Understanding Medicaid Home Care Amid CMS Focus on Potential Fraud and Abuse

Published: Feb 24, 2026

Potential fraud in state Medicaid programs is getting renewed attention, with a recent emphasis on home care, also known as personal care or in-home supportive services. Home care helps with self-care activities such as bathing, dressing, and eating for older adults and people with disabilities. KFF estimates that over 5 million people use Medicaid home care, which allows individuals to receive long-term care without moving into an institution. The Trump administration has recently pointed to Medicaid home care as a source of fraud. Medicaid home care is susceptible to fraud because services are provided in people’s homes to vulnerable individuals who may be less able to advocate for themselves, including some with Alzheimer’s and other dementias. However, there are also additional safeguards against fraud in Medicaid home care compared to other types of Medicaid services. This issue brief describes how Medicaid home care operates, including who is eligible, the various systems in place to promote program integrity in its delivery, and challenges using data newly released by the Centers for Medicare and Medicaid Services (CMS). Key takeaways include the following.

  • All states provide optional home care services to people whose needs are sufficient to warrant institutionalization. An institutional level of care is generally beyond what family members are capable of providing.
  • Recognizing the higher risk of fraud in Medicaid home care, federal and state governments have implemented additional tools to identify and detect home care fraud. States, along with the federal government, use provider credentialing and enrollment and data analytics to help prevent fraud. There has been new attention on fraud in Minnesota’s Medicaid program recently, but the fraud, and the state’s work to root it out, date back at least 18 months. 
  • On February 14, 2026, CMS released a dataset with provider-level spending data that the agency suggests could be used to identify unusual billing patterns for specific services, states, or providers, but the limited data could result in mistaken conclusions. Home care is a major emphasis of the new dataset, which stems from the fact that second to hospital spending, long-term care is the second-largest source of Medicaid spending. Although Medicaid long-term care was historically provided primarily in nursing facilities, most enrollees now recieve home care.

Why does Medicaid cover home care and who is eligible for services?

All states provide optional home care services. Under Medicaid, states are required to cover long-term care provided in nursing facilities, but not home care, which has been referred to as the “institutional bias” in Medicaid. States may only provide home care if they can demonstrate that providing the services would cost no more than institutional care would cost for an individual. All states choose to provide optional home care to people who would otherwise require institutionalization. The increased availability of home care reflects people’s preferences to remain in their homes. Expansions of Medicaid home care services also followed the 1999 Supreme Court ruling in Olmstead v. L.C., which declared that unjustified institutionalization of people with disabilities by a public entity (including Medicaid) is a form of discrimination and not permissible under the 1990 Americans with Disabilities Act. Even though nearly all of the benefits are optional for states to provide, the majority of people who use long-term care now do so at home.

Medicaid home care use is limited by eligibility criteria that generally make it only available to people whose needs are sufficient to warrant institutionalization. To be eligible for Medicaid home care, applicants must meet both financial and “functional” eligibility criteria. Functional eligibility for Medicaid home care, which is evaluated by assessment tools developed by states, generally requires individuals to demonstrate that they need an institutional level of care. There are no recent data available about states’ specific definitions for an institutional level of care, but it generally indicates that people would require 24-hour services and assistance with multiple activities of daily living (ADLs), which include bathing, dressing, eating, toileting, continence, and transferring between bed and other settings.

An institutional level of care is generally beyond what family members are capable of providing. People who require an institutional level of care generally have complex needs that require both skilled and unskilled services and often require services to be provided around the clock. In some cases, family caregivers may not have the medical expertise to provide services, but there are also challenges related to the physical demands of the job and having time to provide such intensive services. Helping family members to bathe, dress, and toilet themselves often requires the strength to lift them, which not all family members have. The time required to provide such intensive services also makes it difficult for family caregivers to provide this level of care and maintain employment or take care of their own health needs. KFF’s focus groups with paid and unpaid family caregivers provide detail that caregiving is physically, mentally, and emotionally challenging; and that family caregivers cannot provide an institutional level of care without supports. To help people requiring an institutional level of care remain at home, Medicaid supports family caregivers by providing supplemental paid care and with direct supports, such as respite care, training, and in some cases payments to the family caregivers to reflect the fact that caregiving makes it impossible to maintain outside employment.

What program integrity tools for Medicaid home care exist?

Recognizing the higher risk of fraud in Medicaid home care, federal and state governments have implemented additional tools to identify and detect home care fraud. In 2016, Congress passed the 21st Century Cures Act, which requires states to implement electronic visit verification for all Medicaid personal care and home health services if a visit is made to a person in the home. State’s electronic visit verification must include six data elements: member receiving the services, caregiver providing the service, type of service, location of the service delivery, date of the service, and time the service begins and ends. Electronic visit verification was established to help promote fiscal integrity for Medicaid home care, and states had until 2023 to fully implement the requirements. The Health and Human Services Office of Inspector General (HHS OIG) has an active project underway to evaluate the availability and completeness of the electronic visit verification data and how states are using the data to promote program integrity.

An HHS OIG report finds that in fiscal year 2024, there were 298 fraud convictions “involving personal care service attendants” from the Medicaid fraud control units, which was 36% of all fraud convictions through the Medicaid fraud control unit, more than that of any other provider type. Although significant, the number of fraud convictions (total and as a percentage of all convictions) is notably lower than the average from 2015-2022 before electronic visit verification was fully in place. During the prior years, fraud convictions involving personal care service attendants averaged well over 400 each year and 43% of all convictions. The amount of money recovered from all convictions is small ($961 million in FY 2024 or $536 million on a 5-year average basis) relative to Medicaid spending.

States, along with the federal government, use provider credentialing and enrollment and data analytics to help prevent fraud. Providers must meet certain state and federal requirements to be eligible to participate in the Medicaid program. Additionally, states use data analytics to confirm that providers have not previously been convicted of committing Medicare fraud or fraud in a different state’s Medicaid program, and to identify unusual billing patterns for specific services or by specific providers. When Minnesota uncovered fraud in its Medicaid home care programs in 2024, the state undertook a series of actions to address that fraud, including targeting specific providers and specific types of services (Box 1).

Box 1: Minnesota’s Actions Towards Maintaining Program Integrity for Medicaid Home Care

In January 2026, CMS administrator Dr. Mehmet Oz issued a letter to Minnesota governor Tim Waltz notifying him that the state of Minnesota’s Medicaid program was not in compliance with federal requirements that help to prevent, detect, and address fraud, waste, and abuse. The letter noted that CMS would start withholding a minimum of $515 million each quarter until CMS determined that the state had satisfactorily met federal requirements.

There has been fraud in Minnesota’s home care programs, and the state has taken steps to address it. On December 5, 2026, CMS gave the state 26 days to send a corrective action plan to address fraud. CMS rejected the plan within one week of receiving it. Minnesota is appealing CMS’ decision and submitted a revised corrective action plan on January 30, 2026.

The state outlines taking the following actions in response to combating home care fraud:

  • Terminating the Housing Stabilization Services program entirely (one of the recent sources of fraud),
  • Auditing autism services providers and conducting onsite visits (another source of recent fraud),
  • Adding new licensure requirements for autism centers,
  • Pausing admission of any new providers into 13 high-risk Medicaid services,
  • Conducting unannounced site visits for providers of high-risk services as part of the regular revalidation process,
  • Enhancing review of claims before they are paid including with increased use of data analytics and Artificial Intelligence (AI),
  • Increasing training for Medicaid providers and employees, and
  • Increasing oversight over Medicaid managed care organizations.

CMS’ approach towards fraud in Minnesota is a significant departure from prior practice. Historically, CMS has used disallowances to deny claims for payments that have been deemed impermissible and has worked collaboratively with states to recoup the funds. Under its new process — known as the “compliance process” — CMS can withhold future payments if the Administrator determines that there is a “failure to comply substantially” with one or more Medicaid requirements. In Minnesota’s case, CMS is effectively withholding funds in anticipation of future fraud.

What do newly released data about home care spending mean?

On February 14, 2026, CMS released a dataset with provider-level spending data that the agency suggests could be used to identify unusual billing patterns for specific services, states, or providers, but the limited data could result in mistaken conclusions. The data include seven fields, including the number of beneficiaries seen, counts of services, and the total spending for each procedure that is included in the data, but they omit significant elements important for pursuing meaningful analyses. With the data release, CMS posted figures to illustrate how the data could be used, with one of the figures displaying total spending among the top 20 procedures in the Medicaid data. The data show that personal care (the primary home care benefit) is the top procedure in terms of spending. However, the personal care “procedure” encompasses a wide range of services that may vary in complexity, difficulty, and length of visit (ranging from less than 30 minutes up to an entire day). In comparison, spending on emergency department visits is split among multiple procedure codes based on the complexity of the case and spending on psychotherapy is split based on the length of the visit (e.g., 30-minute visits and 45-minute visits are considered separate procedures). The data exclude all institutional records and all information about prescription drugs, which are significant shares of Medicaid spending, with hospital care accounting for 37% and being the single largest source of Medicaid spending.

Understanding the context for increases in home care spending is important context for interpreting spending data. Increased spending on Medicaid home care reflects state and federal policy choices to increase the availability of home care in lieu of institutional care when feasible. Analyses of federal spending on long-term care show that home care has grown from 1% of all long-term care spending in 1981 to 64% in 2023. Although the shift away from institutional care dates to the 1980s, the COVID-19 pandemic shone a new spotlight on the challenges of institutional care and illuminated the extent of unmet need for home care. In response, states expanded the availability of home care, increased payment rates for workers in home care settings, and made other efforts to help people remain at home rather than institutional settings. Between 2019 and 2023, the number of Medicaid home care users increased by over 750,000 people. In general, expansions of home care have garnered bipartisan support, with both 2024 presidential candidates expressing support for investments in family caregivers and more at-home services for people who need long-term care.

