Medicaid Waiver Tracker: Approved and Pending Section 1115 Waivers by State

Published: Sep 30, 2026

Section 1115 Medicaid demonstration waivers offer states an avenue to test new approaches in Medicaid that differ from what is required by federal statute, if [in the HHS Secretary’s view] the approach is likely to “promote the objectives of the Medicaid program.” They can provide states additional flexibility in how they operate their programs, beyond the considerable flexibility that is available under current law. Waivers generally reflect priorities identified by states as well as changing priorities from one presidential administration to another. Nearly all states have at least one active Section 1115 waiver and some states have multiple 1115 waivers. See the “Key Themes Maps” tab for a discussion of recent waiver trends.

This page tracks approved and pending Section 1115 waiver provisions (including expansions and restrictions) related to eligibility, benefits, and social determinants of health and other delivery system reforms, once such waivers are posted to the state waivers list on Medicaid.gov. For more information on inclusion criteria and on each provision, as well as a list of acronyms, see the Definitions tab.

Landscape of Approved and Pending Section 1115 Waivers (Stacked Bars)

 

Waivers with Eligibility Changes

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Section 1115 Eligibility Changes - Expanded Eligibility Groups (Table)

Waivers with Benefit Changes

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Section 1115 Benefit Changes - Select Benefit Expansions (Table)

Waivers with SDOH & Other DSR Changes

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Section 1115 SDOH & Other DSR Changes - Approved SDOH Provisions (Table)

All Approved Waivers by Topic

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Approved Section 1115 Medicaid Waivers (Table)

All Pending Waivers by Topic

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Pending Section 1115 Medicaid Waivers (Table)

See KFF's Work Requirements Tracker for additional state and national-level data related to work requirement implementation, including related KFF resources on work requirements.

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 work requirements early through a state plan amendment as well as approved (Georgia) and pending work requirement waivers (submitted to CMS since the start of the second Trump administration). The table below the map provides more detailed state waiver information.

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

States with Work Requirement Waiver Activity (Table)

Section 1115 waivers generally reflect priorities identified by states as well as changing priorities from one presidential administration to another.  Key Biden administration 1115 initiatives included waivers addressing enrollee health-related social needs (HRSN), pre-release coverage for individuals who are incarcerated, and multi-year continuous eligibility for children.

In March 2025, the Trump administration rescinded HRSN guidance issued by the Biden administration. CMS indicates this does not nullify existing HRSN 1115 approvals but going forward they will consider HRSN / SDOH requests on a case-by-case basis. In April 2025, the Trump administration announced it would be phasing out federal funding for “Designated State Health Programs” (DSHP) in waivers. In July 2025, the Trump administration released guidance indicating it will not approve (new) or extend (existing) continuous eligibility waivers for children or adults. CMS also announced in July it would be phasing out initiatives to strengthen the Medicaid workforce for primary care, behavioral health, dental, and home and community based services (not depicted in maps below).

This page tracks pending and approved waivers in key areas of recent state activity and will track Trump administration action in these areas going forward. Hover over individual states to display waiver expiration dates.

Social Determinants of Health

Social determinants of health (SDOH) are the conditions in which people are born, grow, live, work and age. SDOH include but are not limited to housing, food, education, employment, healthy behaviors, transportation, and personal safety. In 2022, CMS (under the Biden administration) announced a demonstration waiver opportunity to expand the tools available to states to address enrollee “health-related social needs” (or “HRSN”) including housing instability, homelessness, and nutrition insecurity, building on CMS’s 2021 guidance. In 2023, CMS issued a detailed Medicaid and CHIP HRSN Framework accompanied by an Informational Bulletin, which were updated in 2024.

In March 2025, the Trump administration rescinded the Biden administration HRSN guidance. CMS indicates this does not nullify existing HRSN approvals but going forward they will consider HRSN / SDOH requests on a case-by-case basis.

The “HRSN Waivers” map below identifies states with approval under the Biden administration HRSN framework. The “All SDOH Waivers” map identifies SDOH-related 1115 waivers more broadly, including those that pre-date or were approved outside of the HRSN framework. For more detailed waiver information, refer to KFF’s Medicaid Waiver Tracker (“SDOH” table) and HRSN waiver watch  (March 2024).

Section 1115 Waivers: Social Determinants of Health (SDOH) (Choropleth map)

Medicaid Pre-release Coverage for Individuals Who Are Incarcerated

In April 2023, the Biden administration released guidance encouraging states to apply for a new Section 1115 demonstration opportunity to test transition-related strategies to support community reentry for people who are incarcerated. This demonstration allows states a partial waiver of the inmate exclusion policy, which prohibits Medicaid from paying for services provided during incarceration (except for inpatient services). Reentry services aim to improve care transitions and increase continuity of health coverage, reduce disruptions in care, improve health outcomes, and reduce recidivism rates. The Biden administration approved 19 state waivers to facilitate reentry for individuals who are incarcerated. 

In September 2026, the Trump administration approved five reentry waivers and indicated that updated reentry demonstration guidance would be released within the next year. The map below identifies states with approved and pending waivers to provide pre-release services to Medicaid-eligible individuals who are incarcerated.  Medicaid pre-release waivers have been pursued by both Republican and Democratic governors. For more information, refer to KFF’s Medicaid Waiver Tracker (“Eligibility Changes” table) and related pre-release waiver watch (August 2024).

Section 1115 Waivers: Medicaid Pre-release Coverage for Individuals Who Are Incarcerated (Choropleth map)

Multi-year Continuous Eligibility for Children

The Consolidated Appropriations Act, 2023 required all states to implement 12-month continuous eligibility for children beginning on January 1, 2024. The Biden administration approved 9 waivers that allow states to provide multi-year continuous eligibility for children (e.g., from birth to age six). Continuous eligibility has been shown to reduce Medicaid disenrollment and “churn” rates (rates of individuals temporarily losing Medicaid coverage and then re-enrolling within a short period of time).

In July 2025, the Trump administration released guidance indicating it will not approve (new) or extend (existing) continuous eligibility waivers for children or adults. The map below displays states with waiver approval to provide multi-year continuous eligibility for children.  For more information, refer to KFF’s Medicaid Waiver Tracker (“Eligibility Changes” table) and related continuous eligibility waiver watch (February 2024).

