health benefits and failure rates of such use.
CondomsAll funds under State-Foreign Ops.
 
Yes, in effect.
Typically included in annual State-Foreign Ops.
POLICY
USAID Policy Paper on Population Assistance (1982)
Outlines the longstanding USAID guidelines surrounding its fundamental programmatic principles of voluntarism and informed choice and consent.6
Voluntarism/
Informed Choice & Consent
All FP/RH assistance provided by USAIDNo longer in effect due to USAID’s dissolution.
Policy Determination 3 (PD-3): USAID Policy Guidelines on Voluntary Sterilization (1982)
Describes guidelines for informed consent and voluntarism specifically for voluntary sterilization services, including provisions to ensure ready access to other contraceptive methods and prohibiting incentive payments that might induce a person to select voluntary sterilization over another method.
Voluntarism/
Informed Choice & Consent; Voluntary Sterilization
All FP/RH assistance provided by USAIDNo longer in effect due to USAID’s dissolution.
Mexico City Policy (“Global Gag Rule”, 1984)7
As a condition for receiving U.S. family planning assistance, other global health assistance, and, now, also other U.S. foreign assistance (see “Applies to”), requires foreign NGOs and, now, U.S. NGOs, international organizations, foreign governments, and parastatals to certify that they will not provide or promote abortion as a method of family planning using funds from any source.
 
The latest iteration of the policy under the second Trump administration iss called Protecting Life in Foreign Assistance and falls under the broader umbrella of the “Protecting Human Flourishing in Foreign Assistance Policy” (PHFFA Policy), which also requires certain organizations to certify they will not provide or promote “gender ideology” and “discriminatory equity ideology,” among other activities.. Included in the U.S. Department of State Standard Terms and Conditions (see entry below), when applicable.
 
 
Abortion1984- 2003: when in effect, was applied to FP assistance at USAID only. In 2003, expanded to include all FP assistance at USAID and the State Dept., exempting multilateral organizations and HIV/AIDS funding under PEPFAR. 2009-17: Not in effect.
2017-2021: applied to all global health assistance.
2021-2025t: Not in effect.
2025-present: applied to most foreign assistance at the State Department.
Yes, in effect.8
USAID Post-Abortion Care Policy (2001)
Clarifies that post-abortion care – the treatment of injuries or illnesses caused by legal or illegal abortion – is permitted under the Helms Amendment and that any restrictions under the Mexico City Policy, when in force, do not limit organizations from treating injuries or illnesses caused by legal or illegal abortions (i.e., providing post-abortion care). Notes USAID does not finance manual vacuum aspiration equipment purchase/distribution for any purpose.
Post-Abortion CareAll FP/RH assistance provided by USAIDNo longer in effect due to USAID’s dissolution; however, the current Mexico City Policy does not restrict post-abortion care.
Guidance on the Definition and Use of the Global Health Programs Account: Section on Allowable Uses of Funds for Family Planning/Reproductive Health (2014)
Outlines allowable uses of funds for FP/RH by providing a description of activities allowed and examples of activities not allowed, addressing not only FP/RH activities but also family planning activities’ integration with other global health and multisectoral activities.
FP/RH Activities; FP/RH System Strengthening Activities; Integrated FP ActivitiesAll FP/RH assistance provided by USAIDNo longer in effect due to USAID’s dissolution.
USAID Standard Provisions for Nongovernmental Organizations (U.S. and Non-U.S.)
Outline requirements that must be attached to assistance agreements, including language implementing FP/RH legal and policy requirements described above (e.g., the Helms and Leahy Amendments.)9
 
Voluntarism/
Informed Choice & Consent; Incentives; Abortion; Involuntary Sterilization; Condoms; FP/RH Activities
USAID assistance agreementsYes, in effect in ongoing USAID award agreements with NGOs.
U.S. Department of State Standard Terms and Conditions (revised 10/01/2025)
Outline requirements that must be attached to assistance agreements, including language implementing FP/RH legal and policy requirements described above (e.g., the Helms and Siljander Amendments.)10
 
Includes the Promoting Human Flourishing in Foreign Assistance Policy (PHFFA Policy) – in effect as of Feb. 26, 2026 – for foreign NGOs, U.S. NGOs, international organizations, and, when applicable, foreign governments and parastatals.
Voluntarism/
Informed Choice & Consent; Incentives; Abortion; Involuntary Sterilization; FP/RH Activities
State Department assistance agreementsYes, in effect.
  1. As noted in CRS, Abortion and Family Planning-Related Provisions in U.S. Foreign Assistance Legislation and Policy, July 2022: “No restrictions exist on funding for the medical evacuation of Peace Corps volunteers who decide to have an abortion. Under existing policy, the Peace Corps covers the cost of evacuation to a location where ‘medically adequate facilities’ for obtaining an abortion are available and where abortions are legally permissible.” ↩︎
  2. In most recent years, a provision is included requiring that any Kemp-Kasten determination that is made must be accompanied by the evidence and criteria used to make the determination. ↩︎
  3. USAID defines a target/quota as “a predetermined figure that a service provider or referral agent is assigned or required to affect or achieve” for the purposes of the Tiahrt Amendment. It states that “the key to interpreting ‘incentives’ is to see whether they are provided in exchange for accepting a method (in the case of a client) or linked to achievement of a predetermined target or quota (in the case of program personnel).” USAID Global Health eLearning Center, “FP Legislative & Policy Requirements (Updated),” online course, February 2009, authored by Debbie Gueye, MSI. ↩︎
  4. USAID Global Health eLearning Center, “FP Legislative & Policy Requirements (Updated),” online course, Feb. 2009, authored by Debbie Gueye, MSI. ↩︎
  5. Although such reallocation began in practice in FY 2002, it was first authorized by Congress in legislation beginning in FY 2004 with reference to FY 2002 and FY 2003 funds. ↩︎
  6. Informed Choice: Effective access to information on family planning choices and to the counseling, services, and supplies needed to help individuals choose to obtain or decline services; to seek, obtain, and follow up on a referral; or simply to consider the matter further. Voluntarism: Decision to use a specific method of family planning or to use any method of family planning is based upon the exercise of free choice and is not obtained by any special inducements or any element of force, fraud, deceit, duress or other forms of coercion or misrepresentation. USAID Global Health eLearning Center, “FP Legislative & Policy Requirements (Updated),” online course, Feb. 2009, authored by Debbie Gueye, MSI. ↩︎
  7. This policy was first instituted via presidential memorandum in 1984 by President Reagan. In 1993, it was rescinded by President Clinton, although it was briefly applied legislatively in 1999 (see “Status” column). In 2001, it was reinstated by President Bush, who expanded its applicability in 2003 to include family planning funds at the State Department (see “Applies to” column) with some exemptions. In 2009, it was rescinded by President Obama. In 2017, it was reinstated by President Trump, who expanded its applicability to include the vast majority of global health assistance furnished by all departments and agencies. In 2021, it was rescinded by President Biden. ↩︎
  8. Note that, with one exception, has been applied via Executive action. The exception was in FY 2000, when President Clinton agreed to a one-year legislative codification with a partial waiver of restrictions as part of a broader arrangement to pay the U.S. debt to the United Nations. See P.L. 106-113, Sec. 599D, and PAI, Global Gag Rule Timeline, July 12, 2011. ↩︎
  9. “M16. VOLUNTARY POPULATION PLANNING ACTIVITIES – MANDATORY REQUIREMENTS (MAY 2006) …
    b. Prohibition on Abortion-Related Activities:
    (1) No funds made available under this award will be used to finance, support, or be attributed to the following activities: (i) procurement or distribution of equipment intended to be used for the purpose of inducing abortions as a method of family planning; (ii) special fees or incentives to any person to coerce or motivate them to have abortions; (iii) payments to persons to perform abortions or to solicit persons to undergo abortions; (iv) information, education, training, or communication programs that seek to promote abortion as a method of family planning; and (v) lobbying for or against abortion. The term “motivate,” as it relates to family planning assistance, must not be construed to prohibit the provision, consistent with local law, of information or counseling about all pregnancy options.
    (2)No funds made available under this award will be used to pay for any biomedical research which relates, in whole or in part, to methods of, or the performance of, abortions or involuntary sterilizations as a means of family planning. Epidemiologic or descriptive research to assess the incidence, extent, or consequences of abortions is not precluded.” ↩︎
  10. For example, one provision related to abortion included in the State Department Standard Terms and Conditions is:
    “AA. Prohibition on use of funds for performance or research respecting abortions or involuntary sterilization
    The recipient agrees that in accordance with 22 USC 2151b(f) Population planning and health programs no foreign assistance funds provided by the award shall be used to:
    (1) pay for the performance of abortions as a method of family planning or to motivate or coerce any person to practice abortions (Helms Amendment, 1973).
    (2) pay for the performance of involuntary sterilizations as a method of family planning or to coerce or provide any financial incentive to any person to undergo sterilizations (Involuntary Sterilization Amendment, 1978).
    (3) pay for any biomedical research which relates, in whole or in part, to methods of, or the performance of, abortions or involuntary sterilization as a means of family planning (Biden Amendment, 1981).
    Furthermore, the recipient agrees in accordance with the Department’s annual appropriation bill, that no funds provided by the award may be used to lobby for or against abortion (Siljander Amendment, 1981).” ↩︎