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

Medicaid Postpartum Coverage Extension Tracker

Published: Feb 24, 2026

The Medicaid program finances about 4 in 10 births in the U.S. Federal law requires states to provide pregnancy-related Medicaid coverage through 60 days postpartum. After that period, some postpartum individuals may qualify for Medicaid through another pathway, but others may lose coverage, particularly in non-expansion states. To help improve maternal health and coverage stability and to help address racial disparities in maternal health, a provision in the American Rescue Plan Act of 2021 gave states a new option to extend Medicaid postpartum coverage to 12 months via a state plan amendment (SPA). This new option took effect on April 1, 2022 and was originally available for five years; however, the option was made permanent by the Consolidated Appropriations Act 2023. The Centers for Medicare and Medicaid Services (CMS) released guidance on December 7, 2021 on how states could implement this option.

States that sought to implement extended postpartum coverage prior to April 1, 2022 have done so through a section 1115 waiver or by using state funds. This page tracks state actions to implement extended Medicaid postpartum coverage, including states that have implemented a 12-month postpartum extension, states that are planning to implement a 12-month extension, states with pending legislation to seek federal approval through a SPA or 1115 waiver, and states that have proposed or received approval for a limited coverage extension.

Medicaid Postpartum Coverage Extensions: Approved and Pending State Action as of February 24, 2026

Postpartum Coverage Tracker MapP

Medicaid Postpartum Coverage Extensions: Approved and Pending State Action as of February 24, 2026

>

Opioid Overdose Deaths: National Trends and Variation by Demographics and States

Published: Feb 24, 2026

Since the opioid epidemic was declared a public health emergency in 2017, it has claimed more than half a million lives. While the epidemic was initially driven by prescription opioids and heroin, it has evolved in recent years, to be dominated by illicit synthetic fentanyl—a substance significantly more potent than morphine. By 2023, most counterfeit opioid pills contained a deadly dose. As of 2022, nearly 1 in 3 adults reported in a KFF survey that they or a family member have been addicted to opioids (29%).

Leading up to and during the pandemic, opioid overdose deaths increased sharply. Deaths began to fall in mid-2023 and have continued to decline, though they remain above pre-pandemic levels. While it is not possible to identify a single driver of the decline, multiple policy actions may have contributed. These policies included efforts to expand access to treatment and overdose-reversal drugs and public awareness efforts about counterfeit opioid pills. They also included supply-side actions aimed at improving fentanyl detection at the ports and borders and limiting the flow of precursor chemicals used to manufacture illicit fentanyl abroad. These efforts coincided with indicators of shifting fentanyl supply, including DEA testing that suggested lower fentanyl potency in counterfeit pills.

Despite progress, a range of more recent federal policy actions may affect future trends, including federal budget cuts, federal staffing reductions, and cuts to federal grants that support state and local programs; reduced Medicaid and Marketplace coverage; and a shift toward a more enforcement-focused approach, including the designation of illicit fentanyl as a “Weapon of Mass Destruction.” This analysis examines opioid overdose deaths over time – including 2024 (the latest finalized data available through CDC WONDER data) – and trends across demographic groups and states. Additional data can be found on KFF’s State Health Facts.

Key Takeaways:

Overall trends: Opioid overdose deaths fell sharply from 2023 to 2024 (79,358 to 54,045), driven largely by decreases in fentanyl-involved deaths. Even after these declines, deaths remained above 2019, the year before opioid deaths increased sharply during the pandemic.

Demographic variation: In 2024, opioid death rates were the highest among those aged 26-64, AIAN people, Black people, and males. All demographic groups saw declines in opioid death rates from 2023 to 2024. However, most groups still had higher rates in 2024 than in 2019.

State variation: State rates in 2024 ranged from 3.3 per 100,000 in Nebraska to 38.6 per 100,000 in West Virginia. From 2023 to 2024, opioid death rates fell across all states, with the largest drops in Virginia (-44%), Wisconsin (-44%), and West Virginia (-46%). About half of states remained above 2019 levels, which may reflect differences in the timing of fentanyl’s spread and state policy.

Opioid overdose deaths fell sharply in 2024, nearing pre-pandemic levels but remaining above 2019 (Figure 1). Total drug overdose deaths dropped from 105,007 in 2023 to 79,384 in 2024 (-24%), while opioid deaths fell from 79,358 to 54,045. Provisional CDC data suggest opioid deaths have continued to decline through 2025. By 2024, opioid deaths were near but still above pre-pandemic (2019) levels, about 4,200 higher than in 2019, the year before the sharp pandemic-era rise in opioid deaths.

Opioid Overdose Deaths Fell Sharply in 2024, Nearing Pre-Pandemic Levels but Remaining Above 2019

Fentanyl was involved in most opioid overdose deaths in 2024 (Figure 1). Declines in fentanyl-involved deaths drove the overall drop in opioid deaths. Deaths involving other opioids, including prescription opioids and heroin, also declined but to a lesser extent. Opioid overdose deaths include fatalities of unintentional, intentional (suicide or homicide), and unknown intent. Any drug overdose death involving opioids is counted as an opioid overdose death. Because more than one opioid can be involved in a single death, opioid subcategories do not sum to total opioid deaths.

How do opioid deaths vary across demographics?

In 2024, opioid death rates were highest among adults ages 26 to 64, American Indian/Alaska Native (AIAN) people, Black people, and males (Figure 2). Rates were highest among adults ages 26 to 44 and 45 to 64 (29.1 and 24.9 per 100,000, respectively), well above other age groups. By race and ethnicity, AIAN people had the highest opioid death rate (35.5 per 100,000), and Black people had somewhat higher rates than White people (22.8 vs. 17.5 per 100,000), a reversal from earlier in the opioid epidemic when rates were higher among White people. Because White people make up a much larger share of the population, the number of deaths was highest among White people (33,105), followed by Black people (10,202) and AIAN people (845), even though rates were higher among Black and AIAN people. Opioid death rates among males were more than double those of females.

Opioid Overdose Death Rates are Highest Among AIAN People, Black People, and Those Ages 26 to 64

From 2023 to 2024, opioid overdose death rates declined across all demographic groups (Figure 3). Young adults (ages 18 to 25) saw the largest decline (-42%), while adults ages 65+, saw the smallest (-20%). Declines by race and ethnicity ranged from -28% among AIAN people to -39% among Black people, and rates fell for both males and females. 

Most demographic groups continued to have higher opioid death rates in 2024 than in 2019 (Figure 3). Rates remained especially elevated among AIAN people (+101%) and adults ages 65+ (+63%). Slower declines among older adults may reflect that SUD can be harder to detect and treat and that few treatment programs are tailored to older adults. Two groups had lower rates in 2024 than in 2019: White people (-9%) and young adults ages 18-25 (-30%). Declines among White people relative to other race and ethnicity groups may partly reflect better access to opioid use disorder treatment.

Opioid Overdose Death Rates Fell Across Every Demographic Group from 2023 to 2024, but Most Remained Above Pre-Pandemic (2019) Levels

How do opioid deaths vary across states?

Opioid overdose death rates varied across states in 2024, ranging from 3.3 per 100,000 in Nebraska to 38.6 in West Virginia (Figure 4). Nebraska, South Dakota, and Iowa had the lowest opioid death rates, (3.3, 5.4, and 5.8 deaths per 100,000 people, respectively). Rates were the highest in the District of Columbia (34.1 per 100,000), Alaska (37.0), and West Virginia (38.6).

Opioid overdose death rates vary widely across states, 2024

All states had declines in opioid overdose death rates from 2023 to 2024, but the size of the decline varied widely. Rates fell by 5% in South Dakota and 8% in Alaska, compared with larger drops of 44% in Wisconsin and Virginia and 46% in West Virginia (Figure 5). KFF State Health Facts provides opioid overdose rates by state for 1999-2024.

By 2024, about half of states continued to have opioid overdose rates above 2019 levels. Several states were close to pre-pandemic levels, including D.C. and Utah (+1%, +2%, respectively). Over one-third of states (39%) had rates that dipped below 2019 levels, with the largest declines in NJ (-42%), Ohio and Massachusetts (each -36%). Alaska and Oregon had the largest increases relative to 2019 (+239% and +226%) (Figure 5).

Opioid Overdose Death Rates Fell in Every State in 2024, but About Half Remained Above Pre-Pandemic (2019) Levels

State differences in opioid-related policy and the timing of fentanyl spread may help explain variation in opioid overdose death trends. Differences in how states use state opioid response grants and settlement funds, and how states structure Medicaid coverage for substance use services, including whether they adopt federal opportunities to expand treatment access may affect outcomes. Fentanyl spread unevenly across states over time, generally moving from east to west. As a result, some states experienced earlier increases, often before the pandemic, while others saw their steepest growth later. These policy and timing differences can affect how states’ 2024 rates compare with 2019. 

Suicide Deaths: National Trends and Variation by Demographics and States

Published: Feb 24, 2026

From 2014 to 2024, over half a million lives (516,790) were lost to suicide, with 2022 marking the highest annual total on record. Since then, overall suicides have declined somewhat, but trends diverged by method: firearm suicides continued to rise, reaching a new high in 2024. As a result, firearms accounted for 57% of all suicides in 2024, up from 50% in 2014, while suicides by other methods fell. Some of the shift may also reflect undercounting if some suicides are recorded as unintentional drug overdose deaths. These shifts may have implications for prevention strategies including the capacity and design of crisis and treatment systems.

In July 2022, the 988 Suicide and Crisis Lifeline launched nationwide, replacing the prior 10-digit number with an easier to remember, three-digit option that connects people in distress to counselors at 200+ local crisis call centers and, when needed, other crisis services. Since launch through October 2025, 988 has received more than 19 million calls, texts, or chats nationally, alongside improved answer rates and shorter wait times.

The combination of 988, other benefit expansions and distance from the pandemic may be factors contributing to small declines in overall in suicides since the 2022 peak; however access to mental health and substance use disorder treatment gaps persist. In 2025, the Trump administration discontinued the LGBTQI+ 988 call line and advanced an array of federal policy actions that could limit access to care including projected coverage loss in Medicaid and the Marketplace.

Key takeaways from analysis of CDC WONDER data from 2014 to 2024, which represents the most recent and comprehensive data available include the following:

Overall death rate: The age-adjusted suicide death rate in 2024 was 13.7 per 100,000 people.