Section 1115 Waivers: Multi-year Continuous Eligibility for Children (Choropleth map)
Section 1115 Waiver Tracker: Key Definitions and Notes (Table)

Recent Developments

General/Overview Resource

Eligibility and Enrollment Expansions

Eligibility and Enrollment Restrictions

Work Requirements:

Other:

Benefit Expansions

Benefit Restrictions, Copays, and Healthy Behaviors

Social Determinants of Health

Delivery System Reform

The Legal and Policy Landscape of Crisis Pregnancy Centers 

Published: Sep 30, 2026

Key Takeaways

  • There are an estimated 2,400 to 2,800 Crisis Pregnancy Centers (CPCs) in the US. These sites, also referred to as Pregnancy Centers, are established to dissuade pregnant people from seeking abortion care and are often associated with or established by faith-based or anti-abortion organizations. They usually attract clients by offering free pregnancy tests, ultrasounds, and material goods like diapers or clothing.  
  • CPCs largely lack oversight of how they handle client data, and clients have limited remedies if their data is leaked. While CPCs typically advertise or position themselves as medical clinics, the vast majority are not medical facilities. CPCs usually collect confidential health information from clients like pregnancy status or sexual history, but they are not subject to the federal medical privacy law known as the Health Insurance Portability and Accountability Act (HIPAA) because they do not bill insurance for their services or electronically transmit claims.  
  • Attempts to regulate CPCs have largely been unsuccessful in the courts. Citing CPC’s First Amendment protections, multiple courts, including the U.S. Supreme Court, have sided with CPCs against attorney general investigations, state laws designed to regulate CPCs, and private-sector actions to inform the public about their anti-abortion mission.  
  • In response to these legal challenges and with support from the Alliance Defending Freedom, a conservative Christian legal advocacy organization, some states have enacted legislation prohibiting state governments from interfering with the expression and association rights of CPCs or restricting CPCs’ ability to provide certain services.  
  • On the federal side, the Trump administration and anti-abortion legislators have prioritized CPC expansion. On Mother’s Day 2026, HHS established a new website, moms.gov, and it spotlights CPCs as a resource for pregnant people without identifying their anti-abortion mission and limited provision of services. The administration also opened the door to the possibility of extending federal funding support to CPCs through the federal Title X family planning program, through the program’s most recent funding guidelines, even though CPCs do not provide contraceptive services or supplies. 

Introduction

On Mother’s Day 2026, the Trump administration launched moms.gov, a website designed as a resource for mothers and their families. At the top of the page, the website features a link to a non-government website that helps locate “pregnancy centers,” also known as Crisis Pregnancy Centers (CPCs), as a resource for support, and positions CPCs alongside Federally Qualified Health Centers, nutrition facts, and guidance on opening Trump investment accounts. While there is no standard definition of what qualifies as a CPC, these unregulated sites typically are associated with or established by faith-based or anti-abortion organizations, with their primary mission being to dissuade pregnant people from seeking abortion care. This brief examines the legal status of CPCs, attempts to regulate them, and future efforts to expand their footprints as they gain more recognition and funding from local, state, and federal programs.

What Are Crisis Pregnancy Centers and How Do They Attract Clients 

CPCs have their origins in the 1960s in the early days of the antiabortion movement. They usually offer pregnancy tests, ultrasound, and material goods like diapers or clothing to support pregnant clients at no cost. However, these services are sometimes conditioned on clients attending religious seminars. According to the U.S. Government Accountability Office as of 2025, between 2,400 and 2,800 CPCs were operating across the country, and most of them were affiliated with three anti-abortion organizations — Heartbeat International, National Institute for Family and Life Advocates (NIFLA), and Care Net. Post-Dobbs, the number of newly opened or reopened CPCs has been highest in the South, which is also where more states ban the provision of abortion or impose early gestational limits on the provision of abortion care. 

Box 1: Major Crisis Pregnancy Center Networks

There are three main national organizations that support Crisis Pregnancy Centers in the United States. Their membership figures overlap and may include maternity homes, adoption agencies, and “abortion recovery programs” as affiliates. Therefore, the total number of affiliates for these three organizations is much higher than the GAO’s estimate of 2400 to 2800 CPCs operating in the U.S. in 2025. 

Heartbeat International

  • Founded in 1971 as Alternatives to Abortion, its stated mission is to “advance life-affirming pregnancy help worldwide.” Heartbeat International describes their pregnancy centers as: “life-affirming non-profit service providers that provide women who have an unexpected pregnancy with alternatives to abortion.” 
  • Heartbeat International states it has over 1,445 affiliate pregnancy centers in the United States, and has an estimated 4,000 affiliates globally, including pregnancy centers, maternity homes, and adoption agencies.  

National Institute of Family and Life Advocates (NIFLA)

  • Founded in 1993, NIFLA’s mission is to: “promote the sanctity of human life, born and unborn, through legal support, counsel, and services to pro-life pregnancy centers.” NIFLA reports that they represent over 1,800 pregnancy centers nationwide.  
  • NIFLA created the Institute in Limited Obstetric Ultrasound, which trains medical professionals to perform ultrasounds in their affiliate clinics, to reach “abortion-minded women.” NIFLA has worked over the past two decades to introduce ultrasound services to pregnancy centers.

Care Net  

  • Founded in 1975, Care Net’s stated mission is: “to offer compassion, hope, and help to anyone considering abortion by presenting them with realistic alternatives and Christ-centered support through our life-affirming network of pregnancy centers, mobile medical units, churches, organizations, and individuals.” Care Net reports it has over 1,200 affiliates nationwide. 

The main purpose of CPCs is to dissuade people from opting for abortion, instead encouraging them to choose adoption or parenting using a variety of approaches to reach individuals whom they call “abortion-determined” clients. For years, CPCs have opened near reproductive health facilities, a practice known as “co-locating,” so they can approach patients attempting to visit abortion clinics and discourage them from seeking or obtaining abortion care. The American College of Obstetricians and Gynecologists has stated, “by using deception, delay tactics, and disinformation, CPC staffs undermine the tenets of informed consent and patient autonomy and impede access to comprehensive, ethical care.” In addition to co-locating near comprehensive reproductive health clinics, CPCs position themselves as attractive to young people, people with low incomes, people who are uninsured or underinsured, people experiencing unintended pregnancies, and communities that have historically experienced barriers to health care.  