The Business of Health with Chip Kahn

Is AI Better for Patients?

June 2, 2026

Video

Audio

About this Episode


Episode 6, AI Series: Is AI Better for patients? What is changing on the ground? Chip talks with Dr. Patrick Conway, Chief Executive Officer of Optum, a health services and technology business under parent company, UnitedHealth Group. They discuss how to ensure the health care industry’s use of AI serves patients first, particularly when the same company bears financial risk and builds the AI that decides who gets care. They also discuss whether use of AI can make value-based care the dominant payment framework, after two decades of policymaker support for the model.

The Host


Headshot photo of Chip Kahn wearing a navy blue suit with a red tie, red pendant on lapel, and glasses.

Sr. Visiting Fellow

Charles N. Kahn III is a senior visiting fellow at KFF. He is also a visiting senior fellow at the American Enterprise Institute and a nonresident senior scholar at the University of Southern California’s Schaeffer Center for Health Policy & Economics. He serves as co-chair of the international Future of Health collaborative.

Guest


Chief Executive Officer of Optum

Dr. Patrick Conway is the Chief Executive Officer of Optum. He served previously as CEOs of Optum Health, Optum RX, and Care Solutions at Optum. Before joining Optum, Dr. Conway was president and chief executive officer of Blue Cross and Blue Shield of North Carolina. He also previously served as Deputy Administrator for Innovation and Quality at the Centers for Medicare and Medicaid Services and as director of the Center for Medicare and Medicaid Innovation and the agency’s Chief Medical Officer. Before joining CMS, he oversaw clinical operations and quality improvement at Cincinnati Children’s Hospital Medical Center.

Transcript


AI Usage Disclosure: This transcript was created with assistance from AI tools. It was reviewed and edited by KFF Staff.

Chip Kahn: Now we move from the health system actually deploying AI inside its hospitals to the health care company doing it across the full stack. One organization bearing the financial risk for care, delivering that care, building the AI that informs coverage decisions, and running the analytics that tie it all together. My guest today is Dr. Patrick Conway, CEO of Optum. No one else in American health care has occupied all four of Patrick’s positions. Regulator at CMS; payer at Blue Cross, North Carolina; pharmacy benefit operator at Optum Rx; and now the head of Optum itself. He designed the value-based payment models. Now he runs the platform meant to deliver them at scale. UnitedHealth is spending at least $1.5 billion on AI. But Patrick will walk us through what is changing on the ground: prior authorizations cleared in seconds; claims are adjudicated while the patient is still in the exam room; and, a true outcomes orientation. At the heart of this conversation, two questions sit alongside the proof points. First, when the same company bears financial risk and builds the AI that decides who gets care, how do you ensure the technology serves the patient first? And second, after two decades of policymaker support for value-based care, particularly in Medicare, can integration and AI finally make it the dominant payment framework? Below all of this sits the test each episode in this series returns to: is the patient better off? Not in the aggregate, but when receiving care in the examination room or the hospital bed. Let’s get started. Patrick Conway, welcome to KFF’s The Business of Health with Chip Kahn.

Patrick Conway: It’s great to be here, Chip.

Chip Kahn: This is great. Such a pleasure. We’ve worked together over the years and known each other for a long, long time and it’s just great to have you here. Before we get into AI and healthcare, although I think this question may touch on that, you were one of the key people that is responsible for designing value-based care and value-based payment models at CMS. Later, you ran the North Carolina Blue Cross plan and now you run the largest integrated health services company within the largest private health insurer in the world. What have you seen from the inside at Optum that you could not see from your earlier vantage points?

Patrick Conway: So, a few thoughts, Chip, and appreciate you having me in the discussion. At a high level, and then I’ll come back to the different stages. You need predictability, you need incentives aligned with total cost of care, quality and experience. And you need the ability to innovate and drive care at the front line on behalf of patients. So then let me take you through the stages that you alluded to and reflect on them. I started in CMS, I was in government twice, the second time through 2011, and then ran the CMS Innovation Center after serving as Chief Medical Officer. As you remember, we had almost zero percent of payments in value-based care models tied to total cost of care quality experience. At that time, you’re launching the ACO program, you’re launching these new CMMI models. The question was, would people participate? Participation went up, we got to over 30% participation by the end of 2016, ahead of schedule. It was a target President Obama had set. Then you’ve seen phases in the public sector, okay, now let’s move to two-sided risk. Now let’s do mandatory models when necessary. Now let’s figure out what’s working and expand those models, and you know, iterate on models. So that’s sort of the public sector side. You know, as I moved into the private sector, at Blue Cross, North Carolina, we actually went from almost 0% of payments in those kinds of models to 70 plus percent in about 18 months. And it was built on some of the lessons—I didn’t plan this out—but from the Innovation Center of partnering, of sharing data, of predictability, of saying, you know, fee for service is not what we want to do. We want to move to this value-based care model that’s integrated. And then at Optum, as you allude to, I’m sure we’ll talk more about this, you know, we have the ability of having the people, resources, and technology to deliver value-based care at scale. So, we serve millions of people across the country. Hospitalizations go down, most models in the high teens, less hospitalizations, unplanned ER visits go down, total cost of care improves significantly, quality 4-star plus in the vast majority of models and NPS or patient experience usually in the 80s to 90s so very high in these models. And I know you like data and stories I’ll share. You know, you see a 91-year-old in her home—this is a visit I went on—used to be hospitalized the year before, 10 plus times. Now has a primary care doc, a nurse care team, people have helped her with food delivery, helped modify her home, addressing her physical, mental, social, and financial needs. Now been hospitalized 0 times and hugs the doctor when she walks in the door. Not me, I am a doctor, but it was a real doctor with me, from our team. And that’s what it’s about, right? That’s better care for patients. So, when we get it right, it delivers exactly what we want for our own loved ones in the health system.

Chip Kahn: So, I think you just described the secret sauce. But how do you scale that, and how does this kind of pay-for-performance, value-based care become the prominent dominant payment scheme?

Patrick Conway: It’s interesting, this week I was in D.C. and the West coast so saw much of the country, and Massachusetts. Dr. Oz talked about this on a panel about, you know, he wants value-based care to be the model in the U.S. He wants 100% of patients and people in accountable care relationships. By the way, this is a bipartisan idea. It’s been across administrations. The good news is I think we’re getting much closer. So, you have over 50% of patients nationally in these models. It’s heading towards 50% and sort of two-sided risk models. So, I think we’re moving. You know then I think how do you get there? It’s going to be public private collaboration. It’s going to be continuing getting the incentives and the various payment incentives right. But that’s not all you need. You also need the technology, the clinical practices, the workforce, which you know is often organizations of a certain scale and capability to deliver those services. We may talk about rural today. That’s something we think about a lot now. How do we scale these models to rural settings as well so that we at Optum are serving the whole population. And you know, it’s not going to be one organization including Optum. It’s going to be a set of public private sector actors that are all moving in the same direction.

Chip Kahn: I have a feeling technology is going to be part of this. So, let’s now go to AI and UnitedHealth Group is spending a great deal on AI. You’ve got hundreds and hundreds of use cases that I understand you’re focused on and trying to operationalize. How is that investment going and what is the evidence that it will be transformative? How are you going to make it transformative?

Patrick Conway: Look, we think AI is going to completely transform our business. You know we talk about if we don’t transform and disrupt ourselves, somebody else will. So then let me describe; we’re now scaling use cases. So, I think we’re at the sort of next phase of the journey. I’ll put them in categories. You’ve got what I’ll call administrative type functions. So, think, call, claim other things. How do you make the system work better? We take about 300 million calls in UnitedHealth Group. We think that could be 150 million or less in the next 12 to 18 months. So many of these investments we think will get an in-year return and then a long-term return. Let’s go to another area. Products and services. So, Optum Real, which is real time settlement of claims. The payer agrees what they’re going to pay, based on what we’ve digitized and used AI on, the benefits, the provider, we’ve pulled the clinical data and made sure we’ve met all the criteria. I think 99 plus percent approval at the point of care. And the patient knows what their copay is and can settle that right away. It’s how the system should work. So, we’re scaling that across payers and providers. You know, also things like ambient listening combined with AI technology. So, the clinician could just practice and then it’ll automatically or autonomously code for them so they’re not spending as much time with documentation. One of the stats I loved: some of this work has saved over 2 million minutes of clinician documentation time just in our system. So let them get back to patient care. I know, you know, I’m still a practical physician. I use the EHR on weekends in the hospital. and you want to focus on the patients, right? Last clinical, I just, I know I’ll try not to be too long winded, but the clinical example, I’ll give that I think we’re in the early stages of. My first week as an attending. I finished residency at Boston Children’s. I go to Children’s Hospital Philadelphia. I get a patient who had been referred all around America, people trying to figure out the diagnosis, about a thousand-page chart. I get to page 487 and I’m like, oh my gosh, this kid has a rare metabolic disorder. Which ended up being the case. That took hours of reading. In an era of AI, that should be queued up to me or any other clinician anywhere in the country. You know, the nurse practitioner in rural America. So instead of two years, that child’s diagnosis may be done in minutes. That’s the kind of potential impact the technology could have.

Chip Kahn: On the paperwork side, in a sense, the sort of rift between providers and payers. What can it do with prior authorization? I know that you’re applying it there and you’re trying to cut back on the number of times that prior auth is required. What do you see the developments there that are going to bridge some of these gaps we have right now?

Patrick Conway: First, as you alluded to, we are both across UnitedHealthcare and Optum, eliminating prior authorization whenever possible. So, decreasing the prior authorization  burden, if you will. And then we’re standardizing and using electronic tools. So let me give you a couple examples. At Optum Rx, our pharmacy business, we once again connected all those benefits using the pharmacy rails into providers. The median prior authorization team had been eight hours, sometimes days or weeks for medicine, we got it down to less than 30 seconds. So, it’s auto approved, by the way, if the clinician, the prescriber, you need one more piece of information, which is usually why prior authorization gets caught up because you don’t have all the documentation. It tells them right then so they can enter the information and get it approved. So that’s how a system should work. We’re also doing that for medical as well through Optum Insight. So, you get approval rates that are very high immediately and they’re in the clinical workflow, which you know, that was prior auth’s original intent, right? Get the right treatment to the right patient. That we can all stand behind. But we have to have a system that makes it fast, standardized, and seamless for the patient and the clinician.

Chip Kahn: In terms of your 91-year-old patient example, how broad based is that in terms of having that integrated platform, at least in your system right now? I mean, are most of the patients getting that total coordination integration or is it just being experimented with? Where are you with that?

Patrick Conway: Yeah, so in our Optum Health platform, integrated value-based care, we serve about 20 million patients today. It’s, by the way, across about 100 payers. It’s national, so it’s large scope. You know, as you alluded to, there’s obviously more Americans in our health care system so there’s more room for growth or expanding the model. But our integrated value-based care platform is impacting millions and millions of people all across the country. And to be clear, Medicare Advantage and duals are the most in that platform. But we also serve Medicaid and commercial on the platform. It’s across all lines of business. As I said, sometimes people forget sometimes we actually serve about 100 payers. So, it’s UnitedHealthcare and all the big nationals, but also regional blues and other health plans as well.

Chip Kahn: Are you using data to locate those patients? What kind of systems do you have?

Patrick Conway: We’re an evolution, transformation, whatever verb you want to use as well. So, we do, and I think those are getting better over time. So, let me try to give you an example. In our various clinics and specialties, we’re trying to make sure we match demand, so patient demand for appointments and things like that to supply. So, we get people to the right clinician quick enough. Actually, mental and behavioral we haven’t talked about yet today, very important. We have about 4,000 mental and behavioral health clinicians. So, psychiatrists, therapists and others. Obviously huge demand. We use technology to try to match that demand to the supply and including through virtual care, also in person, but a large percentage virtual. The last thing I’ll say on sort of clinical pathways in our Optum Insight, Optum Real business, and Optum Health. As we think about guiding patients, we’re increasingly saying, you’ve got a patient with a clinical need. How do we navigate them to the right place? That could be an Optum clinician, that could be a hospital, that could be wherever the right place is. So how to use data and technology and partnerships to sort of find that clinical need earlier and then guide them to the best clinical pathway for them.

Chip Kahn: You know, you’re big. In a sense, there are a lot of people within the whole umbrella, where it’s the same company bearing the risk for the care that bills the AI that informs the coverage decisions. How do you ensure that AI serves the patient first and is seamless for the provider? And what does your sort of AI review board or however you process things, actually do to give confidence to the answer?

Patrick Conway: We do have an AI review board that reviews the technology and its principle is sort of patient quality safety first. Since I’ve been at Optum, I’m in my seventh year now in all the various businesses, and I’ve run different businesses over time, now I just started my second year as CEO of Optum. We always start with a patient story. So, you center on the patient, the clinical first. So, we actually did it yesterday, our monthly business review. It was a child with multiple chronic conditions that we care for in the home. And we care for her almost every day of her life because we have a big home health hospice business as well. You know, that’s why you do the work. Then as you do, you take that principle into AI and you’re always clinical first. As I said, we’re using it for clinical approvals, automatically. You know, if it’s changing direction of care or saying we don’t think the therapy is needed. We have a principle that a clinician must review that—a human doctor, nurse practitioner, or other—the appropriate clinician. Because where we are now on the paradigm, we think that’s important that a clinician has the final say on approvals, auto approval by the technology for anything that is a redirection of care. We think that final decision, aided by AI and technology, but should be made by a clinician.

Chip Kahn: With that principle though, and not focusing on one, United or other companies. There is litigation, legislative activity in this whole area around AI-driven coverage decisions. How do you engage? And in some ways, you just did it. But public concern about AI being used to limit access. How do you assure people? And maybe also what kind of guardrails or public policy do you think are appropriate here?

Patrick Conway: Yeah, so first on us, I’d go back to the principles. I said, so what’s the review of the technology overall for patient quality first? And then I think principles like I described, auto approval, making the system faster, the technology can enable that. Redirection of care, or saying that, you know, this treatment is not approved, we think a clinician, you know, typically a doctor, has the final say. Then how do we assure people? I think it’s around transparency. I don’t know if we’re going to talk about Optum Rx today, but I’ll just—we put out the culmination of a series of work on Monday that is 100% transparency, 100% rebate pass through, 100% transparency down to the group purchasing organization, cost-based reimbursement for all drugs, 100% of independent pharmacies. They actually—Buddy Carter, who, you know, did a positive tweet about Optim Rx that’s, you know, you don’t see that every day.

Chip Kahn: Right.

Patrick Conway: I think it’s the same in AI. If we provide transparency, that builds trust. And so, one of our principles is providing that transparency to build trust. Sorry, last thing I’ll say here, because you alluded to a couple different ways. The health care system has many broken, fragmented parts. You actually need scale, whether you’re a UnitedHealth Group or a health system or public private partnerships to address people’s physical, mental, pharmacy, social needs at scale. I’d almost flip this question on its head sometimes. Individual niche solutions may solve individual niche problems. But if you want to make health care better for millions and millions of people, you actually need the capabilities, the assets, the people, the technology to do that. And that often comes with scale to deliver those outcomes.

Chip Kahn: Yeah, I think what you just articulated is really important and there are a lot of naysayers about…I’ll use the consolidation word. But at the end of the day, if you can’t do most of what the patient needs in some kind of system, then the patient’s not going to get what they need. Fragmentation is a problem. I mean, there’s no question about it.

Patrick Conway: Totally. Look, to bring it to the clinical: I was down at Kelsey-Seybold [Clinic] a while back, which is one of our clinics systems in Houston and they have a product that actually the network is more open than you might imagine. I said, well, how do you keep people coming to Kelsey-Seybold? And they’re like, well, they love us and we do everything. We got primary care, we got specialty care, we got ambulatory surgical centers, we got mental health. And to your point, you need the scale and set of capabilities to do that. And actually, the data proves it out. They’re lower cost by far. Their quality results are through-the-chart positive, and their experience results are very positive. I mean, sometimes you can’t make this up. I’m not going to name the person because I don’t know if you want me to, but I met with senior officials in Massachusetts yesterday and he had been to one of our ambulatory surgical centers. And you’re a little nervous when that happens because you’re like, oh, he was like, he was like, no, it was amazing. Like, it was the best health care experience I’ve ever had. It was patient centered, it was organized. You guys had transferred my primary care record to the ASC [ambulatory surgery center]. I mean, that’s what you want for patients and that is the benefit of some level of scale capabilities, technology to support that level of care.

Chip Kahn: So, let’s move from the patient side to the physician side. You know, there’s some data out there that maybe you can even give us the number of the total physicians that you employ. But Optum docs, I understand, run 34% below industry average in terms of burnout, which is, which is a really incredibly positive number. What is different about a doctor’s day inside your model? And how are you keeping them in the race and not burn out?

Patrick Conway: You do your research. I’m impressed. You know that stat, that is the right stat. We basically try to support them in the clinical care and remove the barriers. And then let me describe. We use ambient listening powered by AI to help them with documentation. We use AI and technology to queue up, have you thought about these clinical decisions? Have you thought about these Star gap closures? So, it’s helping them manage. I mean, you know, I still practice. You’re managing a kid or an adult with 10 plus chronic conditions and many medications. It is a recipe for, on one end of the spectrum, errors or safety errors. On the other end of the spectrum, you know, making sure you address every care gap and address all their needs. We’re supporting them with the latter. Give you some other tangible examples. I live in Massachusetts. I interact with our Atrius physicians a fair bit. They were struggling as an independent. Now they’re expanding, they’re expanding services. They have the technology to do what they need to do. They’ve got home health and hospice and the whole care paradigm, ambulatory surgical centers to serve patients. The last story I’ll tell: It’s actually the flip with a 91-year-old story with one of our geriatricians who do those visits often. She said to me, you know, I was going to retire. She was older in her career and she said, and then I found this and I love it. She was like, I was doing 15-minute office visits, burnt out, could never do everything I wanted. And now I get to drive around and see four or five people in their home and do a visit for an hour, hour and a half. She’s like, this is amazing. Like I love it and I don’t plan to retire anytime soon. So, I mean that you give physicians the ability to practice or nurse practitioners or other clinicians and just deliver amazing clinical care. That’s why they went into medicine, that’s why I went into medicine. And you do the opposite and you create barriers or paperwork or other things, then you end up burning people out. So, we’re trying to do the former.

Chip Kahn: So how much is AI, contributing on this clinical side to diagnostics and are we headed to automated decision-making in this at all? And where’s the accountability? I know you talked a bit about it, but could you put more emphasis on it?

Patrick Conway: Yeah, I think AI is going to be a huge accelerator. So, there’s even a study came out I think, yesterday or the day before, on sort of physicians using AI and various tools. And it’s a very high percentage now what they’re generally, I use it by the way in my clinical practice as well, it’s used as an aid, a support system. And I think that in today’s paradigm that’s the way it should be used. So, if it’s diagnosis, what are the various diagnosis to consider? I like data and stories as you’ve heard. Our care at home model, we broke patients into various cohorts. So, you’ve got a 40-year-old disabled patient versus a 92-year-old patient versus an oncology patient. So, you’re queuing up the right information based on AI technology for that specific patient. It also becomes much more personalized. As you know, patients are starting to use AI to help guide their journey. I think that’s good. It’s giving them information and clinicians are using AI. So, I think it becomes much more personalized, if you will, to get the exact right care for that individual patient in front of you.

Chip Kahn: You’ve committed to pretty significant cost reductions from AI in ‘26 and argued that capitation and generative AI together can bring about value-based care. And this is where we get into the rural side, to rural communities. If you were right and obviously if you’re saving money, some of that’s sort of coming out of the payments and the volume. What happens to the independent physician, that local community hospital, and the smaller players in that market?

Patrick Conway: A couple things. I grew up in Texas, I certainly understand rural health care. With a doc that, you don’t do this anymore, did one year internship, hung a shingle, delivered us, did minor surgery, my entire medical records, like five pages. You don’t see that much anymore, handwritten. We need to support these hospitals and clinicians. Then let me describe that. So, we actually serve a little north of 8 out of 10 hospitals and health systems in the country in some way, usually in a lot of their back-office functions. A ton of those are in rural America. We’re committed to that; we’re committed to doing more of it. We even through our UnitedHealth Group foundation are talking about how we invest even more in rural, both as a business and a foundation. For those independent docs, as you alluded to, we often are given a physician number and people include contracted employed. Employed is actually a smaller percentage of the number. The vast majority are contracted, which means they’re not employed by us. We’re offering them tools, technology, and contractual arrangements to allow them to participate in value-based care. As you know, as a small doc practice, that’s very hard on your own. And many of those are in rural areas and we want to expand those and even more in rural areas. So, the rural hospitals, we support many of them now and we’re having these kinds of conversations. How do we use AI and technology to help you be more efficient, help you get the right patients in your door. Also, you know, when patients need to transfer, go somewhere else. How do we make that process as simple and fast and efficient as possible?

Chip Kahn: Can we go into a little bit more depth, and maybe beyond what you’re doing in terms of rural health care? We have in the OBBA [One Big Beautiful Bill Act ] very large Medicaid reductions and frankly from at least my perspective, we have a small little rural program. And the administration’s made it clear they don’t want to use that money for helping directly to providers. So, there’s going to be a gap and it’s not going to come all at once. It’s going to be over the next few years. But that gap is going to be really significant in terms of those rural hospitals that are very dependent on Medicaid and Medicare. And the Medicaid numbers that they’re paid is going to come down. Do you have a view as to how that should be dealt with? How we can mitigate that at all or…?

Patrick Conway: Look, it’s a major issue. My hypothesis is we’re going to need public and private sector to sort of fill in because gaps, if you will, and partner in rural America. We’ve talked to the current administration about this. You know, rural health has actually generally been bipartisan over time. Certainly something we care deeply about. Look, I think you’re going to have to fill in with technology data supports. I think payment models you’re going to have to think of slightly differently. So, give you an example. You know, in the Innovation Center, we had this rural hospital model in Pennsylvania that basically tried to support them if they wanted to become a smaller sort of inpatient surgical footprint and more of an ER and a community footprint, they could do that and gave them the glide path. In Vermont, we did this all-payer ACO model which also tried to support the rural hospitals. So, I’d look to some of the state-based work as well, not just those two generally that have said, you know, we need a system of care in this state that includes rural and urban and how do we make that system function as best as possible?

Chip Kahn: I mean, something’s got to be done. It’s not going to get better by itself.

Patrick Conway: Exactly. And you know, we read about the alternative, right, where you now have a desert where, you know, I have to drive two and a half hours to deliver my child. You know, to deliver a baby. That’s obviously not optimal. You know, there in a given state, I’d literally map that out to figure out, you know, where do I have those kinds of significant access concerns? How do I as a state support something in that area, even if it’s a smaller physical footprint, not a whole hospital, but some ability to do the more emergent and basic care? And I’d include childbirth, it’s a specialty, but it’s an important specialty that is incredibly important at the time you’re delivering a child. So how do you have that spread out with access uniformly, including to rural areas.

Chip Kahn: You brought up the Rx and you talked about the refinements that you all were making in your pharmacy benefit management function. What role will AI play on the pharmacy side? I know in Utah they’re back and forth about an experiment of having scripts refilled using AI. What’s your view on that?

Patrick Conway: Yeah, so I’d put in categories again. So one, we are using AI for auto approval, like I said now, the median is less than 30 seconds. So, I mean, you know, we literally had a very senior person in our company. It was like, it worked on my phone, like it was ordered and approved, you know, all done. And that’s how it’s supposed to work and that is how it works. So median less than 30 seconds for auto approval. The other place we’re using AI, this cost-based reimbursement for all drugs, all pharmacies across America. One of the challenges before was the data to try to get there. So how do you sort of, you know, you got thousands and thousands of drugs, thousands of pharmacies. So, we actually had an AI technology pricing platform it was part of the solution to allow us to move to a cost-plus type of arrangement for all drugs, all pharmacies. And the feedback we’ve gotten from independent community pharmacists is very positive. Actually, a rural issue as well. You know, if you’re a rural independent community pharmacy, we can support you in a sustainable cost-plus model. We won’t have a pharmacy desert in that area, as an example. The last area I’ll put in is a large part of our Rx business is also the pharmacies. So, think infusion, specialty pharmacy, home delivery. We actually have these community pharmacies that are integrated care for mental and behavioral. So, think schizophrenia, substance use disorder, really cool model, partner with FQHCs and community health centers. The data there is similar to some of the clinical realms. You know, how do we get the nurse to the right patient? How do we make sure this, you know, right drug, right patient, right time, affordably, right dose, you know, how do we make sure that happens every time using AI and technology. So those are some of the ways we’re using it in the Rx space.

Chip Kahn: One of the other issues that comes up, and there have been some Wall Street analysts on this, talking about whether AI in terms of the clinical area will save money or reduce spending immediately. And the issue is, I think, really characterized by one of our earlier interviews with Elad Walach from Aidoc, where their technology now is so good that even if they have a CT scan that was ordered for a certain purpose, they can find out a lot of other stuff about that patient. So, as we apply AI to whether it’s population health or whether it’s specific procedures or diagnostics, you’re going to be finding things you didn’t see before. So where do you fall out on this notion that at least at the beginning it’s going to find more disease, which will have to be dealt with before we get to the longer-run benefits of finding things earlier? You, know, where do you fall out on this?

Patrick Conway: Yeah, look, I go back to first principles. There will be instances where AI finds something earlier. I would argue that’s unequivocally a good thing if it improves health. You know, so if you’re improving health, that’s our first principle goal—health care outcomes and quality and experience. And over the long term, most of those things will have a cost, return as well. There was actually. I’m looking,  I got books above me. Somebody wrote in one of their books about this. You may remember this, when we did the diabetes prevention program in CMMI, I actually had to approve. The actuary said, well, it does improve in quality. It does. You know, it clearly saves lives. By the way, in our 10-year window that we use for everything in D.C., it may increase cost. And we actually said we still want to expand it nationally because the goal of Medicare should be to improve life and health outcomes. And, by the way, a 10-year window is pretty arbitrary, and so we approved it and expanded, as you know. Look, the reason I share a story is similar here. Anything we can do, or anybody in the health system can do to improve quality of life, health outcomes, morbidity, mortality, we should do, because that’s what our population that we serve wants. And the vast majority of those things do have a financial return over some time period. Some of them will be longer, some of them will be shorter. But we need to invest in health.

Chip Kahn: You know, one of the dilemmas in the whole area of pay-for-performance is that, you know, obviously it usually has a pricing angle, and it has some kind of volume angle, but it also includes some kind of metrics. But those metrics are usually structural or process.

Patrick Conway: We worked on this.

Chip Kahn: We did, and it was the best you could do at the time. But we’re sort of stuck with a system that at best, I could say, is not dynamic and may not even be relevant to the services that are being provided. It’s really about compliance now. Do you think that AI can—and obviously we have all the data—AI can break the logjam here.

Patrick Conway: I do. I was smiling because we did work on it and you’re right, we did the, you know, Medicare stars, which we put in when I was at CMS. It was the best for the time. It was. It needs to evolve faster to more outcome-oriented measures, to measures that actually matter. And you know, the current administration agrees with that by the way, as do we. So, I do actually think AI and technology may be the final breakthrough, if you will, because one of the biggest limits before, as you know, was the data. Well, I don’t have the outcomes data, I don’t have the clinical data. Oh, it’s too expensive to collect, you know, so we’re just going to rely on claims data because that’s what we have, you know, or a process metric that we happen to have. That was what you had at the time, but now you’re in an era with the AI technology that you should be able to have the data. It should not be costly to collect. You should actually know the health outcomes. And so, I do think it opens up the health outcome and quality measures to be much more meaningful and actually have that parsimonious set we’ve talked about for so long in the various areas that are the measures that matter.

Chip Kahn: You know, as we close out our conversation, Patrick, there are a lot of doomsayers about AI, generally, as well as those who look at it as making the future brighter. In terms of AI and health care sort of generally, is there anything that keeps you up at night that worries you about where we’re headed?

Patrick Conway: Look, what’s kept me up at night through various…actually, I fall asleep in about two seconds, but if anything kept me because I probably don’t get enough sleep, although I’m trying to get back. But if anything kept me up at night, I’ve had the blessing, if you will, to work at places like CMS and UnitedHealth Group and Optum that serve millions and millions of people. And then what would keep me up or worry me? There’s somebody falling through the cracks. And actually, when I work clinically in the hospital, I work at a safety net hospital in Boston. I see those people that fell through the cracks, didn’t get the mental health care they needed, didn’t get the home-based care they needed, didn’t get basic preventative care. So that’s what keeps me up or worries me. I’m an optimist. I actually think AI is one of the keys to solving that problem, because one of the challenges as a clinician, you don’t see the patient not in front. You see the patient in front of you. And we literally train clinicians that way. But in population health or value-based care, you have got to care for the whole population. To do that, you’re going to need AI and technology to help you see and understand that whole population and serve their physical, mental, pharmacy, social, financial needs across their life trajectory. And that I think AI and technology are the key to. And what gives me hope is when I’ll, go out and see this care. I’ve got to end with one story that I hope you keep in the podcast.

Chip Kahn: We’ll keep it. We’re going to keep it all though.

Patrick Conway: Yeah, it’s not AI, but it’s caring. So, I’m in Lafayette, Louisiana, and I like to do visits, so I show up at this house and the nurse walks from across the yard and I’m like, are you his neighbor? And she says, yeah, I’ve cared for him. You know, when I was a single mother, he helped me help repair my house, he helped do other things. I’m a hospice nurse. He was going into hospice. There was no question I was going to care for him. And we walk into the home and his caregiver, these are these nurses employed by us, the caregivers employed by us watch from the backyard. You can’t make this up. I care for him 50 hours a week because he’s my neighbor. You know, I work. LHC is the business. It’s one of our home health hospice businesses. And the emotion in that room was palpable. And then you walk out and the nurse says, do you have a minute for an elevator speech? Do you know what an elevator speech is? I’m like, of course I do. She gives a speech about hospice and about how it’s important to care for people at birth. It’s just as important at the end of life. And that she cares for their physical, mental, social, pharmacy, their whole holistic needs. That’s when you know you got it right. And we do support her with technology as well. To bring it back to your AI topic. But it’s not just technology, it’s the caring of a clinician like that and giving them the tools and the technology so they can do their best work.

Chip Kahn: Thanks, Patrick, for a great conversation. I really appreciate your time. And I certainly learned a lot today and I know our audience will appreciate it also.

Patrick Conway: Well, thank you. I’m a learner, too.

Chip Kahn: Great.


SERIES

This weekly podcast features insightful conversations between host Chip Kahn and his guests, who discuss the business of health care, connecting the dots between the health care business, policy, and patients.

The podcast’s first series on AI in health care illuminates how AI is changing health care, and features guests who are deploying this technology, managing its consequences, and designing policy around it.

Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Updated on:

The 2025 reconciliation law requires states to condition Medicaid eligibility for adults in the ACA Medicaid expansion group on meeting work requirements starting January 1, 2027; however, states have the option to implement requirements sooner through a state plan amendment (SPA) or through an approved 1115 waiver.

State Plan Amendments (SPAs)

States may choose to implement work requirements prior to the required January 1, 2027 implementation date through a state plan amendment. Nebraska is the first state to announce that it will begin enforcing federal work requirements early through a state plan amendment, starting May 1, 2026. Two other states are also planning to implement before January 2027–Montana on July 1, 2026 and Iowa on December 1, 2026. Arkansas has announced that it plans to launch a soft implementation of work requirements on July 1, 2026 but will not disenroll individuals prior to January 1, 2027.

1115 Waivers

Since the start of the second Trump administration, several states have submitted waivers to implement work requirements. However, states are unlikely to be moving forward with proposed 1115 waivers at this time due to the passage of federal work requirements. States that plan to implement federal work requirements early will do so through a state plan amendment. Currently, Georgia is the only state with a Medicaid work requirement waiver in place following litigation over the Biden administration’s attempt to stop it. Georgia’s waiver will expire December 31, 2026; the state is required to come into compliance with the new federal requirements effective January 1, 2027.

Early Implementation and Waiver Status

The map below identifies states that have indicated they will implement federal work requirements early through a state plan amendment and the one state (Georgia) that has implemented work requirements through an 1115 waiver.

States Implementing Work Requirements Early and/or With Approved Work Requirement Waivers (Choropleth map)

Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Updated on:

KFF Resources on Medicaid Work Requirements

Work requirements overview:

50-state survey of Medicaid eligibility and enrollment policies:

Implementation of work requirements:

Research and analysis on Medicaid and work:

1115 work requirement waivers:

Work requirements implications and state experience:

Arkansas work requirement experience:

KFF Polling on Work Requirements:

Beyond the Data by KFF CEO Drew Altman:

Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Updated on:

CMS Guidance and Information

Operational and Implementation Questions

Table

Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements

Updated on:

The 2025 reconciliation law, once called the “One Big Beautiful Bill,” signed by President Trump on July 4, 2025, conditions Medicaid eligibility for adults in the Affordable Care Act (ACA) Medicaid expansion group and enrollees in partial expansion waiver programs (Georgia and Wisconsin) on meeting work requirements starting January 1, 2027. Currently, 41 states (including DC) have expanded their Medicaid programs under the ACA to nearly all adults with income up to 138% FPL ($21,597 for an individual in 2025).

To implement Medicaid work requirements, states will need to make important policy and operational decisions, implement needed system upgrades or changes, develop new outreach and education strategies, and hire and train staff, all within a relatively short timeframe. The information tracked here can serve as a resource to understand Medicaid work requirements and state options, gauge readiness, and track implementation of the requirements, including:

This resource will be updated to include guidance from the Centers for Medicare and Medicaid Services (CMS), information on state policy decisions as they are made, and new data when available.

Continue scrolling to learn more about the Medicaid work requirements in the 2025 reconciliation law.

Medicaid Enrollment and Unwinding Tracker

Published: May 29, 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 February 2026 include:

  • There are 74.9 million people enrolled in Medicaid/CHIP nationally (Figure 1). This represents a 21% decline from total Medicaid/CHIP enrollment in March 2023, but is still 5% higher than Medicaid/CHIP enrollment in February 2020, prior to the pandemic. However, the number of children enrolled in Medicaid/CHIP declined by 345,000 or 1% from February 2020 to February 2026 (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 nineteen states (AK, AZ, AR, CO, FL, ID, IA, LA, MA, MI, MT, NH, NM, RI, SC, TN, TX, VT, WV) and DC. Enrollment changes from pre-pandemic baseline vary from a 18% decrease in Montana to a 53% 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 35 million children (48%) and 38.3 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 25 states, while adult enrollment is below pre-pandemic levels in 17 states and DC (Figure 2).
  • There are 67.7 million people enrolled in Medicaid and 7.2 million people enrolled in CHIP (Figure 1). More states report CHIP enrollment above their pre-pandemic baselines compared to the number reporting Medicaid enrollment above the baseline (Figure 2).
National Enrollment in Medicaid/CHIP, February 2020 to February 2026 (Line chart)
Cumulative Percent Changes in Enrollment from February 2020 to February 2026 (Column Chart)
Total Medicaid/CHIP Enrollment, Selected Time Periods (Table)

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 September 12, 2024, States Have Reported Renewal Outcomes for Nearly Nine Out of Ten People Who Were Enrolled in Medicaid/CHIP Prior to the Start of the Unwinding (Donut Chart)

 

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 25,198,000 Medicaid Enrollees Have Been Disenrolled and 56,378,000 Have Had Their Coverage Renewed, as of September 12, 2024 (Stacked Bars)

 

  • 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 September 12, 2024 (Stacked Bars)

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 September 12, 2024 (Stacked Bars)

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 August 2024 (Stacked Bars)

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

A Closer Look at North Carolina’s Implementation of the 2025 Reconciliation Law Medicaid Provisions and Other Changes Amid Medicaid Budget Shortfalls

Published: May 29, 2026

On April 30, 2026, North Carolina Governor Josh Stein signed legislation that includes Medicaid policy changes and closes an estimated $319 million shortfall in funding for the state’s Medicaid program for FY 2026. Many of the legislation’s Medicaid policy changes are related to implementation of the 2025 federal reconciliation law. The 2025 reconciliation law requires states to condition Medicaid eligibility for adults in the Affordable Care Act (ACA) Medicaid expansion group and enrollees in partial expansion waiver programs (Georgia and Wisconsin) on meeting work requirements starting January 1, 2027. The 2025 reconciliation law also limits states’ ability to raise the state share of Medicaid spending through provider taxes, restricts state-directed payments (SDPs) to hospitals, nursing facilities, and other providers, and increases barriers to enrolling in and renewing Medicaid coverage. As states are preparing to implement the reconciliation law provisions, many states are facing more tenuous budget situations with slowing revenue growth and broader reductions in federal funding.

This policy watch examines the current budget context in North Carolina, the state’s recently passed legislation, the state’s Medicaid Advisory Committee (MAC) meetings, and data from KFF’s Medicaid work requirements tracker to provide initial insight into how North Carolina is preparing to implement certain Medicaid provisions of the 2025 reconciliation law and how other policy changes may affect coverage and access to care. While some of the issues North Carolina is facing are unique to that state, others are likely to be faced by other states as they implement federal changes to Medicaid in the midst of other fiscal challenges.

What is the budgetary context as North Carolina prepares to implement the 2025 reconciliation law’s provisions?

North Carolina is facing a more tenuous fiscal climate like in other states, and state legislators have not yet enacted a comprehensive state budget for the FY 2025-27 biennium. In the past year, revenue volatility and rising costs have led to slowing state revenue growth following a period of record-breaking revenue and expenditure growth for states after the initial pandemic-induced economic downturn. In North Carolina, scheduled tax cuts have been projected to drive declines in state revenue, and debates over whether to proceed with the cuts have contributed to a budget stalemate in the legislature.

In August 2025, Governor Stein signed a stopgap funding bill  that appropriated $600 million from the state general fund for Medicaid, but it left a $319 million shortfall for FY 2026 in funding for the cost of services for non-expansion (traditional) enrollees. The shortfall and budget stalemate led to rate cuts and the elimination of GLP-1 coverage, both of which were eventually restored. The Medicaid agency ceased “Healthy Opportunities Pilots” program services in FY 2026 due to a lack of appropriations. The pilots covered certain non-medical services that target social needs, including housing, nutrition, transportation, and interpersonal relationship supports to specific and limited enrollees, and evaluations of the “Healthy Opportunity Pilots” 1115 waiver showed lower costs over time and largely positive outcomes. The Medicaid agency also implemented changes to reduce administrative expenses, including reducing temporary staff and contractors, ending certain contracts, pausing quality improvement projects, and scaling back compliance and quality oversight activities. The legislation signed in April 2026 appropriated $319 million to close the shortfall for FY 2026 and made changes aimed at addressing financing pressures associated with new federal limits on provider taxes, which the state uses to help finance its Medicaid expansion and hospital state directed payment program (which increases payment rates for hospitals).

What are some of the Medicaid policy changes included in North Carolina’s recent legislation?

Eligibility and Cost Sharing

North Carolina’s new legislation includes more restrictive standards for how the state will implement work requirements than is required in current law. At a minimum, the 2025 reconciliation law requires states to look back one month immediately preceding the application month and one month between renewal periods to confirm compliance with the requirements. North Carolina’s legislation requires the state to confirm compliance for the three months preceding the application month. At renewal, the state must confirm compliance for at least three of the six months since the last determination of eligibility. The North Carolina legislation also prohibits the acceptance of self-attestation as the only evidence in verification of eligibility requirements (unless required by federal law or regulation, or pursuant to a court order). States await guidance from CMS as to whether self-attestation of medical frailty, parent/caretaker status, or other exemptions or work status can be accepted, but most states report plans to accept self-attestation if allowed. 

The legislation increases the frequency of data checks to identify changes in circumstances for Medicaid enrollees from quarterly to monthly. The state will review information on earned and unearned income, employment status and changes in employment, residency status, enrollment status for other public assistance programs administered by the state and outside of the state, financial resources, incarceration status, and lottery and gambling winnings. States are required to follow up on reported changes that potentially affect eligibility and give individuals an opportunity to respond before taking adverse action. In North Carolina, when data indicates an individual is no longer eligible, enrollees only have 10 days in advance of case closure to submit documentation verifying ongoing eligibility. Increasing the frequency of periodic data checks with insufficient response times can lead to procedural disenrollments and exacerbate churn.

The Medicaid agency will be required to set Medicaid copayments at the highest allowable amounts for both traditional Medicaid enrollees and ACA expansion enrollees. Current federal rules limit cost sharing in Medicaid because of enrollees’ low income and limited ability to pay out of pocket costs. The maximum allowable cost sharing varies by type of service and enrollee income. North Carolina has set current cost sharing amounts, regardless of enrollee income, at $4 per service. Starting July 1, 2027, the legislation requires the Medicaid agency to increase current cost sharing amounts for services where the maximum allowable amount is more than $4 and to increase cost sharing for ACA expansion adults with income 100-138% FPL to up to 10% of the cost of the service, except for prescription drugs and non-emergency use of the emergency department. Beginning in October 2028, when states are required to implement mandatory cost sharing of up to $35 per service for ACA expansion adults with income between 100%-138% FPL, the state will be required to set cost sharing amounts at $35 per service, except for prescription drugs, for all non-exempt services for this group. 

The legislative text implementing the changes to Medicaid eligibility for certain lawfully residing immigrants effectively ends the state’s long-standing optional Medicaid coverage for lawfully residing children and pregnant immigrants without a five-year waiting period. The law limits Medicaid coverage for immigrants to coverage that is required under federal law. However, North Carolina is one of 40 states that have taken up the option to extend Medicaid and/or CHIP coverage to children and/or pregnant adults who are lawfully residing and waive the five-year wait for these groups. The 2025 reconciliation law imposed additional eligibility restrictions for many lawfully present immigrants but allows states to maintain the option to cover lawfully residing children and pregnant adults. By limiting coverage for immigrants to only what is required by federal law, the state law effectively ends this optional coverage as of October 1, 2026. In a recent Medicaid Advisory Committee (MAC) meeting, the Medicaid agency indicated it was working with the legislature to make “corrections” and restore coverage for these populations.

The legislation requires the Medicaid agency to report certain Medicaid applicants and enrollees for whom it cannot verify citizenship or “satisfactory” immigration status to the Department of Homeland Security. These include applicants and enrollees who, after a reasonable opportunity period, have not verified satisfactory immigration status or whose final verification indicates that they do not have a satisfactory immigration status and are not lawfully present. This group would include those found ineligible based on immigration status and individuals receiving Emergency Medicaid services (where Medicaid pays hospitals for emergency care provided to ineligible immigrants who would otherwise be eligible for Medicaid based on their income).

Medicaid Financing

The legislation increases intergovernmental transfers (IGTs) from public hospitals, reducing reliance on the state’s hospital taxes for financing the nonfederal share of Medicaid spending. The 2025 reconciliation law imposes significant new restrictions on states’ ability to generate Medicaid provider tax revenue, including prohibiting all states from establishing new provider taxes or from increasing existing taxes, as well as reducing existing provider taxes for states that have adopted the ACA Medicaid expansion. North Carolina uses provider taxes to help finance the nonfederal share of Medicaid spending. State law requires the nonfederal share for the expansion program to be fully funded by certain non-general fund sources, including hospital taxes and hospital IGTs, and requires the end of expansion coverage if those sources cannot fully fund the nonfederal share. The state estimates $14.3 million in one-time administrative costs for the current state fiscal year and $44.4 million in recurring annual administrative costs (including both state and county expenditures) for the expansion program to implement work requirements and six-month eligibility redeterminations that existing financing mechanisms did not account for. The increased public hospital IGTs aim to offset the financing of some of the existing costs under the state’s hospital tax, as well as to help finance the new administrative costs.

By increasing reliance on IGTs as a financing source, the state may aim to retain higher hospital SDPs under new federal provider tax limits, but new federal requirements for state directed payments are expected to require further changes. North Carolina’s Healthcare Access and Stabilization Program (HASP), a hospital SDP program launched alongside Medicaid expansion in 2023, is also financed through hospital taxes and IGTs. An earlier state report indicated the new federal provider tax limits would eliminate all or most of HASP SDPs. The state has been using HASP payments to incentivize hospitals to relieve medical debt, and as of October 2025, more than $6.5 billion in debt had been relieved for more than 2.5 million North Carolinians under the initiative.

There is significant uncertainty about how federal regulations and state legislation may affect the state’s plan for financing the nonfederal share of Medicaid spending, including for the Medicaid expansion and HASP. New proposed rules on state directed payments and forthcoming provider taxes may affect the state’s financing plans. The state’s legislation created a “trigger” to end the new funding should HASP payments fall below certain thresholds or a change in federal law or regulation result in at least a 20% decrease to IGTs.

Medicare Advantage Out-of-Pocket Limits: Variation and Trends

The Average Medicare Advantage In-Network Limit is $5,421 in 2026, But Nearly 1 in 5 Enrollees Face In-Network Limits Higher Than $7,000

Published: May 28, 2026

For coverage of Medicare benefits, people face a choice between traditional Medicare and private Medicare Advantage plans. While there are many distinguishing features between these coverage types, one key benefit of Medicare Advantage is an annual cap on out-of-pocket costs for medical benefits, which traditional Medicare does not include. In 2026, the out-of-pocket limit for Medicare Advantage plans may not exceed $9,250 for in-network services and $13,900 for a combination of in-network and out-of-network services, but plans can have lower out-of-pocket limits than the maximum.

Policymakers have long considered whether to add a similar out-of-pocket cap in traditional Medicare. In 1988, Congress enacted a Medicare out-of-pocket cap, but the law was repealed one year later principally due to concerns about the financing mechanism. The Medicare Payment Advisory Commission (MedPAC) has recommended changes in traditional Medicare to give beneficiaries better protection against high out-of-pocket spending, including an out-of-pocket cap as part of a broader redesign that also includes combining Part A and Part B deductibles and simplifying cost sharing. Traditional Medicare remains the only major form of health insurance that does not include a cap on out-of-pocket spending, though most beneficiaries in traditional Medicare have additional financial protection through supplemental coverage, including Medicaid, employer- or union-sponsored retiree coverage, or a Medigap policy (which may require additional premiums).

This brief analyzes out-of-pocket limits in Medicare Advantage plans in 2026, variation by plan type, the distribution of enrollees facing different out-of-pocket limits, and trends over time. Of note, this analysis does not show the share of enrollees that reach their plan’s out-of-pocket limit in any year because spending data are not available. The analysis includes Medicare Advantage plans generally available for individual enrollment, reflecting coverage for 21.3 million Medicare beneficiaries in 2026, excluding special needs plans and employer-and union-sponsored group plans (See Methods for details).

Takeaways

  • In 2026, the average enrollment-weighted out-of-pocket limit for Medicare Advantage enrollees is $5,421 for in-network services and $9,825 for in-network and out-of-network services combined. The average out-of-pocket limit for in-network services is higher for preferred provider organizations (PPOs) ($6,592) than health maintenance organizations (HMOs) ($4,636).
  • Just over one in ten Medicare Advantage enrollees (13% or 2.8 million people) are in plans with limits of $3,000 or less for in-network services in 2026, more than two-thirds (68%) are in plans with limits above $3,000 and up to $7,000, and about one in five (19%) are in plans with limits above $7,000.
  • About one in 10 (9%; 1.8 million) Medicare Advantage enrollees are in plans with the maximum out-of-pocket limit for in-network services ($9,250). Among the 8.6 million enrollees in PPOs, roughly one in five (22%; 1.8 million) are in plans with the maximum out-of-pocket limit for in-and out-of-network services combined ($13,900).
  • The average out-of-pocket limit for in-network services decreased by nearly $600 from 2017 to 2023 ($5,253 to $4,685), before increasing by about $700 from 2023 to 2026 ($4,685 to $5,421).

In 2026, the Average Enrollment-Weighted Out-of-Pocket Limit for Medicare Advantage Enrollees Is Lower for HMOs Than PPOs

The average out-of-pocket limit faced by Medicare Advantage enrollees in 2026 is $5,421 for in-network services and $9,825 for in-network and out-of-network services combined (Figure 1). These averages are lower than the maximum allowable out-of-pocket limits ($9,250 and $13,900, respectively).

Differences in out-of-pocket limits may reflect how Medicare Advantage plans choose to allocate rebate dollars, which are extra payments they receive from the federal government beyond the cost of providing Part A and Part B services. Plans may use rebates to reduce beneficiary cost sharing, including lowering out-of-pocket limits, but they can also use these funds for other purposes, such as offering supplemental benefits not covered by traditional Medicare, offering a rebate against the Part B premium, or lowering Part D premiums.

In 2026, the Average Out-Of-Pocket Limits for Medicare Advantage Enrollees Are ,421 for In-Network Services and ,825 for In-Network and Out-Of-Network Services Combined (Bar Chart)

Out-of-pocket limits for in-network services vary by plan type. HMOs, which have 12.8 million Medicare Advantage enrollees in 2026, generally offer no coverage of services from out-of-network providers, but offer a lower out-of-pocket limit for in-network services than PPOs. PPOs, which have 8.6 million enrollees in 2026, cover services delivered by in-network and out-of-network providers, but require higher cost sharing for out-of-network providers. While PPO enrollees have broader access to out-of-network providers than HMO enrollees, they also face a higher out-of-pocket limit, even for in-network services. Specifically, the average enrollment-weighted out-of-pocket limit for in-network services is $6,592 for PPOs and $4,636 for HMOs.

The distribution of enrollment between HMOs and PPOs, as well as the average out-of-pocket caps for in-network services by type of plan, vary across states (Appendix Table 1). Due in part to PPOs (which have higher average in-network out-of-pocket limits than HMOs) comprising a larger share of enrollment in rural areas, the average out-of-pocket cap is about $800 higher for Medicare Advantage enrollees in rural areas than in urban areas ($6,078 vs $5,291).

In 2026, Roughly One in Ten Medicare Advantage Enrollees Are in Plans With Limits of $3,000 or Less for In-Network Services and About One in Five Are in Plans With Limits Above $7,000

Among all Medicare Advantage enrollees in individual plans, just over one in ten (13%, 2.8 million) are in plans with out-of-pocket limits of $3,000 or less for in-network services (Figure 2). Nearly all of these enrollees (99%) are in an HMO. More than two-thirds (68%, 14.4 million) of Medicare Advantage enrollees are in plans with out-of-pocket limits above $3,000 and up to $7,000. About one in five (19%, 4.1 million) are in plans with limits above $7,000, including 1.8 million enrollees who are in a plan with the maximum in-network out-of-pocket limit of $9,250. PPOs enrollees account for the majority of these enrollees at the maximum cap (66%).

Among the 8.6 million Medicare Advantage enrollees in PPOs, about one in ten (9%) have a combined limit for in-network and out-of-network services at or below $6,000. More than two-thirds (66%; 5.7 million) of enrollees are in plans with a combined limit for in-network and out-of-network services between $6,000 and $12,000. One quarter (25%; 2.1 million) are in plans with an out-of-pocket limit for in-and out-of-network services combined above $12,000, including 1.8 million enrollees in plans with the maximum out-of-pocket limit for in-and out-of-network services combined ($13,900) (Figure 2).

Roughly One in Ten Medicare Advantage Enrollees Are in Plans With Out-Of-Pocket Limits of ,000 or Less for In-Network Services and About One in Five Are in Plans With Limits Above ,000 (Column Chart)

Average Out-of-Pocket Limits for In-Network Services Generally Declined Between 2017 and 2023 but Have Increased Since Then

The average limit for in-network services decreased by nearly $600 from 2017 ($5,253) to 2023 ($4,685), before increasing by about $700 from 2023 to 2026 ($5,421) (Figure 3, Appendix Table 2). The average limit for in-network and out-of-network services combined has fluctuated over time but increased overall by about $750 between 2017 ($9,073) and 2026 ($9,825).

The maximum allowable out-of-pocket cap has generally increased over time, consistent with projected beneficiary out-of-pocket spending in traditional Medicare, which CMS uses to calculate maximum out-of-pocket limits in Medicare Advantage. However, the maximum cap decreased by $100 between 2025 and 2026. The average out-of-pocket limit faced by enrollees each year has always been lower than the maximum allowable limit. This gap has generally widened over time, but shrank somewhat between 2025 and 2026.

Average Out-Of-Pocket Limits in Medicare Advantage Declined Between 2017 and 2023 But Have Increased Since Then (Line chart)

Methods

This analysis uses data from the Centers for Medicare & Medicaid Services (CMS) Medicare Advantage Enrollment, Benefit and Landscape files for 2017-2026. The analysis excludes Special Needs Plans (SNPs), employer- and union-sponsored plans, PACE plans, and cost plans. These plans serve distinct populations and some may have different enrollment requirements than Medicare Advantage plans (e.g., may be available to beneficiaries with only Part B coverage) and in some cases, may be paid differently than Medicare Advantage plans, limiting comparability with individual Medicare Advantage plans for general enrollment. These exclusions are reflected in both current data as well as data displayed trending back to 2017.

The total number of enrollees in individual Medicare Advantage plans in this brief (21.3 million) may be slightly different than the number reported in other KFF briefs because this analysis further excludes a small number of plans without an in-network out-of-pocket amount specified in the plan benefits files.

The average for PPOs in this analysis includes two types of plans: local PPOs, which cover individual or multiple counties, and regional PPOs, which cover an entire state or multiple states. The average for HMOs includes two types of plans: HMOs that primarily cover services provided by in-network providers only and therefore do not have a limit for out-of-network services, and HMOs that are Point-of-Service plans (HMO-POS), which allow out-of-network care for certain services but typically charge higher cost sharing than for in-network services.

In previous years, KFF’s analysis of average out-of-pocket limits in Medicare Advantage excluded HMO-POS because they represented a relatively small share of HMO enrollment at the time (e.g., 10% in 2017). However, HMO-POS enrollment has grown substantially and now accounts for nearly half (46%) of HMO enrollment in Medicare Advantage. As a result, these plans are included in the current analysis to better reflect the experience of a substantial share of Medicare Advantage enrollees in HMOs.

This analysis determines urban and rural analysis based on the 2024 Urban Influence Codes (UIC) published by the U.S. Department of Agriculture (USDA) Economic Research Service. See Methods of KFF, “Key Facts About Medicare Beneficiaries in Rural Areas” (June 2025) for more details. Connecticut is excluded from the analysis by rurality because of differences in FIPS codes in the CMS Medicare Advantage data and the USDA 2024 UIC.

Appendix Tables

Average Out-of-Pocket Limits in Medicare Advantage by State, 2026 (Table)
Average Out-of-Pocket Limits and Maximum Out-of-Pocket  Limits, 2017-2026 (Table)