Overall trends: Suicide deaths fell slightly from their peak of 49,476 deaths in 2022 to 48,824 deaths in 2024, but trends by suicide method diverged: suicides by other means declined while firearm suicides reached their highest level and accounted for 57% of all suicides (up from 50% in 2014).

Demographic variation: In 2024, suicide death rates were highest among AIAN people and males (22.5 and 22.3 per 100,000, respectively). Over the past decade, rates increased the most for Black people, while rates were stable or declined somewhat for adults ages 45 to 64 and females.

State variation: State suicide death rates in 2024 ranged from 5.7 per 100,000 in Washington D.C. to 29.7 in Alaska. About four in ten states had stable or lower rates than in 2014, while rates increased in the remaining states, ranging from a 27% decrease in Washington D.C. to a 35% increase in Wyoming. Rates tended to be higher in many Western states, while lower rates were more common in parts of the Northeast and a few coastal states.

Firearm suicides reached their highest level in 2024, while suicides of other means decreased (Figure 1). Total suicide deaths peaked in 2022 and fell slightly by 2024 (about 600 fewer deaths). Even as overall suicides decreased, firearm suicides rose to their highest level in 2024, about 6,000 higher than in 2014, and accounted for 57% of all suicides in 2024 (up from 50% a decade ago). The increase has coincided with changes in gun ownership, including a surge in new buyers during the pandemic and greater racial and ethnic diversity among gun owners. Because firearms are highly lethal, greater access can reduce opportunities for intervention. Some state policies, including extreme risk protection orders (ERPOs) and other gun laws, have been linked to declines in firearm suicides.

Firearm Suicides Reached Their Highest Level in 2024, While Suicides of Other Means Decreased

How do suicide deaths vary across demographics?

Overall suicide death rates were highest among AIAN people and males in 2024 (Figure 2). AIAN people had the highest suicide death rate (22.5 per 100,000), higher than the rate among White people (17.2), while rates for other racial and ethnic groups were lower. Because White people make up a much larger share of the population, the total number of suicide deaths was higher among White people than AIAN people (36,560 vs. 545), even though AIAN people had a higher suicide death rate. While females are more likely to report mental illness and to attempt suicide, males had a suicide death rate about four times higher (22.3 versus 5.6 per 100,000). There are similar suicide rates across age groups in 2024 except that adolescent rates are lower (5.7 per 100,000) than other age groups.

Overall Suicide Death Rates Were Highest Among AIAN People and Males

Over the past decade, suicide death rates increased faster for younger than older adults and more for people of color than White people, while declining somewhat for adults ages 45 to 64 and females (Figure 3). From 2014 to 2024, rates increased 17% among adults ages 18 to 25 (from 13.4 to 15.7 per 100,000) and 13% among those ages 26 to 44 (from 15.9 to 18.0), while rates were mostly flat or declined among older age groups. Rates increased more among people of color than among White people, with the largest increase among Black people (up 53%, from 5.7 to 8.7), followed by Hispanic people (up 27%, from 6.3 to 8.0). In contrast, suicide rates among White people were more stable, rising 5% over the same period (from 16.4 to 17.2). Increasing suicide rates among people of color may reflect differences in diagnosis and access to mental health care, as well as stigma and discrimination. Trends may also be influenced by shifts in firearm access and potential racial and ethnic differences in 988 awareness, use, or perceived helpfulness.

Suicide Death Rates Increased Faster for Younger Than Older Adults and More for People of Color Than White People, While Declining Somewhat for Adults Ages 45 to 64 and Females

How do suicide deaths vary across states?

Suicide death rates varied widely across states in 2024 (Figure 4). Rates ranged from 5.7 deaths per 100,000 people in the District of Columbia (D.C.) to 29.7 in Alaska, with a median death rate of 15.4 per 100,000. Rates tended to be higher in many Western states, while lower rates were more common in parts of the Northeast and a few coastal states. The suicide rate may vary by state due to factors such as demographics, firearm availability, mental health status, and access to mental health and crisis services.

Suicide death rates range widely across states

About four in ten states had stable or lower suicide death rates than a decade ago, while suicide death rates increased in other states (Figure 5). Between 2014 and 2024, suicide death rates decreased or were relatively stable in 22 states. The largest declines were in D.C. (-27%, from 7.8 to 5.7 per 100,000), Vermont (-21%, from 18.7 to 14.7), and New Jersey (-19%, from 8.3 to 6.7). Rates increased by 15% or more in 10 states, with the largest increases in Wyoming (35% increase, from 20.6 to 27.8), Alaska (34% increase, from 22.1 to 29.7), and Iowa (33% increase, from 12.9 to 17.1).

About Four in Ten States Had Stable or Lower Suicide Death Rates Than A Decade Ago, While Other States Increased

If you or someone you know is considering suicide, contact the 988 Suicide & Crisis Lifeline at 988.

Alcohol Deaths: National Trends and Variation by Demographics and States

Published: Feb 24, 2026

Alcohol use disorder (AUD) is the most prevalent non-tobacco substance use disorder in the United States and over half of US adults (54%) say that someone in their family has struggled with an alcohol use disorder. Federal data show that 1 in 10 Americans (ages 12+) had an AUD in the past year and over 40% of drinkers reported binge drinking in the past month, yet only one-third of adults view alcohol addiction as a “crisis,” compared to over half who see opioids as such.

In early January 2026, the Department of Health and Human Services (HHS) released the updated 2025-2030 Dietary Guidelines for Americans (DGA). The report marks a departure from decades of guidelines that set recommendations to limit intake to specific daily caps (formerly one drink for women and two for men), instead advising people to “drink less for better overall health.” Without clear thresholds, it may be harder for individuals and clinicians to identify when clinical screening or treatment is warranted. This challenge is compounded by low public awareness of alcohol’s health risks. For example, fewer than 40% of US adults are aware that alcohol is a carcinogen, compared to over 90% awareness of tobacco’s link to cancer. In addition, clinical screening for AUD is inconsistent and treatment rates for AUDs are low. For those receiving or seeking treatment, a range of recent federal policy actions may affect future treatment access, including substantial coverage losses in Medicaid and Marketplace coverage.

This analysis largely focuses on the narrowest definition of alcohol deaths known as “alcohol-induced deaths” (referred to as “alcohol deaths” throughout the brief). These alcohol deaths are caused by conditions directly attributable to alcohol consumption, such as alcohol-associated liver diseases. Broader definitions of alcohol deaths extend this definition to also encompass cases where an alcohol-induced condition was a contributing factor, but not the underlying cause of death. Key takeaways from this analysis of CDC WONDER data from 2014 to 2024 include the following:

Key takeaways:

Overall trends: Alcohol deaths increased gradually before the pandemic, jumped in 2020 and 2021, and have fallen somewhat since then. Even after these declines, deaths remained above 2019, the year before the pandemic.

Demographic variation: In 2024, alcohol deaths were highest among adults ages 45 to 64, American Indian and Alaska Native (AIAN) people, and males. By 2024, alcohol death rates remained above 2019 levels for several groups; the groups most above their 2019 rates were adults ages 26 to 44, 65+, White people, and females.

State variation: State rates in 2024 ranged from 6.1 per 100,000 in New Jersey to 35.9 per 100,000 in New Mexico. In 2024, alcohol death rates remained higher than 2019 rates for most states. Changes ranged from declines in New Jersey (-9%) and West Virginia (-6%) to an 80% increase in Mississippi.

Alcohol deaths are down from their peak but still above pre-pandemic levels (Figure 1). Alcohol deaths increased gradually before the pandemic, jumped in early pandemic years, and have declined somewhat since then. From 2014 to 2024, the year-over-year rise in alcohol deaths averaged about 5% per year, with the largest single-year jump from 2019 to 2020 (+26%). Deaths peaked in 2021 (54,258) and have fallen since. Even with declines after 2021, in 2024 alcohol deaths were still about 50% higher than a decade ago and about 20% higher than in 2019, the year before the pandemic.

Alcohol-Induced Deaths Are Down from Their Peak but Still Above Pre-Pandemic Levels

How do alcohol death rates vary across demographics?

Alcohol deaths in 2024 were highest among adults ages 45 to 64, American Indian and Alaska Native (AIAN) people, and males (Figure 2). By age, alcohol death rates peaked among adults ages 45 to 64 (28.9 per 100,000) and were next highest among adults 65 and older (21.5 per 100,000). AIAN people had the highest alcohol death rate across all demographic groups (57.9 per 100,000), more than four times the rate among White people, the racial group with the next highest rate. Because White people make up a much larger share of the population, the total number of deaths was higher among White people (32,849 vs. 1,424), even though AIAN people had the higher death rate. Alcohol death rates among males (17.3 per 100,000) were more than double those among females.

Alcohol Death Rates are the Highest Among Adults Ages 45 to 64, American Indian or Alaska Native People, and Males

Alcohol death rates remained above pre-pandemic (2019) levels in 2024, especially for adults ages 26-44, 65+, White people, and females (Figure 3). Rates increased gradually before the pandemic, rose sharply in 2020 and 2021, and then declined from their peak, but not enough to return to 2019 levels. Adults ages 26 to 44 had the largest continued increases, with 2024 rates 38% higher than in 2019. Adults ages 65 and older also remained elevated, with 2024 rates about 22% higher than in 2019. Rates among White people remained about 20% higher than pre-pandemic levels and higher than rates among other race and ethnicity groups. Female alcohol death rates were still about 20% above 2019 levels, while male rates were closer to pre-pandemic levels.

Alcohol Death Rates Remained Above Pre-Pandemic (2019) Levels in 2024, Especially for Ages 26–44, 65+, White People, and Females

How do alcohol death rates vary across states?

Alcohol death rates varied widely across states in 2024 (Figure 4). Alcohol-induced death rates ranged from 6.1 per 100,000 in New Jersey to a 35.9 per 100,000 in New Mexico. Higher rates tended to be concentrated in the West, particularly in the Mountain West (and Alaska), while lower rates were more common across parts of the South and the Northeast. Many factors may contribute to the differences in alcohol mortality rates across states, some of which may include differences in alcohol consumption, cultural attitudes, state-specific alcohol policies, and treatment rates.

Alcohol Death Rates Vary Widely Across States, 2024

In 2024, alcohol death rates remained higher than pre-pandemic (2019) levels in most states, though the magnitude varied widely (Figure 5). Changes from 2019 to 2024 ranged from declines in New Jersey (-9%) and West Virginia (-6%) to large increases in Mississippi (+80%) and South Dakota (+63%). Leading up to the pandemic, most states had modest steady increases, though growth was faster in some more rural states, including Wyoming, Montana, Arkansas, and North Dakota. Consistent with national patterns described above, many states experienced their sharpest increases in 2020 and 2021 and then declined somewhat from their peak, but in most states, 2024 rates remained above 2019 levels. South Dakota and Mississippi saw especially large early-pandemic increases and only modest declines afterwards, leaving them with the largest percent increases in alcohol death rates from 2019 to 2024.

In 2024, Alcohol Death Rates Remained Higher Than Pre-Pandemic (2019) Levels in Most States, but to a Varying Extent

What factors may contribute to alcohol deaths?

Alcohol is linked to far more deaths when broader definitions are used (Figure 6). Many alcohol-related conditions develop over time, and alcohol can also worsen other health problems or contribute to injuries, which complicates how alcohol deaths are counted. This analysis uses a narrow definition, counting only deaths where alcohol is listed as the underlying cause on the death certificate, such as alcohol-related liver disease. When deaths are also counted where alcohol is listed as a contributing cause on the death certificate (“alcohol-related deaths”), the total number of deaths nearly doubles, reaching 93,118 in 2024 (Figure 5). Under this broader definition, alcohol-related deaths exceeded opioid overdose deaths (55,535 opioid deaths when underlying and contributing cause are included), and opioid deaths change little when moving from the narrow to broader definition (54,045 under the narrow definition). Others methods can produce even higher estimates of alcohol deaths by accounting for deaths that alcohol increases the risk of, even when alcohol is unlikely to be recorded on the death certificate, such as certain cancers.

Alcohol Is Listed in Nearly Twice as Many Deaths When Contributing Causes Are Included

Alcohol treatment rates are low, reflecting a mix of provider, patient, and financial barriers. In 2022, only 7.6% of people ages 12 and older with a past-year alcohol use disorder (AUD) received any treatment, and fewer (2.1%) received evidence-based AUD medication. Providers may lack confidence or knowledge in treating AUD and prescribing AUD medication, which can reduce treatment initiation or referrals. On the patient side, limited understanding of what constitutes problematic drinking and attitudes towards seeking treatment can hinder recognition of need for help. Among adults who meet the criteria for SUD—which may include symptoms like increased tolerance, repeated attempts to quit or control use, or social problems related to use–95% did not seek treatment and didn’t think they needed it. Even when people want care, practical constraints such as coverage limits, treatment availability, paid leave, and out-of-pocket costs can affect decisions about whether they start or stay in treatment.

TrumpRx: What’s the Value for Customers?

Published: Feb 24, 2026

Editorial Note

This brief was updated on February 24, 2026, to clarify the requirements for health savings accounts.

Introduction

The cost of prescription drugs is a top health policy issue for consumers and policymakers. Half of the people in the United States take at least one prescription drug, and KFF polling from 2025 found that more than 1 in 4 adults under age 65 report difficulty affording their medication; these shares are much higher among those with individual insurance and the uninsured. Aimed at addressing high prescription drug costs, on February 6, 2026, the Trump administration launched TrumpRx, a government website that provides prescription drug discounts to consumers. This Issue Brief examines issues that may impact consumers who access drug discounts through TrumpRx, particularly those with private insurance, and sets out key policy questions going forward.

What is TrumpRx?

In an effort to reduce prescription drug costs, a May 2025 Executive Order seeks to facilitate an option for consumers to purchase prescription drugs at the “most-favored-nation” (MFN) price directly from the drug manufacturer (“direct-to-consumer” purchasing). MFN prices refer to the lowest prices paid in comparable countries. The Trump administration announced that it had made deals with drug manufacturers and negotiated MFN pricing for a range of medications. The details of these deals are confidential and not available to the public.

TrumpRx is an online platform that consumers can use to search for discounted, ostensibly MFN, prices on brand-name medications when paying without using insurance (referred to as “self-pay” or sometimes “cash-pay”). TrumpRx does not offer direct-to-consumer (DTC) purchasing, meaning patients cannot purchase these medications from the TrumpRx website. Instead, for the majority of its advertised drugs, it allows consumers to print drug manufacturer coupons that can be used at retail pharmacies at the time of purchase. Many of the self-pay discounted prices shown on TrumpRx are also available via DTC options on the manufacturer’s website, but in most cases, this requires consumers to go to the manufacturer’s website, search for the drug, and find and interpret the written information describing the discount. Just eight of the advertised drugs on TrumpRx direct consumers to the specific pharmacies (often linked via the manufacturer’s website) where they can purchase the drug directly at the discounted price shown on TrumpRx. In all cases, a valid prescription is still needed to buy the medication.

As of February 20, 2026, 43 different prescription medications from five manufacturers were listed on TrumpRx, used in the treatment of a range of conditions, such as asthma, arthritis, infertility, and diabetes. The 43 prescription drugs currently listed on TrumpRx include one “authorized generic” (of a brand-name product from the same manufacturer) and one biosimilar; the rest are brand-name drugs. There are currently more than 24,000 FDA-approved prescription drugs in the U.S. Additionally, the terms and conditions listed on most of the TrumpRx coupons indicate that they cannot be used in California or Massachusetts. State law in California and Massachusetts prohibit the use of prescription drug coupons unless a generic equivalent is unavailable.

What Sources of Discounted Drug Pricing Already Exist?

Drug discounts have been available for a long time, via different mechanisms and for different populations. From drug manufacturers, there are “copay assistance” coupons for people using private health insurance; free trial offers; discounts for self-pay consumers purchasing the drug directly; and “patient assistance programs” specifically for certain uninsured and/or low-income people. Separately, discounts are offered by several online platforms (such as GoodRx) and online pharmacies (such as Cost Plus Drugs).1

TrumpRx presents one of many avenues for finding discounts on certain drugs. Specifically, those who are insured but choose not to bill through insurance, and those who are uninsured but don’t meet existing requirements for patient assistance programs (such as income), may now be eligible to use these coupons to get discounted prices from manufacturers for drugs included on the platform. While most TrumpRx coupons are also displayed on GoodRx, consumers will find discounts for many more prescription drugs from Cost Plus Drugs and GoodRx than are currently available on TrumpRx.

GoodRx has advertised “exclusive” savings for prescription drugs, including drugs listed on TrumpRx, long before TrumpRx launched. It is not clear how these and other self-pay discounts that drug manufacturers, retailers, or other third-party platforms were already offering before TrumpRx compare to what is available on this new platform. Such comparisons with historic prices are not readily available, but most of the savings from TrumpRx appear to be new. Archived GoodRx pages show that, for most of these drugs, prices available in 2025 or earlier were higher than currently advertised on TrumpRx. Manufacturers with drugs on TrumpRx began announcing their anticipated TrumpRx discounts in late 2025.2 Self-pay discounts for certain dosages of Ozempic, Wegovy, and Zepbound were available prior to TrumpRx and before the Trump administration’s second term, but those prices were higher than their comparable prices now on TrumpRx. According to the manufacturer, the price for the 2 mg dosage of the Ozempic pen ”remains” $499, suggesting that the ”discounted” price shown on TrumpRx does not reflect any recent change.

For those paying with private insurance, many of these drugs already had “copay assistance programs” to help offset some out-of-pocket costs for the commercially insured (and still do). In many cases, out-of-pocket costs could be less than the TrumpRx self-pay discount. 

Comparing TrumpRx Self-Pay Discounts to Private Insurance: Issues to Consider



Evaluating the impact of TrumpRx requires a closer look at how most Americans access prescription medication. Sixty-six percent of people under age 65 have private health insurance, including 58% with employer-sponsored coverage and 8% with individual insurance purchased on or off ACA Marketplaces. Nearly all (99%) workers with employer-sponsored coverage are at a firm that provides prescription drug coverage to enrollees in its largest health plan. 

The discounts currently advertised on TrumpRx are only available to those purchasing medications without using insurance. The “Frequently Asked Questions” at the bottom of the TrumpRx landing page explicitly state that the discounted pricing is only available for “cash-paying” patients. The webpage for each TrumpRx drug notes that patients with insurance should check what their copay would be if using insurance, as it may be even lower than the TrumpRx price.

Due to the complexity of prescription drug pricing and the variation in private insurance plan designs, several factors need to be considered to evaluate the usefulness of TrumpRx for individual consumers. Three illustrative scenarios are provided below.

Patient has private insurance for a TrumpRx drug, and a generic equivalent is not available

Medication covered by an individual’s private insurance may be less expensive when purchased through insurance. Because TrumpRx coupons are for self-pay consumers, dollars paid for a TrumpRx medication will not count toward a consumer’s insurance deductible or out-of-pocket maximum. In contrast, individuals using private health insurance to purchase the drug instead of the TrumpRx coupon or other manufacturer discount will have their out-of-pocket payments count toward their plan’s deductible and out-of-pocket maximum. Since many of these drugs are used by individuals with chronic illnesses who need their medication throughout the year, the out-of-pocket expenditure may contribute significantly to the deductible and out-of-pocket maximum amounts for the plan, affecting the out-of-pocket costs for other services billed to insurance.

Individuals purchasing through insurance will also have access to a negotiated price through their insurer or employer plan. The “savings” listed on TrumpRx for each drug are based on the manufacturer’s list price for drugs sold to wholesalers or direct purchasers (“wholesale acquisition cost,” or WAC) and typically do not directly reflect what consumers pay. The negotiated prices vary across private plans but are typically lower than the WAC. In such a case, consumers could pay less over the year with their insurance, even having to meet a deductible. Specific cost-sharing arrangements, copay or coinsurance, for the drug depend on the plan formulary, but may also be cheaper than the TrumpRx price.

But deductibles matter. While many patients with private insurance could come out ahead in terms of their annual out-of-pocket costs by using their insurance instead of a TrumpRx coupon or other manufacturer discount for a specific medication, growing insurance deductibles for those with private insurance factor into patient choices and might steer people who have insurance to discounted self-pay options via direct-to-consumer (DTC) manufacturer websites or TrumpRx. 

According to the annual KFF Employer Health Benefits Survey (EHBS), among workers covered by employer-sponsored insurance, the average deductible for single coverage was $1,663 in 2025 (including those whose plan does not have a general annual deductible), 23% higher than the average general annual deductible in 2020 ($1,350), and 54% higher than in 2015 ($1,078). Average deductibles are higher for Affordable Care Act (ACA) Marketplace plans sold on HealthCare.gov, though growth over the past decade has increased more slowly than for employer-sponsored plans. In 2025, the average annual individual combined deductible (medical services and drugs) for ACA Marketplace coverage was $2,759. While this is lower than the average deductible in 2020 ($2,962), it is an increase from $1,987 in 2015.3

At least one study has found that for employer-sponsored insurance, out-of-pocket prices for branded retail drugs, on average, increased nearly 6% annually between 2007 and 2020, driven by large increases in deductible and coinsurance payments.

TrumpRx may be an economical option for those who face high out-of-pocket costs for prescription drugs before they meet their plan’s deductible, especially those who do not reach their annual deductible at all. If a consumer, for instance, must pay the retail price for an expensive medication prior to meeting their plan’s deductible, they might look to Trump Rx or DTC self-pay options to reduce their monthly payment for a medication. Self-pay expenses won’t count toward their deductible, but some consumers may choose this option if their monthly income and other household expenses will only allow them to afford the medication at a self-pay discounted price.

Example 1

Terry has a prescription for Prempro to help manage symptoms of menopause. The self-pay discounted price on TrumpRx is $98.84 per month, but she has private health insurance. It is the beginning of the year, though, and Terry has not met any of her plan’s $1,500 annual deductible. If her monthly cost for Prempro is $250 and she has a $30 copay after meeting her deductible, she would pay the full price from January through June, at which point she would have met her $1,500 deductible, then she would just pay the $30 copay from July through December. Assuming no other deductible spending during the year, her total annual out-of-pocket cost for this drug would be $1,680 if she uses her insurance. In this example, she would pay less over the year ($1,186) using the self-pay TrumpRx discount instead of her insurance, though the amount she spends using the discount would not count toward her plan’s deductible or out-of-pocket maximum.

However, some employer plan designs effectively mitigate the impact of high deductibles on prescription drugs. According to the 2025 KFF EHBS, 61% of workers enrolled in an employer-sponsored health plan with a general annual deductible do not have to meet the deductible before prescription drugs are covered. Formularies with a tier for “preferred” brand-name drugs may require a relatively small copay even before the deductible is met. Additionally, 45% of covered workers in firms with 50 or more workers are enrolled in a plan that reduces or waives cost sharing for at least some maintenance drugs for chronic conditions, such as insulin for diabetes. 

Example 2

Using the previous example, now assume that Terry’s insurance covers prescription drugs before meeting the deductible, meaning that she is just responsible for the $30 copay for a month of Prempro. Using her insurance to purchase the drug, she would spend $360 over the year, far less than the $1,186 she would spend if she were to pay using the TrumpRx coupon and bypass insurance.

People enrolled in a high-deductible health plan (HDHP) paired with a health savings account (HSA) must pay all medical costs until they meet their high deductible (at least $1,700 for an individual in 2026) to be eligible to establish or contribute funds to an HSA, with some exceptions.4 These pre-deductible coverage exceptions include certain prescription drugs that are ACA-required preventive services, certain insulin products, and other medications deemed preventive for certain chronic conditions. However, beginning this year, people in bronze and catastrophic individual Marketplace plans can establish and contribute to an HSA regardless of whether the plan meets these (and other) requirements. Employer-sponsored plans must still meet these requirements to be paired with an HSA.

For privately insured patients with chronic disease, copay assistance could also be a factor. Manufacturer “copay assistance programs” specifically for consumers using private health insurance are available for over half of the drugs currently available on TrumpRx, which may lower enrollees’ copay and coinsurance payments to as little as $0/month for some drugs, without TrumpRx discounts. Many health plans (group and individual), however, do not count the value of manufacturer copay coupons toward the enrollee’s deductible or out-of-pocket maximum, a feature known as a “copay adjustment program.” As of 2026, at least 25 states and the District of Columbia prohibit or restrict the use of at least some of these types of programs in certain health insurance plans sold in those states.5 These laws do not apply to those in employer self-insured plans regulated only under federal law. Consumers may need to consult their plan documents to find out whether manufacturer copay assistance can be used and, if so, whether their expenses will count toward their plan’s out-of-pocket obligations.

Patient takes a prescription drug that is discounted on TrumpRx, and a generic equivalent is available

According to one analysis, 90% of all prescriptions filled in the U.S. in 2024 were generics. Regardless of the form of payment (private insurance or self-pay), generic equivalents are often cheaper than brand-name drugs, sometimes even after discounts offered through TrumpRx. About half (22) of the drugs on TrumpRx have generic equivalents available in the U.S., at least three-quarters (17) of which are less expensive via GoodRx discounts or direct purchase from Cost Plus Drugs than the TrumpRx coupon price for the brand-name version. Five brand-name drugs on TrumpRx are less expensive on TrumpRx than their generic equivalents on the other two websites. Generic drugs generally have more favorable cost-sharing arrangements than brand-name drugs through insurance, decreasing patient out-of-pocket responsibility for patients using private insurance. Since usual and customary retail prices for these generic drugs are so much lower than their brand-name equivalents, they are cheaper for self-pay patients as well. There is no disclaimer on TrumpRx stating that consumers could pay less than the TrumpRx price by purchasing a generic alternative.

Example 3

Jo has a prescription for Diflucan for an infection. Her insurance has substituted generic fluconazole instead of the brand-name product, with a $10 copay (before deductible) for one bottle. In this case, even with the coupon, it would be cheaper to use her private insurance instead of self-paying with the coupon, which prices Diflucan at $14.06. Additionally, she finds out that the $10 copay will count toward her plan’s out-of-pocket maximum.

If a generic version is available, pharmacists may substitute the generic equivalent for the brand-name drug (and as of 2022, 17 states and the District of Columbia7 required this) unless the prescriber indicates to “dispense as written” on the prescription or the patient specifically requests the brand-name. In these states, a consumer who presents a TrumpRx coupon at the pharmacy for a brand-name drug might automatically end up paying less without using the coupon when the prescription is filled with a generic. Indeed, the “Frequently Asked Questions” at the bottom of the TrumpRx landing page indicates that pharmacies are not required to dispense the TrumpRx discounted drug.

Example 4

Patrick’s physician has written him a prescription for Farxiga for his diabetes. He is uninsured and goes to a pharmacy to fill the prescription. Although the self-pay price is $700, the pharmacist provides a generic equivalent at around half the price. TrumpRx advertises the discounted brand-name drug for a yet lower price of $181.59.

Example 5

Patricia has rheumatoid arthritis and gets a prescription for Azulfidine. She is uninsured and goes to a pharmacy to fill the prescription. Although the self-pay price is $350, the pharmacy only stocks the generic equivalent at $60 a month. This price is lower than the discounted price for the brand-name product advertised on TrumpRx, $99.60.

Patient does not have insurance, or the TrumpRx drug is not covered by their insurance

Those who have already been paying out-of-pocket for certain drugs may see savings from TrumpRx. Some of the drugs on TrumpRx are typically not covered by private health insurance. For example, the KFF Employer Health Benefits Survey found that just one in five (19%) large employers offering health benefits to workers say they cover costly GLP-1 drugs such as Wegovy and Zepbound when used primarily for weight loss in 2025, and fewer than two in five (37%) reported covering fertility medications in 2024. However, some drug discounts on TrumpRx reflect limited-time offers for lower initial doses for new patients. For example, Wegovy pills start at $149/month but increase to $299/month after two monthly fills (for a higher dose).

Example 6

Carol has a prescription for the fertility drug Cetrotide. Her insurance doesn’t cover this drug at all, so she has been buying it from a direct-to-consumer online pharmacy. She pays $49.50 for the generic version, which is more expensive than the brand-name drug with the TrumpRx coupon, at $22.50.

Example 7

Rob receives a prescription to start using Wegovy, which does not have a generic version. He doesn’t have insurance but is able to afford the drug with the one-time introductory offer via TrumpRx of $149 for a month of pills. After that, the monthly price for the drug goes up to $299, making it unaffordable to Rob for continued use even with the discount.

Other patients who could potentially benefit (at least temporarily) from TrumpRx include those who have a gap in insurance coverage, those whose plan formulary has removed coverage for a needed drug, or those whose insurance has utilization management requirements, such as quantity limits or step therapy. As mentioned above, though, since TrumpRx currently only includes 43 drugs, patients will likely find discounts for a much larger selection of drugs using other self-pay discount platforms or from online pharmacies.

Looking Forward

While TrumpRx offers the hope of cheaper medications, whether it will make a significant difference for most people will depend largely on the breadth of prescription drugs available on the website, the cost of the specific medication, state law or pharmacy policy regarding generic drugs, the plan design of the patient’s private insurance plan, if insured, and, particularly for the uninsured, whether there is a less expensive generic version of the drug. This puts a lot more onus on patients, particularly those with private coverage, to understand the many dynamics at play in determining the best option for them. In some cases, TrumpRx advertisement for these discounted brand-name prescription drugs could have the potential to mislead patients into paying more out-of-pocket than they would if they used their insurance and/or purchased a generic alternative.

Future developments that may further impact patient choices include:

  • Possible options to allow patients to count discount coupons toward insurance deductibles and out-of-pocket maximums. As part of a February 2026 settlement with the Federal Trade Commission, ExpressScripts, one of the largest pharmacy benefit managers (PBMs) in the country, and its affiliates, agreed to “Provide covered access to TrumpRx as part of its standard offering upon relevant legal and regulatory changes” following allegations that it had created a system that had artificially increased drug prices. Under the proposed consent agreement, enrollees serviced by ExpressScripts or its affiliates would be able to count payments made through the TrumpRx platform toward patient deductibles and out-of-pocket maximums. How this would work in practice, as well as how this would affect other discount platforms, is not clear. Also, patients with private coverage are still awaiting implementation of changes to federal standards regarding the use of copay adjustment programs that could consistently allow manufacturer coupons to count toward their insurance cost sharing.
  • Changes to federal law that could expand take-up of high-deductible health plans paired with a health savings account (HSA). The 2025 budget reconciliation law and recent proposed changes increase the availability of Marketplace catastrophic plans. For consumers who turn to these plans, out-of-pocket costs for prescription drugs may increase, potentially steering them to TrumpRx and self-pay DTC options instead of using their insurance. Although, in general, TrumpRx coupons cannot be used with insurance, one manufacturer’s drugs listed on TrumpRx link to the manufacturer’s website, which notes that the expense may be eligible for reimbursement by an HSA.
  • Other federal reforms. Broader efforts than a discount website are likely key to addressing system-wide incentives that work to keep prescription drug prices high for all consumers, those with and without insurance. Since most individuals under 65 have employer-sponsored insurance, an important question going forward for this group is whether other current federal efforts, such as recently passed legislation directed at PBM disclosures and pass-through of rebates to employer plans and pending updates to price transparency regulations for prescription drugs, will lower their drug costs.

Endnotes

  1. GoodRx is a website where consumers can compare discounted self-pay drug prices at retail pharmacies like CVS and Walgreens and access GoodRx coupons whose prices have been negotiated between pharmacies and PBMs. Cost Plus Drugs is an online pharmacy that sells discounted generic (and some brand-name) prescription drugs directly to consumers. ↩︎
  2. All three manufacturers’ announcements noted that their products would be excluded from the Trump administration’s new tariffs in exchange for committing to these agreements. ↩︎
  3. Average deductibles vary significantly by metal level and whether the enrollee is eligible for a cost-sharing reduction. ↩︎
  4. An HSA is a tax-advantaged account that allows people enrolled in certain high-deductible health plans to save and pay for unreimbursed, qualified medical expenses. ↩︎
  5. See https://theaidsinstitute.org/media/documents/TAI-2025-Report.pdf (21 states as of February 2025; https://www.bleeding.org/news/government-relations-update-may-2025 (3 more states as of May 2025); and https://www.nationalmssociety.org/news-and-magazine/news/new-jersey-copay-accumulator-legislation (another state in 2026). ↩︎
  6. An 18th state (Indiana) has a similar requirement, but unlike the other state laws, it only applies for Medicare patients. ↩︎

Quiz – How Well Do You Understand Your Health Insurance?

Published: Feb 23, 2026

Health insurance is often complicated, but understanding the basics helps you make better decisions about your coverage and care. This 10-question quiz touches on some terms you may encounter. Test your knowledge and pick up some useful insights along the way.

Question 1 of 10
Which statement best describes a health insurance premium?
Question 2 of 10
Which of the following is the best definition of the term “annual health insurance deductible”?
Question 3 of 10
Which statement describes the difference between a copayment and coinsurance?
Question 4 of 10
Your health insurance plan has a $1,000 deductible for hospital care and a $250 per-day copayment once the deductible is met. You are hospitalized for 4 days, and the hospital charges negotiated with the insurance company (the “allowed amount”) total $6,000. How much would you be responsible for paying?
Question 5 of 10
Which statement describes a Health Savings Account (HSA)?
Question 6 of 10
When you receive care from an out-of-network medical professional or facility, what costs might you be responsible for? (“Out of network” refers to a doctor, hospital, or facility that does not have a contract with your health insurance plan.)
Question 7 of 10
Under federal “surprise billing” protections, patients are generally shielded from higher out-of-network charges when they receive:
Question 8 of 10
What does it mean when a health care professional says that a test, procedure, or medication requires “prior authorization” in order for insurance to cover it?
Question 9 of 10
Which of the following best describes a prescription drug “formulary”?
Question 10 of 10
Which of the following are required to publicly post prices for health care services?

Medicare Advantage Enrollment Grew by About 1 Million People, Mainly Due to Special Needs Plans

Published: Feb 23, 2026

The Centers for Medicare & Medicaid Services (CMS) released the latest Medicare Advantage enrollment data on February 13, 2026. These data provide the first look into Medicare Advantage enrollment for 2026 following a statement published by CMS last fall that Medicare Advantage insurers projected total enrollment would be lower in 2026 than in 2025. The industry projections came at the same time insurers announced a drop in in the total number of Medicare Advantage plans that would be available for general enrollment (individual plans) in 2026, along with an increase the number of special needs plans (SNPs), which limit enrollment to beneficiaries with specialized health needs or who are eligible for both Medicare and Medicaid.

Overall, the data show that total Medicare Advantage enrollment continued to increase, although at a slower rate of growth than in prior years. The increase in 2026 was largely driven by increased enrollment in SNPs. Decisions made by insurers to expand SNP offerings have translated into enrollment growth in that segment. Enrollment in individual plans increased, but more slowly than in any year between 2007 and 2025. Changes in enrollment varied across the private insurers that sponsor Medicare Advantage plans, with some plans experiencing more rapid growth, while others saw a drop in enrollment.

These patterns suggest that the Medicare Advantage market remains an attractive choice for Medicare beneficiaries. In 2026, the average Medicare beneficiary can choose from among 32 Medicare Advantage plans with prescription drug coverage, most of which have no premium (other than the standard Part B premium) and the vast majority of which offer dental, vision, and hearing benefits, in addition to reduced cost sharing compared to traditional Medicare without a supplement.

Medicare Advantage enrollment reaches 35 million, increasing by 1.1 million since February 2025.

Just over 35 million people are enrolled in Medicare Advantage as of February 1, 2026 (Figure 1). That reflects an increase of 1.1 million people since February 2025, which translates into 3% growth year-over-year. Enrollment in Medicare Advantage has increased steadily over the last two decades, rising from 8 million people (19% of eligible beneficiaries) in 2007 to 34 million people (54% of eligible beneficiaries) in 2025, but the pace of enrollment growth has recently slowed. In 2025, enrollment increased 4%, which was a slower rate of growth than any year between 2007 and 2024 when the increase in enrollment averaged 9% a year.

Total Medicare Advantage Enrollment, 2007-2026

Medicare Advantage is the private plan alternative to traditional Medicare and provides coverage of Medicare Part A and Part B benefits. In most cases, Medicare Advantage plans also offer reduced cost sharing compared to traditional Medicare without supplemental insurance, coverage of non-Medicare services, such as vision, dental and hearing, and Part D benefits, usually for no additional premium (other than the Part B premium).

Special needs plans comprised 83% of the increase in enrollment over the last year.

In February 2026, more than 8 million people are enrolled in a SNP, an increase of nearly 900,000 enrollees since February 2025 (Figure 2), comprising 83% of total Medicare Advantage enrollment growth over the last year. The increase in enrollment in individual plans was much smaller, rising by 224,000 people compared to a year ago. Enrollment in employer- and union-sponsored group plans declined slightly, falling by about 40,000 enrollees compared to February 2025; the number of beneficiaries enrolled in group MA-PDs declined by about 1.2 million, which was mostly offset by a 1.1 million increase in enrollment in employer MA-only plans.

Year-Over-Year Medicare Advantage Enrollment Changes, By Plan Type

The share of Medicare Advantage enrollees in SNPs increased from 21% in 2025 to 23% in 2026. Enrollment growth in SNPs has increased steadily since 2018 (13% of Medicare Advantage enrollment), when these plans were made a permanent part of the Medicare program. (See Appendix Table 1 for detailed data on enrollment by prescription drug coverage and plan type.)

Humana and Kaiser Permanente were the only large insurers to increase enrollment.

Across the five largest Medicare Advantage insurers, only Humana Inc. and Kaiser Foundation Health Plan, Inc. saw an increase in total Medicare Advantage enrollment, with Humana boosting its enrollment by 1.2 million enrollees, and Kaiser Permanente adding a smaller number with 64,000 additional enrollees. (Figure 3). Humana and Kaiser Foundation Health Plan saw enrollment increase across all plan types, that is individual plans, employer- and union sponsored group plans, and special needs plans. In contrast, UnitedHealth Group, Inc., the largest Medicare Advantage insurer, lost over 530,000 enrollees compared to February 2025. That change reflects a decline in enrollment in both individual (-582,000) and group (-219,000) plans that were partially offset by an increase in SNP enrollment (+267,000). CVS Health Corporation has 29,000 fewer enrollees this month than a year ago, reflecting a decline in individual plan enrollment (-81,000) that was partially offset by increases in SNP (+40,000) and group plan (+12,000) enrollment. Elevance Health Inc., which has 368,000 fewer enrollees this year than last, was the only one of the five largest insurers to see a decline in SNP enrollment (-18,000).

Enrollment in plans offered by the 150 insurers with a relatively small number of enrollees (fewer than 1 million enrollees) increased by 734,000 people in 2026. That increase reflects growth in SNPs (+388,000), individual plans (+331,000), and group plans (+15,000). Across small insurers who offered plans in both 2025 and 2026, more than three-quarters saw enrollment increase compared to a year ago.

Change in Medicare Advantage Enrollment By Insurer and Plan Type, 2025-2026

Methods

This analysis uses data from the Centers for Medicare & Medicaid Services (CMS) Medicare Advantage Enrollment and Landscape files. The analysis aggregates enrollment data from the monthly enrollment by contract/plan/state/county files, which excludes county-plan combinations that have fewer than 11 enrollees, leading to somewhat lower Medicare Advantage enrollment counts than reported elsewhere. Cost plans, PACE plans, and HCPPs are excluded.

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

Appendix

Medicare Advantage Enrollment, By Plan Type, 2010-2026

Health Insurer Financial Performance in 2024

Published: Feb 23, 2026

Introduction

The largest private health insurance companies often offer plans in multiple markets, including the Medicare Advantage, Medicaid managed care, individual (non-group), and fully-insured group (small and large employer) health insurance markets. Each market has unique features, including eligibility, payment, and coverage rules, which affect insurers’ overhead and potential profit. In recent years, private insurers are playing a growing role in public insurance programs, with more than half of eligible Medicare beneficiaries enrolled in a private Medicare Advantage plan and more than three-quarters of Medicaid enrollees obtaining coverage through a managed care plan (typically a private insurer).

This brief examines two measures of financial performance – gross margins and medical loss ratios – in the Medicare Advantage, Medicaid managed care, individual, and fully insured group health insurance markets using data reported by insurance companies to the National Association of Insurance Commissioners (NAIC) and compiled by Mark Farrah Associates, through the end of 2024 (the most recent year of annual data). The Medicare Advantage market is made up of around 33M people in 2024. In comparison, this is less than half of the population for Medicaid managed care and about 70% of the size of the fully insured group market. However, the Medicare Advantage market is about 1.4 times larger than the individual market.

In 2024, per enrollee gross margins in dollars were highest in the Medicare Advantage market, and medical loss ratios (measured as percentages) were lowest in the individual insurance market. In 2024, the Medicaid managed care market had both the lowest gross margins per enrollee and highest medical loss ratio. While both gross margins and medical loss ratios are indicators of financial performance, higher margins and lower loss ratios (as they are calculated in this analysis) do not necessarily translate into greater profitability since they do not account for administrative expenses or tax liabilities. Additionally, the increasingly complex structure of insurance companies, including the rise in consolidation and vertical integration, and role of subsidiaries, make it difficult to isolate the revenues and expenses associated with a particular insurance market. (A detailed description of each market is included in the Appendix).

Measures of Financial Performance in 2024

Gross margins

The gross margin per enrollee is the amount by which total premium income exceeds total claims costs per person over a specified time period (i.e., per year).

At the end of 2024, gross margins per enrollee ranged from $608 in the Medicaid managed care market to $1,655 in the Medicare Advantage market. Gross margins per enrollee in the group market was $846, roughly half the level observed among Medicare Advantage plans on average. Per enrollee gross margins in the individual market in 2024 amounted to $987. The level of margins reflects, in part, the overall health needs and spending in a market segment. A similar margin in percentage terms will translate to a higher margin in dollars per enrollee when average health expenses are higher.

Gross Margins are Highest in Medicare Advantage in 2024

Medical loss ratios

Another way to assess insurer financial performance is to look at medical loss ratios (MLRs), or the percent of premium income that insurers pay out in the form of medical claims. Generally, lower MLRs mean that insurers have a higher share of income remaining after paying medical costs to use for administrative costs or keep as profits. Each health insurance market has different administrative needs and costs, so a lower MLR in one market does not necessarily mean that market is more profitable than another market.

MLRs are used in state and federal insurance regulation in a variety of ways. In the commercial insurance (individual and group) markets, insurers must issue rebates to individuals and businesses if their MLRs fail to reach minimum standards set by the ACA. Medicare Advantage insurers are required to report MLRs at the contract level (which typically combines multiple plans) and are required to issue rebates to the federal government if their MLRs fall short of the required level of 85% and are subject to additional penalties if they fail to meet MLR requirements for multiple consecutive years. For Medicaid managed care organizations (MCOs), CMS requires states to develop capitation rates for Medicaid to achieve an MLR of at least 85%. There is no federal requirement for Medicaid plans to pay remittances if they fail to meet their MLR threshold, but a majority of states that contract with MCOs require remittances in at least some cases. The MLRs shown in this issue brief are simple loss ratios (claims as a share of premium income) and may differ from loss ratios calculated using the definition of MLR in the ACA and in Medicaid managed care.

In 2024, MLRs were similar between the Medicare Advantage, Medicaid managed care, and group markets. However, individual market loss ratios were lower. Simple loss ratios were around 85% in individual market, 88% in the fully insured (group) market, 90% in the Medicare Advantage market, and 91% in the Medicaid managed care market.

Individual Market Loss Ratios Were the Lowest in 2024

Trends in Gross Margins

While gross margins are not equivalent to profitability, changes in gross margins can be indicative of changes in profitability (assuming administrative costs and tax liability are stable). Gross margins have declined from increases that occurred in 2020 during the initial phase of the COVID-19 pandemic. In 2024, all markets saw decreases in gross margins compared to 2023.

Medicaid Managed Care: Per enrollee gross margins in the Medicaid managed care market increased during the pandemic as policies prohibited states from disenrolling people from Medicaid in exchange for additional federal dollars. Gross margins decreased by 19% to $608 from 2023 to 2024, which is slightly higher than in 2019, before the pandemic. Starting in April 2023, “continuous enrollment” in Medicaid ended and states began disenrolling individuals who were no longer eligible or who did not complete the renewal process, and Medicaid/CHIP enrollment declined by more than 16% (about 15 million people) from March 2023 to December 2024. As millions were disenrolled, states and plans faced considerable rate setting uncertainty. A shift in member risk, characterized by an increase in acuity (or health risk) of the remaining population, and increasing utilization patterns began to emerge by late 2023, which may have contributed to the decrease in per enrollee gross margins seen from 2023 to 2024. States may use a variety of risk mitigation strategies, including “risk corridors” (where states and plans agree to share profit or losses), to provide financial protection and limits on financial risk for states and plans that may not be accounted for in the data used in this gross margin analysis. States may also make capitation rate adjustments (with CMS approval) when substantial coverage changes occur mid-year or adjustments are necessary to address unforeseen circumstances that increase benefit costs.

Medicare Advantage: Through the end of 2024, gross margins in the Medicare Advantage market averaged $1,655 per enrollee, which is 17% lower than in 2023 ($1,986), consistent with reports by the largest Medicare Advantage insurers of increased utilization beginning in late 2023 that extended through 2024. Additionally, the phase-in of changes to Medicare Advantage payments, stemming from revisions to how the federal government makes adjustments for the health status of enrollees, began in 2024 and reduced the pace at which revenue per enrollee grew. Per enrollee gross margins have consistently been larger than those in the individual, fully insured, and Medicaid managed care markets since 2018.

Group Market: Gross margins per enrollee for fully insured group plans declined by 7% from $914 to $846 from 2023 to 2024. This is the first time per enrollee gross margins in the fully insured group market have declined from the year prior since 2021, when they were the lowest in the past decade (not shown).

Individual Market: Individual market gross margins were about 5% lower in 2024 compared to 2023, going from $1,042 to $987 per enrollee.  In 2018, following efforts to repeal the ACA and defunding of Cost Sharing Reduction subsidies, insurers raised individual market premiums substantially. These premium increases resulted in significantly higher margins than in earlier years. For context, gross margins per enrollee in 2024 were around 35% and 16% lower than in 2018 and 2019, respectively.

Gross Margins Remain Higher in Medicare Advantage than Medicaid Managed Care, Group, or Individual Markets Despite Recent Declines

Trends in Medical Loss Ratios

Each health insurance market has different administrative needs and costs, so similar MLRs do not imply that the markets are similar to each other in profitability. Additionally, simple MLRs examined in this brief do not incorporate the effects of changes in tax law, such as the health insurer tax, which has been permanently repealed starting in 2021, was in effect in 2018 and 2020, but was not in 2019. While MLRs alone cannot convey whether a market is profitable in a particular year, if administrative costs hold mostly constant from one year to the next, a change in the MLR could imply a change in profitability.

Medical Loss Ratios Increased Slightly Across All Markets In 2024

Individual Market: The average individual market MLR in 2024 was similar to 2023, but higher than those seen in the years following the end of cost-sharing reduction payments. As mentioned earlier, 2018 and 2019 were exceptionally lucrative years for the individual market. Many plans fell short of the ACA’s MLR requirements and were therefore required to issue large rebates to consumers based on their 2018 and 2019 experience.

Group Market: The average MLR for group plans was stable between 2022 and 2023 at 86% but rose to its 2021 value of 88% in 2024. These are all higher than in the years prior, when MLRs ranged from 83% in 2018 and 2020 to 85% in 2019.

Medicaid Managed Care: Relative to 2023, the average MLR in 2024 for the Medicaid managed care market increased from 88% to 91% (implying a potential decrease in profitability). This is the highest Medicaid managed care average medical loss ratio observed in the past decade (data not fully shown). As previously discussed, states and plans faced considerable rate setting uncertainty after millions of people were disenrolled during the unwinding of the pandemic-era Medicaid continuous enrollment provision, resulting in acuity and utilization shifts within the remaining population. These factors may have contributed to the change in MLR seen from 2023 to 2024. Looking ahead, implementation of the 2025 federal budget reconciliation law’s Medicaid coverage and financing provisions could affect Medicaid managed care plans.

Medicare Advantage: Average MLRs in the Medicare Advantage market rose to 90% in 2024. That is higher than before and during the onset of the COVID-19 pandemic, from 2018-2020, when MLRs ranged from 83% to 86%. The increase of the MLR in the Medicare Advantage market could imply decreased profitability, consistent with higher utilization and the effects of phasing in a new risk-adjustment model.  At the same time, it may be difficult to interpret changes in MLRs with increasing consolidation, driven in part by insurers purchasing related businesses, such as pharmacy benefit managers, physician groups, and post-acute care providers, because it is not entirely clear how insurers allocate expenses across different lines of business.

Medicare Advantage plans have both higher average costs and higher premiums (largely paid by the federal government), because Medicare covers an older, sicker population. So, even when Medicare Advantage insurers spend a similar share of their premiums on benefits as other insurers in other markets, the gross margins described above—which include profits and administrative costs—tend to be higher in Medicare Advantage plans.

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

Methods

We analyzed insurer-reported financial data from Health Coverage PortalTM, a market database maintained by Mark Farrah Associates, which includes information from the National Association of Insurance Commissioners (NAIC). We used the “Exhibit of Premiums, Enrollment, and Utilization” annual report (accessed January 21, 2026) for this analysis. The dataset analyzed in this report does not include California HMOs regulated by California’s Department of Managed Health Care. Additionally, for Medicaid, there are four states (California, Delaware, New York, and Oregon) that have different reporting practices and therefore may only have partial or no NAIC data available for the years displayed.

We excluded plans in each segment of interest that filed negative values or have negative or zero dollars in premiums or claims. We also excluded plans reporting at least 1,000 hospital patient days incurred per 1,000 member months. We only included plans that were categorized as having a “medical” focus in our analysis and exclude “specialty” plans which are categorized as “ancillary or supplemental benefit plans.” We also excluded any plans from the U.S. territories. We corrected for plans that did not file “member months” or filed a zero “member month” value in the annual statement but did file current year membership by imputing these values. If, after imputing, plans still did not have “member months,” they were excluded.

The group market in this analysis only includes fully insured plans (but excludes Federal Employee Health Benefits Program plans and plans regulated by the California Department of Managed Health Care). NAIC defines “Medicaid” as “business where the reporting entity charges a premium and agrees to cover the full medical costs of Medicaid subscribers.” This explicitly excludes Administrative Services Only (ASO) plans. We only use “medical” focused plans to help exclude any specialty plans; however, prepaid ambulatory health plans (PAHPs), prepaid inpatient health plans (PIHPs), or Programs of All-Inclusive Care for the Elderly (PACE) plans may be included in the analysis due to NAIC’s definition of Medicaid.

Gross margins per enrollee were calculated by subtracting the sum of total incurred claims from the sum of unadjusted health premiums earned and dividing by the total number of members.

Premiums for Medicare Advantage plans primarily consist of federal payments made to plans and any additional amounts plans may charge their enrollees. Premiums for Medicare Advantage plans do not include payments for Medicare Part D benefits. Premiums for Medicaid may not reflect contractual adjustments related to risk corridors or other risk-sharing adjustments.

To calculate medical loss ratios, we divided the market-wide sum of total incurred claims by the sum of all unadjusted health premiums earned. MLRs in this analysis are simple loss ratios and therefore, may differ from loss ratios used to calculate rebates.

Appendix

Individual Market: The individual market includes coverage purchased by individuals and families through the Affordable Care Act’s exchanges (Marketplaces) as well as coverage purchased directly off-exchange, which includes both plans complying with the ACA’s rules and non-compliant coverage (e.g., grandfathered policies purchased before the ACA went into effect and some short-term plans). The federal government provided subsidies for low and middle-income people in the Marketplace and includes measures, such as risk adjustment, to help limit the financial liability of insurers. Insurers in the individual market receive premium payments from enrollees, plus any federal subsidies for people in the Marketplaces.

Some plans submitting data on the Exhibit of Premiums Enrollment and Utilization appear to be including some Children’s Health Insurance Program (CHIP) data in their Individual market filings. In a previous version of this analysis, we used the Supplemental Health Care Exhibit to address this. However, in this analysis, we opted to use the EPEU to ensure comparability.

Group Market: The fully insured group market serves employers, their employees and dependents who are enrolled in fully insured health plans. This market includes both small and large group plans but excludes employer-sponsored insurance plans that are self-funded, which account for 63% of workers with employer-sponsored insurance in 2024. This analysis does not capture metrics for the Federal Employee Health Benefit Program or California Managed Health Care plans.  Roughly 25 million people from the fully insured group market in 2024 are accounted for in this analysis. Plans typically receive premium payments from both employers and their employees.

Medicaid Managed Care: The Medicaid managed care market includes managed care organizations (MCOs) that contract with state Medicaid programs to deliver comprehensive acute care (i.e., most physician and hospital services) to enrollees. As of July 2024, more than three-fourths (over 66 million people) of all Medicaid beneficiaries nationally received most or all of their care from comprehensive risk-based MCOs. There is significant variation across states with respect to services that are covered by MCOs.

In this analysis, the NAIC data we use defines “Medicaid” as “business where the reporting entity charges a premium and agrees to cover the full medical costs of Medicaid subscribers” and only explicitly excludes Administrative Services Only (ASO) plans from their reporting. While we only use “medically” focused plans to help exclude any specialty plans, PAHPs, PIHPs and PACE plans may not be excluded due to NAIC’s definition of Medicaid. Additionally, for Medicaid, there are four states (California, Delaware, New York, and Oregon) that have different reporting practices and therefore may only have partial or no NAIC data available for the years displayed. In other work, KFF defines comprehensive MCOs as managed care plans that provide comprehensive Medicaid acute care services and, in some cases, long-term services and supports as well. This excludes “limited benefit plans” including prepaid ambulatory health plans (PAHPs), prepaid inpatient health plans (PIHPs), and Programs of All-Inclusive Care for the Elderly (PACE) that may be included in this analysis.

Medicare Advantage: The Medicare Advantage market provides Medicare-covered benefits through private plans to around 33 million Medicare beneficiaries in 2024, which is over half of all Medicare beneficiaries in 2024. The federal government makes risk-adjusted payments (higher payments for sicker enrollees and lower payments for healthier enrollees) to plans (averaging nearly $14,823 per enrollee in 2024) to cover the cost of benefits covered under Medicare Parts A and B and supplemental benefits, such as dental, vision, hearing, and others, with additional payments for costs associated with prescription drug coverage. Some plans charge enrollees an additional premium.

What Newly Released Medicaid Data Do and Don’t Tell Us

Published: Feb 20, 2026

The Centers for Medicare and Medicaid Services (CMS) is focused on addressing “fraud, waste and abuse” in health programs including Medicaid. Efforts span across different types of health coverage and across all provider and service types. In November 2025, CMS issued a letter to states describing opportunities for federal and state governments to work collaboratively. Efforts to address fraud, waste and abuse are not new. The Center for Program Integrity (CPI), within CMS, was established in 2010 to coordinate program integrity efforts and move from a “pay and chase” model to higher reliance on data analytics to detect and prevent fraud. CPI has worked with states to provide training through the Medicaid Integrity Institute and access to broad sets of complete data to help promote program integrity efforts.

On February 14, 2026, CMS released a dataset with provider-level spending data that the agency suggests could be used to identify unusual billing patterns for specific services, states, or providers. This policy watch describes what the data include, what they exclude, and how they could potentially lead to mistaken conclusions given the limitations of the data.

What do the data include and exclude?

The new dataset includes seven types of data:

  •  The national provider identifier (NPI) for the billing provider,
  • The NPI of the servicing provider (which may be an individual or an organizational entity),
  • The procedure code (also known as the healthcare common procedure coding system or HCPCS code),
  • The month and year,
  • The number of beneficiaries seen,
  • The number of procedures delivered (the count of claims), and
  • The total amount paid for the services.

The totals include records of outpatient services paid for by Medicaid directly (“fee-for-service”) and those paid for by Medicaid managed care organizations on behalf of enrollees between 2018 and 2024.

The data exclude all institutional records and all information about prescription drugs, which are significant shares of Medicaid spending, with hospital care accounting for 37% and being the single largest source of Medicaid spending. Beyond excluding entire categories of services, the data omit several types of information that are important in evaluating the reasonableness of service volume and spending:

  • Enrollment. The amounts of services used depend on how many people are eligible to receive the services, which varies based on state policies, the economy, and people’s demographics. Differences in service use over time or between geographic locations may not be comparable without accounting for the number of Medicaid enrollees and their age and health status.
  • Benefits and Coverage. The volume of services used also depends on what services states elect to offer and how they determine who is eligible to use those services, features that may change over time.
  • Payment rates. Spending on services depends on how much states are paying for each service, which could depend on the local cost of living as well as state decisions about how much payment rates should be to ensure reasonable access to care.
  • Diagnoses. The data do not include any information to indicate what condition the procedures are used to treat.
  • Place of service and other modifiers. The data exclude information about where the services were performed (including whether they were provided in-person or remotely) and other modifiers that are used to identify characteristics of the services.

How might the data lead to mistaken conclusions?

Although data analytics can be a powerful tool to identify potentially problematic patterns, they could lead to mistaken conclusions if used in isolation. A few specific shortcomings of the new Medicaid data stand out.

  • The reported procedures are not always comparable to each other. The data provide counts of patients, services, and Medicaid spending for each procedure, but the procedures are not in all cases comparable to each other. Some are very narrowly defined whereas others encompass a wide array of procedures. In CMS’ example of how the data could be used, spending on personal care appears to be a significant outlier and the single largest source of Medicaid spending. However, the “procedure” for personal care includes a range of possible services lasting from 15 minutes up to an entire day. In contrast, there are multiple separate procedures for psychotherapy that each correspond to visit length (30 minutes, 45 minutes, 60 minutes, etc.). Similarly, there are multiple procedures for emergency department visits and office visits that correspond to the complexity of the case on a scale from one to five. Personal care would not be the largest category of spending if institutional spending were also included.
  • Providers are not always comparable to each other. The data provide counts of patients, services, and Medicaid spending for each provider, but some of the providers are individuals whereas others are group practices, clinics, or even entire county and state health departments. In CMS’ example of how the data could be used to look at spending by provider, 10 of the 20 largest “providers” are state or local government agencies that both administer and deliver Medicaid benefits rather than health care providers. States’ approaches to delivering Medicaid benefits vary broadly, but in most cases, state or local health departments contribute by paying providers to deliver services and by providing services directly (particularly in the case of services for people with behavioral health needs and developmental disabilities).
  • There is limited information about the methods used to create the dataset or the underlying data quality. The data do not indicate how underlying Medicaid data were aggregated to create the summary file. They also do not address issues related to the quality of the underlying data, which come from the Transformed Medicaid Statistical Information System or T-MSIS. T-MSIS is a rich source of data, but sometimes there are issues with the data in specific states for specific topics. CMS maintains a rigorous “data quality atlas” that supports “insightful, methodologically sound analysis” of the data. The atlas provides a wealth of information about potential data problems. It’s unclear how CMS handled those issues when generating the recently-released data. For example, CMS reports that in the 2024 data, there were six states with unusable information about total spending for the services included in the data; and an additional 16 states where the data were of high concern. It is unknown whether CMS included the unusable data in the public file or whether the public data reflect a different version of T-MSIS.

Beyond those data issues, the data are missing context about how Medicaid spending and use of care changed between 2018 and 2024. The COVID-19 pandemic, which began in 2020, resulted in major changes to Medicaid spending that resulted from increased enrollment during the continuous enrollment period and increased awareness of unmet needs for behavioral health and long-term care. As states increased access to those services, use of those services and associated spending grew due to changes in states’ policies regarding coverage, eligibility, and provider payment rates.