In 2024, over 71% of CPCs nationwide offered nondiagnostic ultrasounds, 28% advertised testing for Sexually Transmitted Infections (STIs), and 6% advertised HIV testing. As hospital labor and delivery units close and OB-GYN practitioners leave states like Idaho that ban the provision of abortion care, several CPCs have begun to see increased foot traffic. However, CPCs will not be able to fill persistent and growing gaps in the maternity care safety net for a variety of reasons, including their requirements for recruiting qualified clinicians. For example, the 7B Care Clinic, a CPC, on the Idaho-Washington border, recently sought to provide prenatal services due to the recent closure of the local hospital’s labor and delivery unit. 7B created a contract with a rural Washington hospital to bring qualified clinicians into the center to see clients; however, the center required potential clinicians to sign a pledge that aligned with Christian values. The contract with the hospital was subsequently canceled when providers refused to sign the pledge, thus leaving 7B with no ability to expand prenatal services.  

Most Crisis Pregnancy Centers Are Not Medical Clinics

Although Crisis Pregnancy Centers either advertise or position themselves as medical clinics, the vast majority are not medical facilities. While CPCs offer a variety of services, including ultrasounds, and some advertise the ability to rule out conditions like an ectopic pregnancy, many CPCs do not have a credentialed or practicing qualified physician or a registered nurse affiliated with their center. CPCs that have a trained clinician affiliated with their center may employ them only on a part-time or volunteer basis.  

Although some CPCs may offer limited medical services that are already available over the counter to consumers, such as pregnancy and STI testing, other clinics offer ultrasounds as a tool to persuade patients not to seek an abortion rather than as a diagnostic test. CPCs are sometimes staffed by volunteers with limited or no medical training, and because only a medical professional with specialized training can interpret ultrasounds or assess fetal health, the ultrasounds performed by CPCs are largely considered non-diagnostic. Instead, ultrasounds at CPCs are used as a persuasive tool to show pregnant clients their fetus. These nondiagnostic ultrasounds can lead to inaccurate gestational age calculations or missed pregnancy complications such as ectopic pregnancy.  

The misdiagnosis of serious medical conditions by CPCs has resulted in several lawsuits against the centers. Some CPC networks have instructed their affiliates to avoid offering ultrasounds to clients suspected of having serious medical conditions like an ectopic pregnancy. Recently, a non-profit group compiled a list of CPCs that advertise their ability to “rule out” ectopic pregnancies, even though these centers lacked the medical expertise and equipment to properly diagnose an ectopic pregnancy. In Massachusetts, a class-action lawsuit was filed against Clearway Clinic, a CPC, after the clinic failed to diagnose a woman’s ectopic pregnancy. In response, Massachusetts enacted a law regulating who may perform pregnancy-related ultrasounds. Under the new law, a person may not provide ultrasound services related to a possible or actual pregnancy unless supervised by a licensed health care provider who, acting within their scope of practice, provides medical care to people who are pregnant or may become pregnant.  

Other states have also enacted similar laws regulating the provision of ultrasound services. In the state of Washington, all ultrasounds must be performed only under the supervision of a licensed health care professional acting within their scope of practice. Connecticut similarly has a law that prevents a person from performing an ultrasound unless it was ordered by a health care provider acting within their scope of practice for a medical or diagnostic purpose. Only four states (New Hampshire, New Mexico, North Dakota, and Oregon) require providers of ultrasounds to have a license issued and regulated by the state. 

Ultrasound licensing statutes make it illegal for someone without a medical imaging license to perform ultrasounds. In practice, however, there is not a consistent enforcement mechanism to hold unlicensed individuals accountable for providing ultrasounds. North Dakota’s own licensing board acknowledges it has no jurisdiction over unlicensed individuals, and New Hampshire has also not taken any action against unlicensed volunteers performing ultrasounds at some CPCs, leaving enforcement to criminal prosecutors who thus far have not pursued it. This is in sharp contrast to states like California, where the attorney general has used subpoena power and cease-and-desist authority against CPCs to enforce violations of California law, which requires ultrasound technology to be used only in licensed facilities or by licensed providers.  

Most Crisis Pregnancy Centers Are Not Subject to HIPAA, the Federal Health Privacy Law  

Crisis Pregnancy Centers collect confidential health information from clients; however, they are not required to adhere to medical privacy regulations. The Health Insurance Portability and Accountability Act (HIPAA) privacy rule is a federal standard prohibiting medical entities from disclosing confidential health information without patient consent. Coveredentities subject to the HIPAA Privacy Rule are defined as: (1) health care providers; (2) health plans (insurance companies); and (3) health care clearinghouses that transmit patient health information in connection with health care transactions. A health care transaction is an exchange of information to conduct financial or administrative activities related to health care, such as processing payment for services.  

While some CPCs work with health care providers, neither the centers nor the providers who work or volunteer there are considered covered entities bound by HIPAA if they do not conduct health care transactions, such as billing insurance. Most CPCs do not charge for their services, nor do they accept insurance. Instead, CPCs are funded through private donations, national CPC networks, state government funds, and federal funds through programs like Temporary Assistance for Needy Families (TANF). It is estimated that CPCs received over $2 billion in revenue in 2024; however, none of this was generated from charging clients. CPCs’ variety of funding sources allows them to offer their services without needing to conduct health care transactions.  

Data Privacy Violations at Crisis Pregnancy Centers Often Escape Regulatory Enforcement 

Some CPCs have misled clients about the safety of their confidential personal information by including notices on their website, alleging HIPAA compliance, or by requiring clients to sign authorization forms. However, these steps can give clients a false sense of confidentiality: because CPCs are not bound by HIPAA, there is no oversight of how they handle client data, and clients have limited remedies if that data is leaked. In 2024, it was reported that Heartbeat International, one of the largest CPC networks, posted on the internet a training video with the full names, date of last menstrual period, and services received by clients of one of its affiliate centers in Louisiana. The breach of client health information was reported to the Department of Health and Human Services Office for Civil Rights (OCR), the entity responsible for enforcing HIPAA. However, OCR closed the complaint after determining that the CPC was not a HIPAA-covered entity and that it therefore lacked authority to investigate the violation, leaving the affected clients without recourse and no penalties for Heartbeat International. In contrast, violations of HIPAA for covered entities can lead to criminal penalties and fines of up to $2 million per violation based on the severity of the data breach and whether the entity took corrective action.  

Additionally, there is currently no enforcement mechanism to stop organizations not bound by HIPAA from falsely claiming HIPAA compliance. While entities like the Federal Trade Commission (FTC) work to protect consumers from fraud and deception, they only have authority over businesses and other for-profit organizations, not non-profits. Therefore, because clients at CPCs receive services for free, CPCs fall outside the FTC’s jurisdiction. Some advocacy groups have submitted complaints to state attorneys general urging investigations into CPCs that misrepresented their HIPAA compliance, and some centers subsequently removed HIPAA-compliance language from their websites. However, CPCs continue to collect client medical information with little accountability for protecting privacy. 

Courts Have Shielded CPCs from State Oversight

Across multiple states, courts have consistently sided with CPCs against attorney general investigations and private-sector pushback, citing First Amendment protections. 

Compelled Notice Requirements

NIFLA v. Becerra (CA, 2018): California’s FACT Act required CPCs to post notices about state-funded family planning services (for licensed clinics) or disclose their unlicensed status (for unlicensed clinics, closely matching CPCs). NIFLA sued, and after losing at the district court and Ninth Circuit, won at the Supreme Court. 

Outcome: The Supreme Court struck down both notice requirements as unconstitutional compelled speech, establishing the foundational precedent that state governments cannot force CPCs to disclose licensing status or promote state services. Later cases rely on this Supreme Court ruling as precedent.

Abortion Pill Reversal Claims  

NIFLA v. James (NY, 2024- ongoing): Attorney General Letitia James sued Heartbeat International and 11 CPCs under New York’s deceptive trade practice statute, alleging their abortion pill reversal advertising misrepresented the treatment as safe and effective.  

Outcome: This underlying case is still pending, but a related ruling in NIFLA v. James (described below) has weakened the state’s position going forward. 

NIFLA v. James (NY, 2024): In response to the suit above, NIFLA and two New York CPCs filed a separate countersuit against James, arguing her enforcement effort to prevent CPCs from advertising abortion pill reversal chilled their speech and discriminated against them for their pro-life views.  

Outcome: The Second Circuit affirmed a preliminary injunction protecting NIFLA and the 11 CPCs, holding the First Amendment allows CPCs to promote abortion pill reversal, a precedent likely to help Heartbeat International defend the still-pending case above. 

California v. Heartbeat International (2023–ongoing): Attorney General Rob Bonta filed a lawsuit against Heartbeat International for their promotion of abortion pill reversal. The false-advertising suit survived a First Amendment summary judgment challenge, and there was a 6-week trial which began in June 2026 in Alameda County; closing arguments were held on September 17, 2026. 

Outcome: Still unresolved, but it is one of the few cases where a state’s claims have proceeded to trial rather than being blocked outright. California requires state judges to issue a ruling within 90 days after the case is officially submitted for decision. 

Investigative Subpoenas 

First Choice v. Platkin (NJ, 2002-2026): Attorney General Matthew Platkin subpoenaed a CPC for donor, donation, and data-handling records amid fraud allegations.  

Outcome: In 2026, the Supreme Court ruled that compelling disclosure of CPC donor identities violates associational First Amendment rights, since such demands can chill donors from supporting the group. While the Court’s decision did not fully extinguish the attorney general’s subpoena, it established First Amendment protections for CPCs that lower courts must now follow. This could make it harder for states to subpoena records of CPCs’ donors, volunteers, board members, or clients during investigations.

Private Sector Pushback

Yelp v. Paxton (TX, 2023–ongoing): Attorney General Ken Paxton sued Yelp on CPCs’ behalf over its consumer notices describing CPCs’ limited medical services, alleging misrepresentation under Texas law. A Bastrop County court initially dismissed the case for lack of jurisdiction (Feb. 2024), but the Texas 15th Court of Appeals reversed in October 2025, holding Texas courts do have jurisdiction; Yelp has appealed to the Texas Supreme Court.  

Outcome: This case is ongoing and, unlike the other cases, does not turn on CPCs’ own First Amendment rights. This case demonstrates that private companies criticizing CPCs can themselves face sustained legal exposure from CPC-supportive state governments. 

State Laws Limiting Regulations of Crisis Pregnancy Centers  

Recently, the Alliance Defending Freedom, a conservative Christian legal advocacy organization, has pushed for states to enact their model legislation protecting CPCs. The Center Autonomy and Right of Expression (CARE) Act prohibits state governments from interfering with the First Amendment free expression and association rights of CPCs or restricting their ability to provide pregnancy services because they do not counsel for, or offer, abortions or contraception. The CARE Act has passed in at least four states, including Kansas, Montana, Oklahoma, and Wyoming, providing CPCs protection from regulation. In Wyoming, for example, government entities are prohibited from: (1) requiring CPCs to perform abortions; (2) requiring CPCs to provide medication abortion or contraception; (3) requiring CPCs to refer clients for abortion or contraception; or (4) requiring CPCs to counsel in favor of abortion or contraception. Beyond the First Amendment protections, the CARE Act further restricts states’ ability to regulate CPCs.  

Looking Ahead 

With the launch of moms.gov and other proposed policies to promote fertility, Crisis Pregnancy Centers may gain greater attention and potentially increased federal funding in the coming years. Obria, one CPC chain with sites in five states, has begun to expand their medical offerings to position its centers as an alternative to national abortion providers like Planned Parenthood. From 2022 to 2025, twenty-one states provided $491 million in funding to CPCs, not including funds allocated through federal programs like Temporary Assistance for Needy Families (TANF). In 2019, the first Trump administration awarded Obria, a chain of CPCs that opposes abortion and contraception, $1.7 million of funding under Title X, a program designed to provide free or reduced-cost family planning services to low-income and uninsured people.  

In July 2026, the Trump administration released its revised Fiscal Year 2027 Notice of Funding Opportunity (NOFO) for Title X. The NOFO stated that the Trump administration would prioritize grantee applications that “reduce overmedicalization by strengthening approaches focused on underlying behavioral and lifestyle factors of health and evidence-based practices such as fertility-awareness based methods; promote health and body literacy; advance reproductive goals counseling for all clients; and support family formation.” In response, the National Family Planning and Reproductive Health Association (NFPRHA), Planned Parenthood Federation of America, and 23 States (CA, CO, CT, DE, HI, IL, KY, ME, MD, MA, MI, MN, NV, NJ, NM, NY, OR, PA, RI, VT, VA, WA, WI) have each filed lawsuits challenging the FY 2027 NOFO, arguing that its priorities depart from the factors Congress intended HHS to consider in awarding Title X grants and instead impose politically driven, vaguely defined criteria that disadvantage qualified applicants.  

These new priorities could re-open the door for CPCs to receive Title X funds in addition to ongoing efforts by anti-abortion states to invest more resources into these centers. As states and the federal government continue to direct funds into CPCs, challenges and gaps in regulating these centers will likely persist, driven by First Amendment protections and a growing body of state laws designed to shield them from oversight. 

Early Medicaid Work Requirement Insights From Nebraska

Published: Sep 29, 2026

On May 1, 2026, Nebraska became the first state to enforce new Medicaid work requirements. The 2025 reconciliation law requires states to condition Medicaid eligibility for adults in the ACA Medicaid expansion group and enrollees in certain waiver programs (such as in Georgia and Wisconsin) on meeting work requirements or exclusion criteria starting January 1, 2027; however, states have the option to implement requirements sooner (as is the case for Nebraska). KFF analysis shows most Medicaid adults under age 65 are working already (without a requirement) or face barriers to work. This brief describes the verification process for Medicaid work requirements in Nebraska and examines early data from Nebraska’s September Medicaid Advisory Committee (MAC) meeting on outcomes for individuals subject to work requirements, including for those newly applying for Medicaid as well as those renewing Medicaid coverage through August 2026. Data show that among those subject to the new work requirements:

  • 46% of new applicants and 34% of individuals renewing coverage met qualifying activities (e.g., working at least 80 hours a month, having a monthly household income of at least $580, attending school).
  • 39% of new applicants and 57% of individuals renewing coverage qualified for an exclusion from work requirements (e.g., due to being a parent of a child under age 14, being medically frail).
  • 14% of new applicants and 7% of individuals renewing coverage had their applications denied or lost coverage due to not meeting work requirements.
  • Only a small number of people (2% of new applicants and 2% of individuals renewing coverage) had a short-term hardship exception.

What is the verification process for Medicaid work requirements in Nebraska?

Nebraska is using a combination of available data and self-declaration forms to verify whether individuals meet work requirements or exclusion criteria; the state has also adopted temporary hardship exceptions. In cases where the state can automatically verify that individuals meet work requirements, it sends an approval notice. For individuals where the state does not have enough information, the state sends a notice describing the additional information that is required and a declaration form that must be returned within 30 days. Individuals can use the declaration form to attest that they met qualifying activities or that they meet the criteria for an exclusion from the requirements. The interim rule clarified that while states are allowed to accept self-declaration through 2027, starting in January 2028, except for medical frailty, states must request documentation from individuals when the state does not have data on file. Nebraska has also chosen to adopt optional short-term hardship exceptions for enrollees (or applicants) experiencing certain extenuating circumstances, including residing in counties with high unemployment rates or experiencing natural disasters, individuals admitted to a hospital or nursing facility, or those who must travel outside of their community for an extended period to obtain medical care for themselves or a dependent.

Qualifying Activities and Exclusions from Work Requirements

Adults must meet qualifying activities or exclusion criteria to enroll in Medicaid and maintain coverage. Qualifying activities include:

  • Working at least 80 hours a month;
  • Having a monthly household income of at least $580;
  • If a seasonal worker, having an average monthly income over 6 months of minimum wage multiplied by 80 hours;
  • Attending school half time;
  • Volunteering or participating in a work program for at least 80 hours a month; or
  • Doing a combination of activities for at least 80 hours per month.

Exclusions from the work requirements include:

  • Pregnant and postpartum individuals;
  • American Indian and Alaska Natives;
  • Parents and caretakers of dependent children under age 14 or disabled individuals;
  • Veterans with a disability;
  • Incarcerated individuals;
  • Individuals receiving SNAP and not exempt from SNAP work requirements; and
  • People who are medically frail.

States must first determine if an individual is excluded from the Medicaid work requirements before assessing if an individual meets the qualifying activities. Some individuals who meet exclusion criteria may also be working.

What are the initial data on Nebraska Medicaid application and renewal outcomes?

Among those who were newly applying for Medicaid and subject to the new work requirements in Nebraska, 86% of applicants met the work requirements or qualified for an exclusion or short-term hardship exception, while 14% of individuals had their application denied (Figure 1). A total of 9,614 applications were processed between May to August. Of these, some were submitted prior to May and therefore not subject to work requirements, and 4,434 were denied for reasons other than work requirements (e.g., income exceeding Medicaid eligibility thresholds). Among the remaining 4,089 applications subject to work requirements:

  • Nearly half of all individuals (46%) met the qualifying activities. Among those who met the requirement, the vast majority of people (92%) worked 80 or more hours in the month prior to their application or had a household income of $580. A much smaller share (8%) were enrolled in an education program or work program, volunteered, or met requirements by combining hours across multiple types of qualifying activities.
  • About 4 in 10 individuals (39%) qualified for an exclusion. Of these applicants, one-third were parents or caregivers of a child under the age of 14 or a disabled individual (33%); one quarter were medically frail, and 12% were an American Indian or Alaska Native. The remaining 30% qualified for other exclusions. Because the state is relying on self-attestation, future documentation requirements may lead to a lower share of individuals who qualify for an exclusion.
  • Only a small number of individuals had a short-term hardship exception. Only 92 individuals met the criteria for short-term hardship exceptions, with the majority of these being individuals who required temporary use of medical services or living in counties that were exempted due to high unemployment.
  • 14% of individuals had their application denied. Most of the 557 denied applications were due to non-response to requests for additional information (84%); only 16% of applicants with denied applications were affirmatively found to be noncompliant.
Nebraska Application Outcomes Among Individuals Subject to Medicaid Work Requirements (Pie Chart)

Among those who were renewing their Medicaid coverage and subject to the new work requirements, 93% met work requirements or qualified for an exclusion or short-term hardship exception and had their coverage renewed, while 7% of enrollees lost coverage (Figure 2). A total of 7,280 renewals subject to work requirements were processed between July and mid-August. Other expansion enrollees determined ineligible and disenrolled at renewal for reasons not related to work requirements (e.g., moving out of state or exceeding income eligibility) are not shown in the figure below.

  • Over half (57%) of individuals renewing their coverage qualified for an exclusion from the requirements. Medically frail individuals (39%) and parent/caregivers (31%) made up the majority of those who met an exclusion. States are more likely to have medical claims history for individuals renewing coverage than new applicants, meaning Nebraska may have been able to automatically verify medical frailty for a higher share of enrollees compared to applicants. States are also required to verify exclusions status first, and it is likely that some enrollees who were excluded, especially parents, are also working.
  • About a third of individuals (34%) met the qualifying activities requirement. Nearly all (97%) of individuals who met the qualifying activities were either working 80 hours a month or had a household income of $580. The remaining 3% met the requirements by attending school, volunteering, or engaging in a combination of activities.
  • A small share of individuals qualified for a short-term hardship exception. Of the 127 people who had a short-term hardship exception, 109 lived in counties experiencing natural disasters and 15 lived in a high unemployment county.
  • 7% of people lost coverage due to not meeting the work requirements. Of the 533 individuals who lost coverage, 92% did not respond to verification compliance requests. The remaining 8% were affirmatively found to be noncompliant.
Nebraska Renewal Outcomes Among Individuals Subject to Medicaid Work Requirements (Pie Chart)

What can additional data show?

While these data provide early insights into how coverage may be affected for enrollees subject to the new work requirements, additional data may provide a more comprehensive picture. More granular data on who is losing coverage could shed light on particular barriers certain individuals may be facing in trying to prove they met qualifying activities (e.g., gig workers or those with multiple part-time positions) and may help the state identify additional data to include as part of the verification process. In addition, it remains unclear if individuals who were denied coverage or disenrolled because they did not respond to notices of non-compliance were ineligible for coverage, unaware of the fact they needed to provide additional information, or experienced difficulty providing documentation of their exclusion or work status. Additional data, including whether these individuals reapply for coverage, could provide insight.

Required changes to the state’s medical frailty verification process specifically and limitations on the use of self-attestation starting in 2028 will likely affect disenrollment rates over time. CMS recently notified the state that it will need to make changes to its medical frailty verification process. If the state is required to tighten the verification process, fewer individuals may qualify for the exclusion in the future. More broadly, while the state’s reliance on self-attestation in 2027 will likely mitigate some coverage losses that would have occurred had documentation been required in the first year of implementation, future documentation requirements may impose a barrier that will lead to a decrease in the number of people who are able to verify they meet work requirements or qualify for an exclusion. As the state makes changes to its processes, monitoring the interactive effect of application denials and disenrollments on Medicaid enrollment in the state as well as whether the new rules lead to fewer individuals applying for Medicaid will be important.

Americans’ Challenges with Health Care Costs

Published: Sep 29, 2026

Editorial Note: This brief was updated on September 29, 2026, to include the latest KFF polling data. It was originally published on December 14, 2021.

For many years, KFF polling has found that the high cost of health care is a burden on U.S. families, and that health care costs factor into decisions about insurance coverage and care seeking. These costs also rank as the top financial worry for adults and their families. This data note summarizes recent KFF polling on the public’s experiences with health care costs. Main takeaways include:

  • Health care costs are at the top of the list of people’s financial worries, with about a quarter (27%) saying they are “very” worried about affording health care costs for themselves and their families. This is followed by about one in five adults who are “very” worried about affording other household expenses, such as gasoline and transportation costs (22%), their rent or mortgage (21%), food and groceries (20%), or monthly utilities (19%).
  • The cost of health care can lead some to put off needed care. About three in ten (28%) adults say in the past 12 months they have skipped or postponed getting health care they needed because of the cost. Uninsured adults under age 65 (62%), young adults under age 30 (40%), Hispanic adults (34%), adults with lower incomes (32%), and women (31%) are among the most likely to report that they put off needed care in the past year because of the cost. Putting off needed health care can have health repercussions; about one in seven (15%) adults overall say their health got worse because they skipped or delayed needed care for any reason, including cost, rising to 27% among those with multiple health conditions.
  • Just under half of adults in the U.S. say it is difficult to afford health care costs and substantial shares struggle to pay medical bills, often with financial consequences. About one in five (22%) adults overall say they had problems paying or were unable to pay medical bills in the past 12 months, including one in seven (14%) who say they cut back on basic household expenses, like clothes or food in order to pay health care costs. These experiences are especially common among younger adults, women, those with lower incomes, and the uninsured. In addition, LGBTQ+ adults and those with multiple health conditions face outsized problems paying medical bills.
  • The cost of prescription drugs prevents some people from filling prescriptions. About four in ten (43%) U.S. adults say they have not taken their medication as prescribed in the past year due to costs. This includes three in ten who say they have taken an over-the-counter drug instead of getting a prescription filled (31%), a quarter (27%) who have not filled a prescription, and one in five (19%) who have cut pills in half or skipped doses of medicine because of the cost. Larger shares of lower-income, uninsured, women, Black, and Hispanic adults report taking these measures.
  • Health care debt is a burden for a large share of Americans. In 2022, about four in ten adults (41%) reported having debt due to medical or dental bills including debts owed to credit cards, collections agencies, family and friends, banks, and other lenders to pay for their health care costs, with disproportionate shares of Black and Hispanic adults, women, parents, those with low incomes, and uninsured adults saying they have health care debt.
  • Those who are covered by health insurance are not immune to the burden of health care costs. Large shares of adults with employer-sponsored insurance (ESI) and those with Marketplace coverage rate their insurance as “fair” or “poor” when it comes to their monthly premium and to out-of-pocket costs to see a doctor. In addition, three in ten insured adults ages 18-64 say report skipping or postponing care because of the cost and about a quarter say they had problems paying medical bills in the past year.

Worries and Difficulty Affording Medical Costs

For most of 2026, health care costs have remained at or near the top of the list of people’s financial worries, with about six in ten saying they are “very” (27%) or “somewhat worried” (35%) about affording health care costs for themselves and their families, including the cost of health insurance and out-of-pocket costs for things like office visits and prescription drugs. About one in five adults say they are “very worried” about affording other household expenses, such as gasoline and transportation costs (22%), their rent or mortgage (21%), food and groceries (20%), or monthly utilities (19%).

Notably, just under nine in ten (87%) uninsured adults under age 65 say they are very or somewhat worried about affording the cost of health care, though a large share of insured adults under age 65 are also worried (64%). Health care costs are a top household worry across insurance types and across partisans. (Source: KFF Health Tracking Poll: July 2026)

Stacked bar chart showing the public's levels of worry when it comes to affording living necessities. Health care tops the list of the public's economic anxieties. Shown among total adults.

Echoing these worries, many U.S. adults find health care costs difficult to afford. While lower income and uninsured adults are the most likely to report this, those with health insurance and those with higher incomes are not immune to the high cost of medical care. Just under half of U.S. adults say that it is very or somewhat difficult for them to afford their health care costs (44%). Uninsured adults under age 65 are much more likely to say affording health care costs is difficult (82%) compared to those with health insurance coverage (42%). Additionally, a slight majority of Hispanic adults (55%) and half of Black adults (49%) report difficulty affording health care costs compared to about four in ten White adults (39%). Adults in households with annual incomes under $40,000 are more likely than adults in households with higher incomes to say it is difficult to afford their health care costs. (Source: KFF Health Tracking Poll: May 2025)

Mirrored bar chart showing shares who say it is easy or difficult to afford their health care costs by total, insurance status, race/ethnicity, and household income.

The cost of care can also lead some adults to skip or delay seeking services. Roughly three in ten adults (28%) say that they have skipped or postponed getting needed health care in the past 12 months because of the cost. Women, younger adults, Hispanic adults, and those with lower incomes are more likely than their counterparts to report skipping or postponing care due to cost. In addition, roughly six in ten (62%) uninsured adults say they have skipped or postponed getting the health care they needed due to cost. Having health insurance, however, does not offer full protection as three in ten adults ages 18 to 64 with insurance still report not getting health care they needed due to cost.

Single bar chart showing percent who say they have skipped or postponed getting needed health care in the past 12 months because of the cost by total, age, gender, race/ethnicity, household income, and insurance status.

Skipping care for any reason, including cost, can have notable health impacts. Roughly one in seven (15%) adults report that their health got worse because they skipped or delayed getting care for any reason. Among adults under age 65, those who are uninsured are significantly more likely than those with health coverage to say that their health worsened due to skipped or postponed care (27% vs. 17%). Four times as many adults under age 30 (24%) say their health got worse after skipping or postponing care as adults ages 65 and older (6%), most of whom have Medicare coverage. (Source: KFF Survey of Health Access and Caregiving)

Single bar chart showing the share who say their health got worse because they didn't get care or postponed their care by total, age, and insurance status.

Problems Paying Medical Bills

About one in five (22%) adults overall say they had problems paying or were unable to pay medical bills in the past 12 months, including bills for doctors, tests or labs, or medication. Larger shares of younger adults, women, Hispanic adults, Black adults, those with lower incomes, and adults under age 65 without health insurance report problems paying medical bills than their counterparts.

Problems paying bills can lead to important financial consequences, with one in seven (14%) adults saying they have had to cut back on household expenses like food, clothing, or other basic household items in order to pay for health care costs. This experience is more common among adults with lower incomes (20% of those with an income of less than $40,000 a year) and uninsured adults under age 65 (26%).

A Quarter of Adults Had Problems Paying Medical Bills, One in Seven Had To Cut Back on Household Expenses (Split Bars)

Skipping Care and Medical Bill Problems Among LGBTQ+ Adults and Those With Serious Health Conditions

KFF polling has found that some populations are more likely than others to report challenges with health care affordability. One such population is LGBTQ+ adults, who are on average younger and have lower incomes than their non-LGBTQ+ counterparts. More than four in ten (43%) LGBTQ+ adults report skipping or delaying care in the past year due to cost, compared to about a quarter (26%) of non-LGBTQ+ adults, according to the KFF Survey of Health Access and Caregiving. Another three in ten LGBTQ+ adults report that they had problems paying or an inability to pay medical bills in the past year, including two in ten (19%) who report cutting back on basic household expenses to pay for health care costs. Trans adults are especially likely to report these challenges, with over half (56%) of trans adults saying they skipped or delayed care because of the cost. Almost half (45%) of trans adults say their health got worse due to delayed or skipped care for any reason. (For a more detailed analysis, see Examining LGBTQ+ Adults’ Experiences with Health Care Costs and Access)

Bar chart showing share of adults ages 18-64 who say their health got worse because they skipped or delayed care. Reported among total adults ages 18-64, by number of active health conditions, and among adults treated for diabetes, asthma, emphysema or lung disease, cardiovascular disease, cancer, or a mental health condition.

Those with multiple and complex health conditions also face disproportionate problems with medical bills and worsened health due to skipping care. About one-third (36%) of adults ages 18-64 with three or more health conditions report they did not get the health care they needed in the past year because of the cost and a quarter (27%) say their health got worse because they skipped or delayed care for any reason, including cost. More than a third (36%) of those ages 18-64 with three or more conditions report problems paying medical bills in the past year, while around one in four (24%) say they have cut back on household expenses to pay for health care. (For a more detailed analysis, including the experiences of adults with conditions like cancer, mental health conditions, and diabetes, see: Health Care Access and Affordability for Adults with Multiple or Complex Health Conditions: A Snapshot of Patient Experiences)

Bar chart showing share of adults ages 18-64 who say their health got worse because they skipped or delayed care. Reported among total adults ages 18-64, by number of active health conditions, and among adults treated for diabetes, asthma, emphysema or lung disease, cardiovascular disease, cancer, or a mental health condition.

Prescription Drug Costs

The high cost of prescription drugs also leads some people to cut back on their medications in various ways. About three in ten adults (31%) say in the past 12 months they have taken an over-the-counter drug instead of getting a prescription filled because of cost concerns, while about a quarter (27%) say they have not filled a prescription and about one in five (19%) say they have cut pills in half or skipped doses of medicine due to cost. Overall, four in ten (43%) adults report taking at least one of these measures in the past year, continuing an upward trend from a third (33%) in 2025 and about three in ten (31%) in July 2023.

Larger shares of adults in households with lower and middle incomes report resorting to these cost-saving prescription medication solutions compared to those with higher incomes. About half of adults in households with annual incomes under $40,000 (52%) or between $40,000 and $90,000 (47%) say they have not taken their medication as prescribed due to the cost in the last year, compared to three in ten adults in households with incomes of $90,000 or more. Uninsured adults under age 65 are more likely than their counterparts to also report not taking their medicine as prescribed due to costs (58% compared to 43% of insured adults under age 65). Additionally, half of women (49%) say they have taken any of these prescription medication measures compared to about a third (36%) of men. Over half (55%) of Black adults say the same, compared to half (47%) of Hispanic adults and four in ten White adults. (Source: KFF Health Tracking Poll: March 2026)

Multiple split bars showing the percent who have taken steps to reduce the cost of care including taking an over-the-counter drug instead of getting a prescription filled, not filled a prescription for medicine, or cut pills in half or skipped doses of medicine.

Health Insurance Cost Ratings

Health insurance provides some financial protection, but premiums and out-of-pocket costs can still present a financial burden for many individuals. Overall, most insured adults rate their health insurance as “excellent” or “good” when it comes to the amount they have to pay out-of-pocket for their prescriptions (61%), the amount they have to pay out-of-pocket to see a doctor (53%), and the amount they pay monthly for insurance (54%). However, at least three in ten rate their insurance as “fair” or “poor” on each of these metrics, and affordability ratings vary depending on the type of coverage people have.

Adults who have private insurance through employer-sponsored insurance or Marketplace coverage are more likely than those with Medicare or Medicaid to rate their insurance negatively when it comes to their monthly premium, the amount they have to pay out of pocket to see a doctor, and their prescription co-pays. About one in four adults with Medicare give negative ratings to the amount they have to pay each month for insurance and to their out-of-pocket prescription costs, while about one in five give their insurance a negative rating when it comes to their out-of-pocket costs to see a doctor.

Medicaid enrollees are less likely than those with other coverage types to give their insurance negative ratings on these affordability measures (Medicaid does not charge monthly premiums in most states, and copays for covered services, where applied, are required to be nominal). (Source: KFF Survey of Consumer Experiences with Health Insurance)

Split bar chart showing shares of adults by main insurance coverage who rate specific aspects of their current health insurance as either fair or poor.

Health Care Debt and Long-Term Costs

In June 2022, KFF released an analysis of the KFF Health Care Debt Survey, a companion report to the investigative journalism project on health care debt conducted by KFF Health News and NPR, Diagnosis Debt. This project found that health care debt is a wide-reaching problem in the United States and that 41% of U.S. adults currently have some type of debt due to medical or dental bills from their own or someone else’s care, including about a quarter of adults (24%) who say they have medical or dental bills that are past due or that they are unable to pay, and one in five (21%) who have bills they are paying off over time directly to a provider. One in six (17%) report debt owed to a bank, collection agency, or other lender from loans taken out to pay for medical or dental bills, while similar shares say they have health care debt from bills they put on a credit card and are paying off over time (17%). One in ten report debt owed to a family member or friend from money they borrowed to pay off medical or dental bills.

While four in ten U.S. adults have some type of health care debt, disproportionate shares of lower income adults, the uninsured, Black and Hispanic adults, women, and parents report current debt due to medical or dental bills.

Single bar chart showing the percent who say they have different types of debt due to medical or dental bills for themselves or someone else in their care.

Many U.S. adults may be one unexpected medical bill from falling into debt. About half of U.S. adults say they would not be able to pay an unexpected medical bill that came to $500 out of pocket. This includes one in five (19%) who would not be able to pay it at all, 5% who would borrow the money from a bank, payday lender, friends or family to cover the cost, and one in five (21%) who would incur credit card debt in order to pay the bill. Women, those with lower household incomes, Black and Hispanic adults are more likely than their counterparts to say they would be unable to afford this type of bill. (Source: KFF Health Care Debt Survey: Feb.-Mar. 2022)  

Split bar chart showing how adults would handle an unexpected medical bill of 0, if they'd be able to pay the bill without going into debt, go into debt to pay the bill, or would not be able to pay the bill.

Among older adults, the costs of long-term care and support services are also a concern. Almost six in ten (57%) adults 65 and older say they are at least “somewhat anxious” about affording the cost of a nursing home or assisted living facility if they needed it, and half say they feel anxious about being able to afford support services such as paid nurses or aides. These concerns also loom large among those between the ages of 50 and 64, with more than seven in ten saying they feel anxious about affording residential care (73%) and care from paid nurses or aides (72%) if they were to need these services. See The Affordability of Long-Term Care and Support Services: Findings from a KFF Survey for a deeper dive into concerns about the affordability of nursing homes and support services.

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, requires 44 states (including DC) to condition Medicaid eligibility for adults in the Affordable Care Act (ACA) Medicaid expansion group and certain enrollees in 1115 waiver programs 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). In June 2026, CMS released a list of states with 1115 waiver programs that include individuals who will be subject to work requirements. The list identifies waiver programs in three non-expansion states Georgia, Tennessee, and Wisconsin, as well as in five expansion states, Hawaii, Massachusetts, New York, Oregon, and Utah (Figure 1).  

ACA Medicaid Expansion Enrollees and Certain Medicaid Section 1115 Waiver Enrollees Will Be Required to Meet Work Requirements in 44 States. (Choropleth map)

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

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

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

Tracking Implementation of the 2025 Reconciliation Law Medicaid Work Requirements

Updated on:

KFF Resources on Medicaid Work Requirements

Work requirements overview:

Medical frailty exemption:

Implementation of work requirements:

50-state survey of Medicaid eligibility and enrollment policies:

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:

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:

CMS Guidance and Information

Operational and Implementation Questions

Table

The Business of Health with Chip Kahn

What Should Health Care Do About AI’s Lack of Guardrails?

September 29, 2026

Video

Audio

About this Episode


Episode 17, AI Series: In another concerning example of AI agents going rogue recently, an OpenAI agent hacked into an Australian government website containing health care data. While some industry CEOs are calling for a slowdown and demands for regulation grow, host Chip Kahn focuses on the implications for health care when these same kinds of AI systems are already at work in hospitals — in billing, in scheduling, and increasingly in decisions about patients. To consider how health care should respond, Chip talks with Stephen Klasko, a physician, former health system CEO, and now an industry leader who sits on both sides of the issues, working with the labs building the technology and focusing on patient care initiatives through his work at General Catalyst and as CEO of the Health Assurance Foundation. Klasko says there’s time to act and the answer isn’t a “pause.” