Federal Vaccine Injury Compensation Programs: Overview and Current Issues

Published: May 15, 2026

Introduction

For decades, the federal government has overseen two key vaccine injury compensation programs: the National Vaccine Injury Compensation Program (VICP) and the Countermeasures Injury Compensation Program (CICP). The VICP and CICP are designed to help maintain vaccine access while also recognizing that vaccine injuries can occur and those affected by such injuries should be compensated. However, over time, the demands on, and challenges faced by, these programs have grown. Recently, they have become targets of criticism from members of the Trump administration, including the Secretary of Health and Human Services (HHS) Robert F. Kennedy Jr. ,who said (without evidence) in 2025 that VICP had “devolved into a morass of inefficiency, favoritism, and outright corruption” and that he would lead an effort to overhaul it. Some lawmakers and external groups have called to replace or end these programs while others have suggested keeping them intact but adopting policy changes that could help modernize them and make them more effective. Some have raised concerns that making drastic changes to vaccine injury compensation programs could undermine the U.S. vaccine market and, more generally, confidence in vaccines.

To provide background and context on this topic, this brief summarizes the history and rationale for these programs and their key elements, analyzes publicly available information on claims and compensation under the programs, and discusses key policy issues they currently face. The programs, while both having been created as alternatives to civil courts, vary significantly in their structures, processed, vaccines covered, and compensation rates and amounts, among other factors.

Origins and Rationales for VICP and CICP

VICP and CICP were both created as alternative pathways to civil courts to allow individuals to seek compensation for vaccine-related injuries and address vaccine safety while also addressing concerns about vaccine supply in the U.S. Prior to the existence of these programs, there were times when vaccine manufacturers faced a large volume of lawsuits linked to rising public concerns about vaccine safety, which threatened to drive vaccine makers from the market and led them to raise their prices, affecting access to vaccines.

  • VICP, created by Congress in 1986, was designed as a legal pathway separate from traditional civil courts through which individuals can seek compensation for potential vaccine injuries directly from the federal government. VICP was created by Congress following a wave of public concern regarding vaccine safety in the late 1970s and 1980s that was fueled, in part, by sensationalized television programs on the topic of vaccine injuries in children. There had been a surge in lawsuits in the civil court system filed against health care practitioners and vaccine makers. Facing rising legal costs, some vaccine manufacturers chose to exit the vaccine market and those that remained raised their prices, which threatened the market for childhood vaccines in the U.S. In response, Congress passed the 1986 National Childhood Vaccine Injury Act (NCVIA) that, among other things, established the VICP. It was intended to help stabilize the vaccine market, preserve public confidence in immunization, while also providing a less adversarial and more streamlined pathway for families to submit claims and receive compensation payments for vaccine injuries compared to civil litigation. The act created the process by which vaccines could be added to VICP coverage and created the VICP trust fund, which funded the program using excise taxes placed by Congress on each of the vaccines covered under VICP. Congress has made several statutory changes and additions to VICP since 1988, including the 1993 Omnibus Budget Reconciliation Act that allowed for rapid inclusion of new U.S. Centers for Disease Control and Prevention or CDC-recommended vaccines into VICP once Congress enacted the excise tax on that vaccine, and the 21st Century Cures Act from 2016 that added vaccines recommended for pregnant women to VICP and explicitly included injuries to children in utero as eligible for VICP compensation.
  • CICP was created by Congress in 2005 to allow individuals to seek compensation for injuries that may have occurred from use of medical countermeasures (such as vaccines) during a public health emergency (as distinct from routine use addressed under VICP). It was established as part of the Public Readiness and Emergency Preparedness (PREP) Act, at a time of heightened national security concerns following the September 11, 2001 attacks, anthrax mailings, and the threat of an influenza pandemic. The PREP Act was meant to address concerns that in a public health emergency, such as a bioterrorist attack or a naturally occurring outbreak, private companies might be reluctant to develop and manufacture vaccines, drugs, and other medical countermeasures because of liability risks they could face from use of those products during an emergency. As part of a broader strategy incentivizing rapid development and deployment of countermeasures, the PREP Act offered immunity from liability to manufacturers and distributors of these products, and created the CICP as the federal compensation mechanism for injuries that may occur through use of these products.

Vaccines and Injuries Covered, and Processes for Review and Compensation

While both VICP and CICP are designed to be more efficient and streamlined mechanisms compared to civil courts for vaccine injury compensation cases, they are distinct in terms of which vaccines are covered and how claims are submitted, reviewed, and adjudicated (see Table 1 for a comparison of key characteristics of these programs).

VICP

  • There are currently 16 vaccine types covered under the VICP program. By statute, VICP covers FDA approved vaccines used in the U.S. that are 1) recommended by the CDC for “routine administration” to children or pregnant women, 2) subject by Congress to the VICP excise tax, and, 3) added to the official VICP vaccine injury table by the Secretary of HHS. When first passed in 1986, VICP covered 6 vaccines, a number that has grown to 16 existing vaccines, including the components of common childhood vaccines such as DPT, MMR, and polio as well as child and adult vaccines such as seasonal influenza. The VICP also covers “any new vaccine” recommended by CDC, subject to an excise tax and issued a notice of coverage by the Secretary of HHS.
  • The vaccine injury table is a key VICP document listing vaccine types and injuries compensable by VICP. The table lists and explains injuries presumed to be caused by vaccines and the time periods in which the first symptom of these injuries must occur after receiving the vaccine. The current table lists 14 compensable injuries across the 16 vaccine types, with most injuries associated with one or a few vaccine types only. For example, “chronic arthritis” is listed as a potential injury associated only with rubella-containing vaccines, and “vaccine-strain polio infection” is only associated with oral polio vaccine. Others are associated with multiple vaccine types, such as “shoulder injury” and “vasovagal syncope” (i.e. a drop in blood pressure and heart rate), which are each listed for 15 vaccine types.
  • VICP claims are submitted to HHS and the U.S. Court of Federal Claims and reviewed through a judicial process overseen by the Office of Special Masters. An individual (or legal representative) must first file a petition with the U.S. Court of Federal Claims “Office of Special Masters” which handles VICP cases. “Special Masters” are specialized officers of the court who function similarly to a judge. Upon receipt, each claim is assigned to one of eight Special Masters and initially reviewed by specialized HHS staff for compliance with VICP submission requirements. Documentation to support an injury claim must be provided, and typically only injuries listed on the vaccine injury table are eligible for compensation. For injuries not on the table, a petitioner must prove, through medical documentation and/or expert opinion, that the vaccine in fact caused the alleged injury. VICP typically pays petitioners’ legal fees, even if the claim is eventually unsuccessful.
  • Special Masters issue a ruling on compensation based on a “preponderance of evidence” standard. VICP is designed as a no-fault system, meaning petitioners do not need to prove negligence on the part of vaccine makers or health care practitioners. With sufficient documentation of an injury matching a condition and fitting the timetable listed on the vaccine injury table, it is usually presumed that the vaccine caused the injury. In some cases, additional information is needed such as expert testimony or medical research findings to support injury claims, and evaluating evidence may require hearings with witnesses.
  • Petitioners can accept or reject a compensation decision, with the option for appeal. If a ruling is made in favor of a petitioner, the Special Master determines the level of compensation, which a petitioner can accept or reject. If the claim is denied, the petitioner can seek review by a judge of the Court of Federal Claims and potentially appeal further to the U.S. Court of Appeals. If the claimant moves through all appeals and is still denied compensation, then they may have the right to subsequently file a suit in civil court (with some limitations). 
  • The Secretary of HHS can modify the VICP vaccine injury table, though changes must abide by a statutory process including external expert review and a public comment period. The Secretary of HHS has the explicit authority to modify the vaccine table, though any changes are subject to a process outlined in statute (42 U.S.C. § 300aa-14) and federal regulations (Code of Federal Regulations (CFR) Part 100), including referred to an external expert advisory body known as the Advisory Commission on Childhood Vaccines (ACCV), which has at least 90 days to review suggested changes. In addition, HHS must follow Administrative Procedures Act (APA) guidelines, including publishing a Notice of Proposed Rulemaking (NPRM) in the Federal Register and a 180-day public comment period. Adding a new vaccine to the vaccine injury table requires that new vaccine to be recommended for routine use by CDC, and for Congress to apply an excise tax on that vaccine, before HHS can publish a notice of coverage and submit related changes to the vaccine injury table.
  • The VICP vaccine injury table has rarely been updated; its last major revision was in 2017. At that time, “Shoulder Injury Related to Vaccine Administration, or SIRVA was added. HHS proposed adding this to the Table, submitted it to ACCV for input, and in 2015 published the related NPRM. In 2017 HHS issued the final ruling after reviewing and responding to public comments, as required under APA.

CICP

  • CICP covers countermeasures used in federally declared public health emergencies, which has included COVID-19 vaccines, as well as vaccines for pandemic influenza, smallpox, and mpox. By statute, covered countermeasures are those that the Secretary of HHS specifically lists in the declarations issued under the PREP Act for each health emergency. Currently, there are 10 such declarations in effect covering countermeasures against health emergencies, including Anthrax, Ebola, Marburg, pandemic influenza, mpox, and COVID-19.
  • CICP claims are reviewed through an administrative process by HHS staff, rather than a judicial process. Individuals submit a request to the Health Resources and Services Administration (HRSA) within HHS, which administers CICP. Filings must include sufficient medical records and other documentation linking the countermeasure and the individual’s claimed injury. In contrast to VICP, there no judges or hearings under CICP. Instead, claims are reviewed internally by HHS medical and legal staff. CICP does not pay petitioners’ legal fees.
  • CICP does not have a single “injury table” reference for covered countermeasures, with claims typically requiring individualized, case-by case review. Some declared health emergencies – including smallpox and pandemic influenza – have a specified countermeasure injury table, but most do not (COVID-19 countermeasures, for example, do not have an injury table). Therefore, most claims require individualized scientific review and case-by-case considerations. To receive compensation, a petitioner must show “serious physical injury was sustained as the result of the use of a covered countermeasure,” which is a higher evidentiary standard compared to VICP.
  • CICP decisions leave little room for appeal. HRSA issues a written determination on whether the injury is eligible for compensation under CICP and, if found eligible, how much compensation is awarded. If found ineligible, a petitioner can request reconsideration, but further review is still handled internally, with no process for formal legal appeal. In most cases, individuals who have pursued compensation through CICP cannot go on to pursue lawsuits in civil court against manufacturers or providers for covered countermeasures.
  • The HHS Secretary has broad authority to make changes to countermeasures and injuries covered under CICP. The PREP Act provides the HHS Secretary more discretion and imposes fewer regulatory requirements on the process to make changes to injuries covered by CICP, compared to VICP. The Secretary can determine which countermeasures are covered and which injuries are presumed to be compensable under the CICP, and there is no statutory requirements for advisory committees or public comment periods for changes to these policies.
Key Characteristics of Federal Vaccine Injury Compensation Program (VICP and CICP) (Table)

Historical Data on Petitions and Compensation Decisions

The number of petitions submitted to VICP and CICP has varied over time, and both programs have seen large increases in petitions in certain years driven by different factors, such as a surge in CICP claims related to COVID-9 vaccines starting in 2021 (COVID-19 claims comprise most CICP petitions at this point). Overall, VICP provides compensation for a much greater share of its petitions compared to CICP (48% compared to less than 1% for COVID-19 vaccine petitions), largely reflecting the differences between the programs. Still, given the large number of vaccines administered in the U.S., very few petitions or claims in either program are found to be compensable relative to vaccines received (1.89 VICP compensable petitions per million vaccine doses and 0.14 compensable CICP claims per million COVID-19 vaccine doses).

VICP

  • From FY 1988 through FY 2025, VICP received a total of 28,673 petitions. The annual number of petitions has varied over time, including notable surges in some years (see Figure 1). Surges occurred in FY 1990 and FY 1991 (1,492 and 2,718 VICP petitions were filed, respectively) due to a large increase in claims stemming from parental concerns about injuries caused by DPT vaccines. There was also a surge a decade later, primarily reflecting a wave of public concern about MMR vaccine after reports (later found to be false) that the vaccine could be linked to autism.1 Since FY 2014, there has been a general increase in the number of petitions filed, with the average number growing from 466/year during the FY 2005-FY 2014 period to 1,238/year during FY 2015-FY 2025. This increase may be linked to policy changes that expanded the scope of the vaccine injury table, such as the inclusion of “Shoulder Injury Related to Vaccine Injury (SIRVA),” which was formally added in 2017
Number of VICP Petitions Received FY 1998 - FY 2025 (Column Chart)
  • 25,026 VICP petitions (87% of all 28,673 petitions received) have been adjudicated through FY2025, with 12,019 (48%) found to be compensable and 13,007 (52%) dismissed. As shown in Figure 2, the share of compensable injuries has generally increased in recent years compared to earlier periods of the program, with 77% of petitions found compensable between FY 2016-FY 2025 compared to 28% of petitions in the prior 10-year period (FY2006-FY2015). This again may be partially attributed to increasing scope of the vaccine injury table. The notable spike in claims dismissed in FY 2011-FY 2012 was a result of the resolution of the Omnibus Autism Proceedings allowing a backlog of claims related to autism as a vaccine injury to be processed and dismissed when the program found no credible evidence that vaccines were the cause of autism.2
VICP Claims Compensated and Dismissed FY1989-FY2025 (Stacked column chart)
  • The number of VICP claims and compensation adjudications represents a tiny fraction of the number of vaccines distributed in the U.S. According to HRSA and CDC data, from January 1, 2006 to December 31, 2024 there were 5.65 billion doses of VICP-covered vaccines distributed in the U.S.. During this same period, there were 14,409 VICP petitions filed, or 2.6 VICP petitions per million doses distributed. Of these, 10,633, or 1.89 petitions per million doses, were found to be compensable.

CICP

  • Between FY 2010 and FY 2026 (through March 1, 2026) CICP received a total of 14,733 claims for covered countermeasures. CICP reports it has reached a decision on 7,423 (50%) of those claims, finding 135 (1.8%) were eligible for compensation. The remainder are still being processed.
  • The majority of CICP petitions received were related to COVID-19 vaccines (10,981 or 75% of all petitions filed). CICP has reached a decision on 6,827 (62%) of these. Overall, 95 (0.9%) of COVID-19 vaccine claims been found eligible for compensation through CICP. With over 670 million doses COVID-19 vaccines administered in the U.S. between December 2020 and May 2023, that translates into approximately 16 petitions filed per million doses administered, and 0.14 compensation-eligible claims per million doses.
  • Relatively few non-COVID-19 vaccine countermeasure claims have been filed through CICP. For example, CICP reports 29 compensation payments were made related to the 2009 H1N1 vaccine (after approximately 90 million doses were administered in the U.S., translating to about 0.3 compensation payments per million doses administered). One CICP compensation payment was reported related to the smallpox vaccine, though CICP reports that 8 petitions related to the mpox vaccine and 2 additional claims related to the smallpox vaccine have been filed and are still being processed.
  • Publicly available information about CICP claims and compensation is limited compared to VICP. In contrast to VICP, CICP does not report petitions received or claims processed by year and does not publicly release details on the rationale for compensation decisions.

Funding and Expenditures

These two programs have different funding sources, with VICP funded through a trust fund holding revenues collected from the excise taxes and CICP funded through the annually-appropriated funds provided to HHS/HRSA. Compensation award amounts through VICP, while variable, have averaged between $500,000 and $1 million for most of the program with some recent declines.. In contrast, most awards (75%) through CICP are for amounts under $10,000, though there have been a few very large individual payments exceeding $1 million.

VICP

  • VICP is funded through revenues collected from an excise tax placed by Congress on every dose of each vaccine covered under VICP produced in the U.S.. The excise tax is paid into a Vaccine Injury Compensation Trust Fund overseen by the U.S. Treasury. The Trust Fund also generates revenue from investing its assets. Treasury uses Trust Fund resources to make payments and transfers to government agencies responsible for administering VICP including the Department of Justice, the U.S. Court of Appeals, and HHS/HRSA.
  • Over time, the VICP trust fund has grown as its annual revenues typically exceed expenses. The U.S. Treasury reports that as of September 30, 2025 the VICP trust fund held $4.66 billion. In FY 2025, $363 million was added to the trust fund (including $131 million from excise taxes, $169 million from interest on investments, and $63 million in refunds from current and prior year authority). VICP expenses totaled $314 million in FY 2025, which were primarily for compensation payments but also administrative and other costs. 
  • 12,409 VICP compensation payments have been awarded between FY1989 and FY2025 totaling $4.89 billion (see Figure 3). Since the early 2010s, the average amount of compensation has generally declined, and has remained below $500,000 since FY 2015, likely a reflection of the expansion of the vaccine injury table to include milder injuries such as SIRVA (which entail comparatively lower payments relaive to other injuries).
Average VICP Compensation Payment Amounts by Year (FY1989-FY2025) (Column Chart)

CICP

  • There is no specific tax or dedicated funding source for CICP compensation payments, as there is for VICP. CICP funding comes from annual Congressional appropriations to HRSA rather than an excise tax. Through the PREP Act Congress created a “Covered Countermeasures Process Fund (CCPF)” to be administered by HRSA for CICP purposes, though little information is available on how much funding – if any – is currently held in the CCPF. At times Congress has provided emergency appropriations (such as the CARES Act during the COVID-19 response) that allowed, but did not require, HHS to direct funds to the CCPF.
  • Several large single payments comprise the majority of all compensation provided by CICP since 2010. There is only limited information about CICP expenditures, which includes the number and amounts of CICP compensation payments that have been made since FY2010. According to this data, CICP has paid compensation for 81 claims totaling more than $13 million. Most of the this total comes from a few very large single compensation payment amounts – for example there are reported payments of $5.9 million (related to thrombotic thrombocytopenia syndrome injury linked to COVID-19 vaccination), $2.3 million, and $1.8 million (the latter two related to Guillain-Barre Syndrome injury linked to 2009 H1N1 pandemic influenza vaccines). Of the 81 claims that received compensation, 11 (14%) were for amounts over $100,000, 10 (12%) were for amounts between $10,000 and $100,000, and 60 (74%) were for amounts under $10,000.
  • There are significant caseload, backlog, and capacity constraints in both programs. As noted above, there has been a growing number of petitions filed for each these programs over the last few years. However, the staffing and resources allocated to the programs have not matched this growth. For example, the VICP is limited by statute to eight special masters, with each now facing a larger caseload. The CICP has faced a surge of claims related to COVID-19 vaccines since 2021. The growing burden of claims and limited set of resources has contributed to long case review times and delays in issuing decisions and settlements.
  • The question of how best to address COVID-19 vaccine injuries has been an ongoing issue, particularly now that the COVID-19 public health emergency has ended. Under current law, COVID-19 vaccines are still covered under the CICP through the end of 2029. However, because CICP was created to address smaller scale deployments of medical countermeasures during a health emergency, rather than national-level responses to pandemics that extend over years, it has faced limitations in taking on COVID-19 vaccine injuries. Available compensation is generally lower compared to VICP, and the standard of proof for non-table injuries is higher. Even though the deployment of COVID-19 vaccines began as an emergency countermeasure during a national health emergency, these vaccines have become integrated into routine vaccinations and are recommended by CDC for broad segments of the U.S. population. For that reason, some health policy experts, lawyers, and politicians have advocated for including COVID-19 vaccines under VICP rather than CICP.
  • Politicization of vaccines and strains on scientific credibility threaten confidence in and stability of these programs. As views about vaccines have become more politicized, vaccine injury compensation programs have become a frequent target of partisan criticism. There is a striking partisan divide on the benefits and risks of COVID-19 vaccines, for example, with Republicans seeing those vaccines as causing more harm and arguing for more injury compensation as a result, compared to Democrats. This has also played out in actions taken by the Trump administration, such as seeking to narrow recommendations for several childhood vaccines and calling into question vaccine safety. On VICP, the Secretary of HHS Kennedy has argued that the program is too restrictive and the number and scope of vaccine injuries covered should be expanded to include conditions such as autism, though there is no credible evidence that vaccination causes autism, and the VICP itself reviewed available evidence on autism and vaccines during the Omnibus Autism Proceedings in the early 2000s and found no scientific evidence to support the link. Secretary Kennedy has also said that VICP has become a “morass of inefficiency, favoritism, and outright corruption.” Advocates linked to Secretary Kennedy have argued for expanding the VICP injury table to cover as many as 300 additional conditions they claim are injuries linked to vaccines. Others have raised concerns that adding injuries without sufficient scientific evidence to do so threatens the credibility of these programs and could even lead to insolvency if the scope of covered “injuries” expands to highly prevalent conditions like autism.
  • Updating legislation and regulations on compensation payment rules and related policies is politically challenging. A frequent criticism of these programs is that compensation payments were set when the programs were first created and have not been updated over time to reflect new developments and are not indexed to inflation. VICP, for example, has the same $250,000 cap on compensation for injuries or death that was in place when the program was established in 1988. However, making changes to these rules would require that Congress amend the underlying legislation, and doing so has proven politically challenging (changes were last made in 2016 through the “21st Century Cures Act”). There have been multiple legislative proposals introduced to update and modernize the vaccine injury compensation systems legislation but none has advanced. For example, the Vaccine Injury Compensation Modernization Act (H.R. 5142), which was last introduced in 2022-2023, proposed changes such as: increasing the number and tenure of special masters, requiring a formal plan to eliminate backlog, moving COVID-19 vaccines from CICP to VICP, increasing compensation caps and indexing payments to inflation, and increasing transparency and reporting requirements. Another proposal, recognizing that CICP has been inundated with claims for COVID-19 vaccines even though the program was designed with a smaller scale in mind, would replace that program with a “pandemic injury compensation system” that would be pre-funded, scalable, and automatically activated during a public health emergency. However, these bills have not advanced.

Endnotes

  1. Due to the increased public concern about a potential vaccination-autism link and the large number of related claims filed, VICP established a special program in 2002 called the Omnibus Autism Proceeding, which evaluated several hypotheses for vaccine-autism links, ultimately finding that there was no causal relationship. No scientific evidence has shown autism to be linked to childhood vaccines, therefore autism is not included as an injury in the VICP vaccine injury table. ↩︎
  2. Due to the increased public concern about a potential vaccination-autism link and the large number of related claims filed, VICP established a special program in 2002 called the Omnibus Autism Proceeding, which evaluated several hypotheses for vaccine-autism links, ultimately finding that there was no causal relationship. No scientific evidence has shown autism to be linked to childhood vaccines, therefore autism is not included as an injury in the VICP vaccine injury table. ↩︎

Medicaid Changes in House and Senate Reconciliation Bills Would Increase Costs for 1.3 Million Low-Income Medicare Beneficiaries

Authors: Maiss Mohamed, Alice Burns, and Jeannie Fuglesten Biniek
Published: May 14, 2026

Editorial Note

This analysis, originally published on June 17, 2025, was updated to note that changes to the final legislation that became law reduced the number of low-income Medicare beneficiaries who would be affected. CBO did not provide a detailed analysis of the impact, but based on available information the number is likely somewhat lower.

On May 22, the House passed a reconciliation bill, the One Big Beautiful Bill Act, which would partially pay to extend expiring tax cuts by cutting Medicaid. The Congressional Budget Office (CBO) estimates that the bill would reduce federal Medicaid spending by $793 billion over ten years and 10.3 million fewer people would be enrolled in Medicaid in 2034, including 1.3 million people with Medicare, otherwise known as “dual-eligible individuals”. The loss of Medicaid coverage for Medicare beneficiaries stems from delaying implementation of two rules that aimed to streamline the enrollment process and make it easier for people to maintain Medicaid coverage by reducing administrative barriers. Dual-eligible individuals would be disproportionately impacted by these provisions, comprising nearly 60% of the 2.3 million Medicaid enrollees who are estimated to lose coverage as a result of delaying these rules under the House reconciliation bill (Figure 1). Instead of placing a moratorium on implementation of the rules, the recently released Senate reconciliation language would prohibit nearly all of the provisions in the rules from ever being implemented.

Medicaid Changes in House Reconciliation Bill Would Increase Costs for 1.3 Million Low-Income Medicare Beneficiaries

Dual-eligible individuals have low incomes and modest savings. The 1.3 million people that would no longer have Medicaid if the eligibility and enrollment rules were not implemented would retain their primary health insurance coverage under Medicare, but lose Medicaid coverage of Medicare premiums, and in most cases, cost sharing, which are provided through Medicare Savings Programs (MSPs) administered by state Medicaid programs. Many would also lose coverage of Medicaid benefits that supplement their Medicare coverage, such as long-term care, dental services, and non-emergency medical transportation.

The loss of Medicaid coverage for Medicare beneficiaries stems from provisions in the House bill that would delay implementation of two Biden administration rules until 2035. The two rules that would be delayed under the House reconciliation bill were intended to make it easier for people to enroll in and maintain Medicaid coverage by minimizing administrative burden in the following ways.

  • One rule aimed to reduce barriers to enrollment in the Medicare Savings Programs (MSPs), under which Medicaid pays Medicare premiums, and in most cases, cost sharing for low-income Medicare beneficiaries. Among other changes, the rule would automatically enroll Medicare beneficiaries with Supplemental Security Income (SSI) into the MSPs and would more closely align the MSP application to the application for Medicare’s Part D prescription drug Low-Income Subsidy (LIS).
  • The second rule would more broadly streamline application, enrollment, and renewal processes in Medicaid. Among the changes most relevant for dual-eligible individuals are new requirements for states to assist applicants with procuring appropriate documentation to validate income and assets, a requirement to renew Medicaid coverage only once per year, and a prohibition on requiring in-person interviews as part of the application process

CBO estimates that delaying these two rules would reduce federal spending by $167 billion over 10 years, making this the second largest source of cuts to federal Medicaid spending in the bill. Illustrating why administrative burdens may make it hard for dual-eligible individuals to maintain Medicaid, prior KFF research finds that among people who newly become eligible for both Medicare and Medicaid, 28% lose Medicaid coverage within the first year despite living on fixed incomes.

Although states have already implemented some of the rules’ provisions (Table 1), if the rules are delayed, it is expected that further implementation will cease and states may resume some practices that were prohibited under the rules. For example, 38 states report sending pre-populated renewal forms to Medicaid enrollees who qualify because they are ages 65 and older or have a disability, a practice they may discontinue if the rules are delayed. Alternatively, it’s possible that some states will reinstate requirements for applicants to submit paper documentation or report for in-person interviews. In a few cases, states will be required to reinstate application requirements or be prohibited from using more streamlined application processes.

Losing Medicaid coverage would substantially increase out-of-pocket costs for low-income Medicare beneficiaries. Because Medicare beneficiaries who qualify for Medicaid typically have very low incomes and little to no savings, the loss of Medicaid payment for the costs of Medicare’s premiums and cost sharing could make their Medicare coverage unaffordable. For example, the first rule would automatically enroll low-income Medicare beneficiaries who receive Supplemental Security Income (SSI) into a MSP. Without the MSP, such people must pay 20% of the $967 SSI monthly benefits for the $185 Medicare Part B monthly premium in 2025. (In order to qualify for SSI, individuals must have low incomes, limited assets, and either be over age 64 or have a qualifying disability.) This same individual would have additional out-of-pocket costs if they went to the doctor or were admitted to the hospital. Those additional out-of-pocket costs could discourage low-income beneficiaries from using health care and is the reason for CBO’s estimate that delaying implementation of the rules would reduce Medicare spending by $11 billion over 10 years.

Additionally, some of the 1.3 million Medicare beneficiaries expected to lose Medicaid under the House reconciliation bill may also lose subsidies that help pay for prescription drug premiums and cost sharing. Medicare beneficiaries with Medicaid are automatically enrolled in the Medicare Part D Low-Income Subsidy (LIS), which provides assistance with Part D prescription drug premiums and cost sharing. Illustrating the connection between Medicaid enrollment and LIS coverage, between December 2024 and January 2025, the number of LIS recipients decreased by 1 million, following Medicaid disenrollments that stemmed from the unwinding of the Medicaid continuous enrollment provision. Before the decline, LIS enrollment had been slowly but steadily growing over time.

Eligibility and Enrollment Final Rule Provisions

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

Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Updated on:

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

State Plan Amendments (SPAs)

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

1115 Waivers

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

Early Implementation and Waiver Status

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

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

Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Updated on:

KFF Resources on Medicaid Work Requirements

Work requirements overview:

50-state survey of Medicaid eligibility and enrollment policies:

Implementation of work requirements:

Research and analysis on Medicaid and work:

1115 work requirement waivers:

Work requirements implications and state experience:

Arkansas work requirement experience:

KFF Polling on Work Requirements:

Beyond the Data by KFF CEO Drew Altman:

Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Updated on:

CMS Guidance and Information

Operational and Implementation Questions

Table

A Look at New or Expanded Medicaid and Public Health Partnerships from 2025: Findings from A Survey of State Medicaid Programs

Authors: Alisha Rao, Anna Mudumala, Elizabeth Hinton, and Cory Caldwell
Published: May 14, 2026

Introduction

Medicaid is the primary program providing comprehensive coverage of health care to about 80 million low-income people in the U.S. Medicaid is an insurance program, not a population health system. It can only fund services for eligible individuals. The public health system in the U.S. is decentralized, with most authorities and programs delegated to the state and local levels. State and local public health agencies are responsible for protecting community health through surveillance, disease prevention, and policy development and enforcement. Local health departments frequently focus on service delivery (immunizations, screenings, maternal health, environmental health) and community outreach to address local health needs. Public health serves entire communities, not just insured individuals.

Medicaid agencies and state/local public health agencies work to advance the health of their communities, often with similar priorities serving common populations. However, there is often a lack of strong and sustained partnerships between Medicaid and public health agencies. Strengthening collaboration between Medicaid and public health could improve safety net services, help coordinate and leverage resources and financing, improve intervention targeting and outreach, and reduce system fragmentation.

To improve understanding of Medicaid and Public Health agency partnerships, the 25th annual Medicaid budget survey, conducted by KFF and Health Management Associates (HMA) in collaboration with the National Association of Medicaid Directors (NAMD), asked state Medicaid directors about new or enhanced initiatives involving public health implemented in FY 2025 or planned for FY 2026 across the following domains. (The survey did not capture the full scope of established Medicaid and Public Health agency partnerships across states, including initiatives implemented or expanded before FY 2025 – FY 2026, nor all activity within these domains as states select which efforts to report.)

More than three quarters of responding states1 reported at least one new or expanded initiative implemented in FY 2025 or planned for FY 2026 (see Appendix), with maternal and child health and behavioral health emerging as areas of focus for newly implemented or expanded Medicaid and Public Health initiatives. Initiatives frequently fell into common areas, including data sharing, rural-focused initiatives, initiatives to improve access, and workforce initiatives.

Findings

States were asked to report only new or expanded Medicaid and Public Health initiatives implemented in FY 2025 or planned for FY 2026 under specific domains. Therefore, initiatives summarized and reported here do not represent a comprehensive look at all initiatives currently in place across states. State counts are not identified in the sections below, as open-ended questions often lead to underreporting. See Appendix for additional (high-level) state-by-state detail.

To track common themes across domains, state responses have been summarized (at a high-level) under the following subheadings, as applicable: “data sharing,” “rural,” “workforce,” “access,” and “other.” State examples are included in text boxes under each domain. While the survey asked about workforce initiatives separately, “workforce” also emerged as a theme applicable to other domains. These initiatives are only summarized once (e.g., do not appear under the separate “workforce” domain if they also fell under another domain).

Maternal & Child Health

Conception through early childhood represents an important period for intervention to promote long-term health and other outcomes. More than one in four Medicaid/CHIP enrollees is a female in their reproductive years. Medicaid is the primary payer for about 41% of all births and provides coverage for 37% of all children in the U.S. Public health agencies often oversee maternal and child health surveillance, prevention, and early childhood initiatives to improve outcomes and reduce gaps in health outcomes and access.

States reported new or expanded maternal and child health initiatives in the following areas:

  • Data sharing. States reported cross-agency data sharing initiatives to strengthen maternal and child health surveillance.
  • Rural. States reported collaborative efforts to address rural maternal health needs, as individuals in rural areas face access challenges (lack of local obstetric services) and geographic barriers.
  • Workforce. Statesmentioned collaborating with public health agencies to certify and support community health workers (CHW), including doulas and other perinatal providers.
  • Access.
    • Transforming Maternal Health Model. States reported collaborating with public health agencies on implementing CMS’s Transforming Maternal Health Model (TMaH), identifying collaboration as important to developing strategies to direct resources / interventions to high-need communities. CMS’s TMaH model supports state Medicaid agencies in implementing evidence-based strategies to expand access to maternal care, integrate behavioral health and social determinants of health, and ensure care continuity in the postpartum period.2
    • Coverage expansions. States pointed to expansion of Medicaid coverage of maternal and child health services, such as doula and lactation services. Some described partnering with public health agencies to inform coverage expansions through shared data and collaborative program design.
    • MH/SUD expansions. States highlighted initiatives to integrate and/or expand mental health (MH) and/or substance use disorder (SUD) services for pregnant and parenting populations, including home visiting services for pregnant and postpartum individuals.
  • Other.
    • Interagency workgroups. States described leveraging interagency workgroups and committees to facilitate coordination and to advance maternal and child health priorities, including improving outcomes and addressing complex factors (e.g., social needs) that a single agency can’t solve alone.

Box 1: State Examples of Maternal and Infant Health Initiatives

Data Sharing:

  • The Oklahoma Medicaid Birth Certificate Linkage Project is supported by an interagency agreement between the Oklahoma Health Care Authority (the state agency that administers the Medicaid program) and the Oklahoma State Department of Health. The project links vital records (birth certificate) data to Medicaid data to provide a more complete picture of pregnancy and birth outcomes of Medicaid enrollees.

Rural:

  • As part of a two-year HRSA-funded Maternity Care Deserts Policy Academy run by the National Academy for State Health Policy (NASHP), Kentucky Medicaid is working with the state’s Department of Public Health to identify maternity care deserts in the state and to develop solutions to connect pregnant individuals to care. (Maternity care deserts are places with no hospitals or birth centers offering obstetric care and no obstetric providers.) The Kentucky Perinatal Quality Collaborative and other state organizations are also involved.

Workforce:

  • Massachusetts reported providing training and technical assistance to MassHealth (Medicaid) providers to support maternal health initiatives, including efforts to strengthen care coordination and outreach and to support implementation of state maternal health legislation (enacted in 2024) that aims to expand access to midwifery, birth centers, doulas, and postpartum home visiting services.

Access:

  • California’s Department of Health Care Services was awarded $17 million in federal funding to implement CMS’s Transforming Maternal Health Model in five counties in the Central Valley. The model will provide funding to transform three key areas: access to care, infrastructure, and workforce; quality improvement and safety; and whole person care delivery (i.e., customized care to meet an individual’s unique needs).  The Department of Health Care Services will work with managed care plans, providers, community-based organizations, and other partners to implement the model and to ensure alignment with the state’s Birthing Care Pathway initiative, a broader statewide effort to improve maternity care and outcomes.
  • To improve maternal health outcomes, Illinois added doula and lactation support services (without requiring physician referral) to its Medicaid coverage. The Department of Public Health supported the coverage expansion, highlighting differences in maternal health outcomes by race and ethnicity in the state.
  • Louisiana reported the state Department of Health launched Project M.O.M. (Maternal Overdose Mortality) in May 2025. Project M.O.M. aims to reduce pregnancy-associated opioid overdose deaths through early identification and treatment of substance use disorder during pregnancy. The project will convene hospital and community partners and aims to align managed care plans and health care providers to improve access to care and treatment coordination.
  • Montana Medicaid is partnering with state public health to implement targeted case management and evidence-based home visiting for pregnant and postpartum individuals and parents of children ages 0-5 who meet high-risk criteria, including mental health/SUD criteria.

Other:

  • Arizona reported that its Medicaid agency will continue to strengthen its relationship with the state Department of Health Services through ongoing participation in health-focused workgroups and committees, including the Maternal Mortality Review Committee, Congenital Syphilis Collaborative, Perinatal and Infant Health Committee, Home Visiting Workgroup, among other groups and committees.

Children/Youth Mental Health

Early childhood and adolescence are important developmental periods that can influence long-term health. In recent years, there have been growing concerns about children’s mental health and well-being. Medicaid provides health coverage for 37% of children in the U.S. and plays a significant role in funding school-based behavioral health services. Nearly one in five students attending public schools in the U.S. use school-based mental health services, underscoring how schools serve as an important access point for youth mental health treatment. Public health agencies may be involved in assessing the status of statewide and community early childhood mental health, developing policy and programming for youth and caregivers, encouraging participation in mental health programs, and partnering to maintain school-based behavioral health services.

States reported new or expanded children/youth mental health initiatives in the following areas:

  • Workforce. States reported working with public health agencies to connect PCPs to psychiatrist consultations, including initiatives specifically targeting rural areas.
  • Access. Statesreported collaborating with public health agencies on maintaining and increasing access to school-based services, which offer a convenient setting for delivering health services to students (overcoming transportation and other barriers), including mental health services.

Box 2: State Examples of Children/Youth Health Initiatives

Workforce:

  • Kentucky’s Medicaid agency reported working with the Kentucky Department of Public Health on “KY MARK,” an initiative that helps PCPs better manage children’s mental health issues by partnering with University systems to connect primary care providers to child psychiatrists. The program aims to help PCPs develop the skills to treat/manage mental and behavioral health needs.

Access:

  • Massachusetts’ Medicaid agency reported working with the state Department of Health on implementing school-based services and on conducting outreach. The Department of Health operates school-based health centers that provide comprehensive primary care and behavioral health services. The state’s Medicaid program covers these services for Medicaid eligible youth.
  • New Hampshire reported cross-agency work to strengthen the system of care for children with behavioral health needs, aiming to create a comprehensive, coordinated network of behavioral health services and supports for children and families.

Opioid Use Disorder (OUD)

Opioids were involved in over 79,000 deaths in 2023. The opioid epidemic’s impact remains widespread, with nearly three in ten adults (29%) reporting in a 2023 KFF poll that they or a family member experienced an opioid addiction. Medicaid is the primary source of coverage for adults with opioid use disorder (OUD), covering nearly half of all adults with OUD, over two-thirds of those receiving outpatient OUD treatment, and more than half of those receiving medication-based treatment. Public health departments have worked to reduce opioid overdoses through harm reduction strategies (e.g., naloxone distribution, fentanyl test strip distribution, syringe services) and data surveillance. The Centers for Disease Control (CDC) funds state and local health departments for drug overdose surveillance through its Overdose Data to Action (OD2A) program.

States reported new or expanded OUD initiatives in the following areas:

  • Data sharing. States reported engaging public health partners in strategic planning and data sharing initiatives (e.g., matching Medicaid records with OUD data) to understand state and local OUD impacts and prevent future OUD deaths.
  • Access. States reported initiatives focused on addressing opioid use disorder among pregnant and parenting populations. These initiatives have been captured and discussed under the “Maternal & Child Health” domain above.

Box 3: State Examples of Opioid Use Disorder Initiatives

Data Sharing:

  • Arizona reported data sharing with the public health agency’s drug overdose fatality review committee that works across state agencies to determine how system changes may help prevent overdose deaths.
  • DC reported matching and sharing Medicaid records with OUD death data to engage public health partners in strategic planning.

Lead Screening

Exposure to lead can seriously harm a child’s health, including damage to the brain and nervous system, which may lead to slow growth and development, learning and behavior problems, and hearing and speech problems. The federal government has estimated that more than half of children with elevated blood lead levels are eligible for Medicaid. Federal law requires that all children enrolled in Medicaid receive blood lead screening tests at age 12 months and 24 months. In addition, children between 36 and 72 months with no record of a previous blood lead screening test must receive one. While Medicaid cannot be used to abate or for remediation of environmental damage, states are required to provide medically necessary diagnostic and treatment services for children identified with elevated blood lead levels. Medicaid programs can leverage public health expertise in outreach, education, surveillance, and data analysis, strengthening identification of populations at risk of lead exposure and expanding the reach and effectiveness of Medicaid services.

States reported new or expanded lead screening initiatives in the following areas:

  • Data sharing. States described maintaining data-sharing agreements with public health agencies to monitor lead screening rates, close care gaps, and better coordinate interventions.
  • Other. States reported working with public health agencies to develop lead screening guidance for providers and/or managed care plans.

Box 4: State Examples of Lead Screening Initiatives

Data Sharing:

  • Maines Medicaid and public health agencies share blood lead level testing data and coordinate technical assistance and communications to PCPs to increase blood lead testing rates. The Medicaid agency incorporated blood lead testing into an alternative payment model for primary care services (called Primary Care Plus) that emphasizes primary care quality and incentivizes providers to improve testing, screenings, and immunizations, including blood lead testing for children enrolled in Medicaid.

Other:

  • Arizona reported that its Medicaid agency works closely with the state Department of Health’s elevated blood lead level program to increase screening rates, identify children with elevated blood lead levels, and provide information to managed care plans for follow-up testing and treatment.
  • DC reported its Healthy Homes Program and Childhood Lead Poisoning Prevention Program moved from its Department of Energy & Environment to the DC Department of Health, streamlining efforts in risk mitigation from lead poisoning, asthma, and pest infestation, providing comprehensive home assessments and case management in one place, ensuring a closer link between environmental housing factors and direct public health intervention.
  • Wisconsin reported that public health staff are routinely included in Medicaid agency meetings with managed care plans to help identify potential quality improvement activities, including activities related to lead screening and environmental intervention.

Infectious Disease

Infectious diseases threaten public health, causing morbidity, mortality, and economic disruption. Recent outbreaks of vaccine-preventable and emerging diseases highlight the need for coordinated prevention, surveillance, and response efforts. States are required to provide comprehensive preventive care to children through the EPSDT benefit. States are required by (federal) law to cover certain preventive services for adults eligible under the ACA’s Medicaid expansion. Medicaid plays a key role in disease prevention by facilitating access to vaccines for children, adolescents, and adults. CMS and the Centers for Disease Control and Prevention (CDC) jointly run the Vaccines for Children program, which provides vaccines to Medicaid and CHIP-enrolled youth. State and local public health agencies lead disease surveillance, outbreak response, and vaccine administration. They provide guidance, education, and outreach to high-risk populations, coordinating with Medicaid to ensure prevention efforts reach eligible individuals

States reported new or expanded infectious disease initiatives in the following areas:

  • Data sharing. States reported collaborating with state public health agencies on disease-specific efforts (e.g., sharing and analyzing HIV data to guide outbreak response and enhance access to care) as well as broader data sharing initiatives with public health agencies to improve coordination and population health monitoring. 
  • Workforce. States reported collaborative initiatives, including training and service coordination, to strengthen the local response capacity of public health teams and clinical providers.
  • Access. States highlighted cross-agency efforts aimed at maintaining vaccine access and aligning coverage policy with public health recommendations.

Box 5: State Examples of Infectious Disease Initiatives

Data Sharing:

  • DC’s Medicaid agency shared data with DC Health to support continuity of care for individuals with HIV following implementation of Medicaid eligibility policy changes effective January 1, 2026 that resulted in coverage changes for certain adults.
  • The North Carolina Division of Public Health’s Immunization Registry is collaborating with the state’s Health Information Exchange (HealthConnex) to draw patient immunization data into the registry. This integration allows providers to access a consolidated record of immunizations administered across the state, regardless of where the vaccines were given.

Workforce:

  • Maine’s Medicaid agency reported working closely with the Public Health agency on HIV outbreak response to coordinate services and training for local response teams and providers.

Workforce

Health care provider shortages can reduce access to care and lead to poor health outcomes. Provider shortages are a particular challenge in low-income and rural communities. Community health workers (CHWs), doulas, and other community-linked providers, often play a role in bridging gaps in care, connecting individuals to services, and addressing health related social needs. Medicaid provides coverage for eligible enrollees by reimbursing providers directly for services or paying managed care plans to deliver services. Public health agencies provide significant safety net clinical care, operating at the state and local level and often bridging gaps in care for underserved populations, including the uninsured.

States reported new or expanded workforce initiatives in the following areas:

  • Rural. States reported collaboration on workforce initiatives spurred by the introduction of the Rural Health Transformation Program, introduced by the 2025 reconciliation law. This program (also referred to as the “Rural Health Fund”) provides $50 billion in funding for state grants that can be used to support rural areas in a variety of ways, including to pay for health care services, expand the rural health workforce, promote care interventions, and provide technical assistance with system transformation. However, over time reductions in funding to Medicaid (due to reconciliation law) are likely to exceed funding from the Rural Health Fund.
  • Other.
    • Provider certification or initiatives to attract and retain providers. States reported working with public health agencies on initiatives to attract and retain (e.g., through loan repayment, training, and certification programs) providers and on provider certification initiatives.
    • Multi-agency committees. States reported participating in multi-agency workforce committees that include public health agency staff. 

Box 6: State Examples of Workforce Initiatives

Rural: 

  • Illinois specifically mentioned cross-agency collaboration at the Rural Health Fund application stage, while other states (including New Hampshire and Wyoming) described future and anticipated collaboration on workforce recruitment funded by the Rural Health Fund.

Other:

  • Indiana mentioned its state Health Workforce Council which brings together state agencies (including the Department of Health and Medicaid agency), legislators, health care experts, and industry leaders to coordinate health workforce-related policies, programs, and initiatives.
  • Massachusetts’ Medicaid agency reported partnering with the state Department of Public Health on the implementation and monitoring of the HRSA-funded Massachusetts Loan Repayment Program for health care professionals.
  • Nevada’s Medicaid agency reported continued collaboration with the state’s Division of Public and Behavioral Health to support the development of training and certification for enrolled Medicaid providers delivering behavioral health services.

The findings from this brief are drawn from the 25th annual budget survey of Medicaid officials conducted by KFF and Health Management Associates (HMA), in collaboration with the National Association of Medicaid Directors (NAMD). Cory Caldwell is a Senior Policy Analyst at NAMD.

Appendix

State Reported Medicaid Initiatives In Partnership with State Public Health Departments (Table)

Endnotes

  1. Florida, Kansas, and Mississippi did not respond to the 2025 survey. ↩︎
  2. Fifteen states have been selected to participate and are eligible to receive up to $17 million in funding to support implementation and technical assistance activities. ↩︎

Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements

Updated on:

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

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

  • NEW: State reported plans and policies related to implementing Medicaid work requirements and county-level unemployment rate data, as well as state and national data on Medicaid enrollment, renewal outcomes, and application processing times;
  • Federal guidance and a list of policy and operational questions that states will need to answer as they implement work requirements;
  • Updates on 1115 waivers submitted by states to implement work requirements (while waivers will no longer be needed starting January 2027, some states may pursue waivers to implement work requirements earlier than January 2027); and
  • A compilation of KFF issue briefs and other resources on Medicaid work requirements.

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

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

VOLUME 46

KFF Poll Finds That Most Adults Lack Confidence in Key Health Agencies to Act Independently


Highlights

KFF’s latest Health Tracking Poll finds that confidence in the independence of key government health agencies overseeing food and drug safety and public health is low among the public and across partisans. Most of the public also share a distrust of agriculture, food, and pharmaceutical companies to act in the public’s best interest, compared with doctors and health care providers who are much more trusted among the public.


KFF Poll Finds Low Levels of Confidence in Federal Health Agencies to Act Independently, Along with Low Trust in Food, Agriculture, and Pharmaceutical Industries to Act in the Public’s Interest

KFF’s latest April Health Tracking Poll finds that fewer than half the public express confidence in the independence of the CDC, FDA, or EPA – government agencies that hold key responsibilities over food and drug safety and public health. Overall, four in ten or fewer adults say they have “a lot” or “some” confidence in the U.S. Centers for Disease Control and Prevention (CDC) (40%), the U.S. Food and Drug Administration (FDA) (36%), or the U.S. Environmental Protection Agency (EPA) (36%) to act independently without interference from outside interests.

While Democrats are somewhat more likely than Republicans or independents to express confidence in the CDC (47% vs. 37% and 38%, respectively), four in ten or fewer across partisanship say they are confident in the FDA or EPA to act independently.

Split bar chart showing share of public who say they have a lot or some confidence in the CDC, FDA, or EPA to act independently without interference from outside interests. Results shown among total, by party identification, and by support for the Make America Healthy Again (MAHA) movement.

Coupled with concerns about the independence of government agencies, most of the public lacks trust in agriculture, food, and pharmaceutical companies to act in the public’s best interest. One in four or fewer adults say they trust food and beverage companies (25%) or pharmaceutical companies (21%) “a great deal” or “a fair amount” to act in the public’s best interest, while a somewhat larger share (40%) trust agriculture companies. These findings hold across partisanship, with fewer than half of Democrats, independents, and Republicans expressing trust in these industries to act in the public’s interest.

On the other hand, most of the public say they trust doctors and health care providers to act in the public’s best interest– a sentiment that is shared across partisanship. These findings are in line with past KFF polling showing that doctors and health care providers are consistently the public’s most trusted source of health information.

Split bar chart showing share of adults who say they have a great deal or a fair amount of trust in doctors/health care providers, agriculture, food/beverage, and pharmaceutical companies to act in the public's best interest. Results shown among total, by party identification, and by support for the Make America Healthy Again (MAHA) movement.

What We’re Watching

Differences in News Consumption Correlate with Trust in MMR Vaccine

A peer-reviewed study published in Vaccine found that among study participants, the type of media people consumed was associated with their attitudes toward the MMR vaccine, even after accounting for political identity and other demographic factors. Researchers assigned 22 media outlets to five categories, using data on media usage from Pew Research Center and AllSides Media, and selected one representative outlet from each category. Those who frequently engaged with “new” or primarily digital right-leaning media, like Breitbart, were about twice as likely to say that the risks of the MMR vaccine outweighed the benefits, compared to those who never did. Even infrequent engagement with such outlets was associated with elevated odds. At the same time, engagement with “legacy” right-leaning media, like Fox News, was not significantly associated with MMR vaccine hesitancy among participants.

What To Watch Out For: The information environment in which people consume news may shape vaccine attitudes, even within political identity. As health communicators work to increase vaccine confidence, understanding how differences in media consumption shape attitudes may help predict what populations are more likely to encounter and be influenced by misleading claims about vaccine safety.

Some Pregnant People Are Choosing to Deliver Without Medical Support, and Online Communities May Be Playing a Role

Online interest in "free births,” a movement that embraces delivering a baby without any medical professional present and was recently featured in the Season 2 finale of The Pitt, has trended upward over the last year, according to reporting from The New York Times. Research on women who choose free births points to a range of motivations, including previous negative or traumatic experiences with providers, concerns about unnecessary medical interventions and wanting a more natural birth, a desire for autonomy and control during birth, and cost and access barriers. These concerns are not without basis: research and polling have documented patterns of disrespectful and nonconsensual care in maternity settings, and women of color in particular face documented disparities in how they are treated and in maternal health outcomes. At the same time, a “free birth” can put both pregnant women and their infants at greater risk for adverse outcomes and death.

Misleading online narratives have entered this space, exploiting these real grievances to promote practices that can carry serious medical risks including infant deaths. Some online communities promoting free birth frequently invoke women’s autonomy and bodily sovereignty in ways that may resonate with some women given documented patterns of disrespectful maternal care. Some also promote narratives of women being empowered or “badass” by so-called free birth. But these communities and individuals promoting free birth also spread misguided approaches to manage birth emergencies that can cause women to delay seeking care and encourage unsafe practices. Even in low-risk pregnancies, up to 29% of births involve unexpected complications that can quickly escalate. According to the CDC, nearly one in 10 births in 2023 resulted in an admission to a neonatal intensive care unit. Without trained professionals present during childbirth, life-threatening emergencies like hemorrhage or shoulder dystocia cannot be quickly identified or treated.

An investigation by The Guardian, though, has documented cases in which organizations promoting free birth have characterized life-threatening emergencies as normal and actively discouraged members from seeking emergency care. Proponents sell access to “classes” and private online forums, some of which shame or prohibit participants who mention medical care. According to The Guardian’s reporting, one of the more prominent groups promoting free birth has earned more than $13 million in revenue since 2018 and charged $6,000 for a three-month Zoom course for so-called “authentic midwives.”


AI & Emerging Technology

World Health Organization Launches AI Tool Designed to Ground Responses in Evidence

The World Health Organization (WHO) has launched a beta version of a new health AI chatbot designed to help health workers, policymakers, and researchers find sexual and reproductive health information that is grounded in WHO and Human Reproduction Programme (HRP) evidence. The tool, called ChatHRP, uses retrieval-augmented generation (RAG), a technique that grounds AI responses in a curated external database rather than in broad training data, reducing the risk of inaccurate outputs and allowing users to trace answers back to specific vetted sources.

Misinformation in Sexual and Reproductive Health

A December 2025 review published in JMIR Infodemiology found that false sexual and reproductive health and rights information in digital spaces undermined informed decision-making and health-seeking behavior across multiple levels, from individuals to health systems. The review found that at the individual level, misinformation shaped beliefs and deterred seeking care; at the community level, it reinforced harmful norms and stigma; and at the policy level, it has been used as a tool to erode legal protections for reproductive rights. WHO has positioned its new AI tool as a response to this problem, saying it would steer users “away from algorithms, opinions, or misinformation.”

Why It Matters

While ChatHRP targets health workers and policymakers rather than the general public, its use of RAG to ground responses in vetted, traceable sources may offer a model for improving the reliability of the general-purpose AI tools that many consumers are already turning to for health information. About a third of U.S. adults now turn to AI for health information, according to KFF’s March 2026 Tracking Poll on Health Information and Trust, and while most users express trust in AI chatbots to provide reliable health information, only a third of adults overall say they have a “great deal” or “fair amount” of trust in these tools for health information. As more health institutions turn to AI to deliver information, how they design for accuracy and reliability will shape both the quality of information people receive and how willing people are to trust these tools.

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


View all KFF Monitors

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

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

Medicaid Mental Health and Substance Use: Expansion Trends and the Fiscal Pressure Ahead

Published: May 13, 2026

Medicaid is a major source of financing for mental health and substance use disorder care. It covers nearly one-third of all adults with mental illness and nearly one-quarter of adults with substance use disorders (SUD), including many people with more intensive behavioral health needs. This includes adults with serious mental illness (SMI) and nearly half of all adults with opioid use disorder (OUD). Because Medicaid covers a large share of people with behavioral health conditions and finances a substantial share of treatment services and medications, it plays a central role in access to behavioral health care.   

In recent years, many states have used Medicaid to expand the behavioral health treatment continuum and improve access to care. While increasing spending, these changes have helped address longstanding gaps in access to community-based treatment as well as higher levels of care. Benefit expansions have also helped to support state efforts to respond to the opioid epidemic and to build out the behavioral health crisis continuum of care. However, recent federal policy changes, including financing and coverage changes in the 2025 reconciliation law and a more tenuous fiscal climate for states may make those gains harder to sustain. The reconciliation law requires states to implement work requirements (at application and renewal) for Medicaid expansion adults, which is the primary coverage pathway for people with mental health or substance use disorders. These requirements are expected to result in coverage losses, which may interrupt treatment and medication access.  

Against this backdrop, this brief examines recent state trends in Medicaid behavioral health coverage and payment and state coverage of select treatment models for people with serious mental illness—a population that has historically faced significant barriers to care. The brief draws on the annual Medicaid budget surveys, conducted by KFF and Health Management Associates (HMA). The 2025 survey included additional detail about coverage of Certified Community Behavioral Health Clinics (CCBHCs) (as a provider type), Assertive Community Treatment (ACT), and Coordinated Specialty Care for First Episode Psychosis (CSC-FEP).

Behavioral health services are not a specifically defined category of Medicaid benefits. Some fall under mandatory Medicaid benefit categories, such as physician services, while others fall under optional benefit categories, such as rehabilitative services. The ability to cover optional benefits and place limits on items and services results in variation across states. State Medicaid benefit design is also shaped by broader fiscal conditions and federal policy changes.

State efforts to expand Medicaid behavioral health benefits reflect both state priorities and federal opportunities. Since the pandemic and intensifying opioid crisis, behavioral health has become a top priority for many state Medicaid programs. States have focused on expanding access (including in schools), integrating care, and addressing social determinants of health. Federal opportunities, including the SUPPORT Act and American Rescue Plan Act (ARPA), have driven expansions in SUD treatment and crisis services. States have also taken steps to promote more coordinated and integrated care, including adding coverage for services provided under the Collaborative Care Model (CoCM) and enrolling provider types such as CCBHCs that offer a broad continuum of behavioral health services in one setting. Some of these initiatives are part of broader behavioral health state transformation efforts.

Behavioral health has been the most frequently cited category of Medicaid benefit expansion in KFF’s annual budget survey over the past decade.  Annually, KFF’s Medicaid budget survey asks state Medicaid officials about recently implemented or planned benefit changes (i.e., benefit enhancements or additions and restrictions or eliminations). In every survey over the past 10 years, behavioral health services were the most frequently reported area of benefit expansions. States reported expansions across the full care continuum of behavioral health services, including institutional, residential, outpatient, home and community-based, peer supports, and crisis services. These trends show how states have used Medicaid to help address longstanding gaps in care and respond to emerging mental health and substance use needs; however future trends are less clear. For example, California’s FY 2026-27 proposed budget would make mobile crisis services optional for counties, rather than statewide and counties that continue to offer the service would have to finance the full non-federal share of costs.

States have also raised fee-for-service (FFS) provider payment rates to help strengthen access to behavioral health services. Even when states add benefits, access may still be limited by provider shortages and narrow networks. Increasing provider rates is one way states have tried to address Medicaid workforce shortages, though rate increases also often face fiscal headwinds. KFF’s Medicaid budget survey asks state Medicaid officials to report annual FFS rate changes for certain provider types. Beginning in FY 2024, KFF’s Medicaid budget survey asked states to report FFS rate changes specifically for outpatient behavioral health clinicians (e.g., psychiatrists, psychologists, clinical social workers, mental health counselors, and marriage and family therapists). More than half of states reported implementing FFS rate increases for one or more outpatient behavioral health providers in FY 2024 and about half of states in FY 2025. The two previous surveys, which asked more broadly about FFS rate increases for any behavioral health provider, found similar numbers of states planning to increase behavioral health provider rates in FYs 2022 and 2023. The size and scope of the rate increases varied, with some states targeting specific provider types or services, while others implemented broader increases. Although most Medicaid enrollees are now in managed care plans, state-set FFS rates often serve as a benchmark or floor for managed care payments in many states. The FY 2025 KFF survey suggests that behavioral health rate increases may be slowing, consistent with reimbursement rate trends for other provider types. About one quarter of states reported plans to increase outpatient behavioral provider rates in FY 2026. This slowdown may reflect the end of pandemic-era federal funds and anticipated federal funding reductions under the 2025 reconciliation law.

What does the FY 2025 KFF budget survey show about selected behavioral health provider types and treatment models?

The FY 2025 annual budget survey asked about state coverage of select optional behavioral health services and provider types: CCBHCs, which provide a broad array of coordinated services in a single setting, and two specialized treatment models for people with SMI: Assertive Community Treatment (ACT) and Coordinated Specialty Care for First Episode Psychosis (CSC-FEP).

State Medicaid recognition of Certified Community Behavioral Health Clinics (CCBHCs) as a provider type continues to grow. CCBHCs are a federally defined model of comprehensive community-based behavioral health clinics that provide or coordinate a core set of mental health and substance use services and serve patients regardless of an ability to pay. In FY 2025, KFF’s Medicaid budget survey asked state officials whether they recognized CCBHCs as a specific enrolled provider type for Medicaid reimbursement in FY 2025 or planned to add the recognition in FY 2026. Nineteen states reported recognizing CCBHCs as an enrolled provider type (Figure 1), up from nine in FY 2022, and several other states reported plans to add CCBHCs as a provider type in FY 2026. This growth has occurred alongside expanded federal support for the Section 223 CCBHC Medicaid demonstration, which gives participating states a pathway to certify CCBHCs, use prospective payments, and receive enhanced federal match rates. States may also add  CCBHCs as a provider type through other pathways, including Section 1115 demonstration waivers and Medicaid state plan authority, a state option made permanent through the 2024 Consolidated Appropriations Act. Recognizing CCBHCs as a distinct Medicaid provider type can support more flexible payment approaches, certification of CCBHCs against federal defined criteria, and make CCBHC services easier to identify in claims data.  However, formal recognition can require additional state administrative capacity, coordination across state agencies, and operational and budgetary changes. Some states may instead cover behavioral health services provided by CCBHCs through existing provider categories, while others may already have community mental health systems with state-defined service arrays that serve a similar function. Research suggests that CCBHCs have improved access to outpatient behavioral health care, with some evidence of reductions in acute behavioral health care use, such as emergency departments or hospitalization. More than 500 CCBHCs now operate across 46 states, DC, and Puerto Rico.

Nineteen State Medicaid Programs Recognize CCBHCs as a Provider Type (Choropleth map)

In FY 2025, two-thirds of states reported FFS coverage for Assertive Community Treatment (ACT), an evidence-based model for people with serious mental illness who need intensive support to remain stable in the community. ACT uses small, multidisciplinary teams to provide 24-hour individualized support in the community and can intensify support when symptoms worsen. It is designed for people with the most serious needs, including those whose severe symptoms and lack of illness awareness can make it difficult to stay engaged in treatment and have higher risk of repeated hospitalization and other disruptions to stable community living. Research suggests that ACT can reduce hospitalizations and improve engagement in care, especially for people with the highest needs and when services are implemented with fidelity to the ACT model. The American Psychiatric Association (APA) guidelines recommend ACT for patients with schizophrenia who have a history of poor engagement with services leading to frequent relapse or social disruption. In KFF’s FY 2025 Medicaid budget survey, 34 states including D.C. reported that ACT is covered under FFS Medicaid for adults (Figure 2).  Even in states that report Medicaid coverage for ACT, workforce and infrastructure constraints may limit access. For example, only about one-quarter (27%) of mental health facilities serving people with SMI reported offering ACT services in 2023. Budget pressures may also affect the availability of these services. In Idaho, 2025 budget cuts interrupted ACT services for people who  relied on ACT to stay stable in the community, and media reporting documented that some Medicaid enrollees receiving ACT services died after the disruption. Idaho later restored funding, though rebuilding these services may be difficult and costly.

Two-Thirds of States Report FFS Coverage for Assertive Community Treatment (ACT), While Fewer Cover Coordinated Specialty Care for First Episode Psychosis (CSC-FEP) (Choropleth map)

Far fewer states reported FFS coverage for Coordinated Specialty Care for First Episode Psychosis (CSC-FEP), an evidence-based early intervention model for people experiencing a first episode of psychosis. KFF’s FY 2025 Medicaid budget survey asked state officials whether they provide FFS reimbursement for CSC-FEP codes in FY 2025 or plan to do so in FY 2026. Seven states reported covering this service in FY 2025 (Figure 2) and several more states reported plans to add coverage in FY 2026. CSC-FEP emerged in the late 2000s as an early intervention model designed to connect people experiencing psychosis for the first time to coordinated treatment to reduce the serious and potentially lasting effects of untreated psychosis. This model includes coordinated medication management, therapy, family support and education, and other services. Research shows that people who receive this treatment experience fewer psychotic symptoms, fewer preventable hospitalizations, and better outcomes in work, school, and quality of life. The APA  guidelines recommend CSC-FEP for patients with schizophrenia experiencing a first episode of psychosis. In addition to the seven states reporting coverage for this model in FY 2025, four more states reported plans to add coverage for CSC-FEP in FY2026, and Virginia reported that coverage approved by its General Assembly will begin in FY 2027. Some states reported that these services are funded outside of Medicaid through the  federal Community Mental Health Services Block Grant, which requires states to set- aside 10%  of funds for  evidence-based programs for people with early serious mental illness.

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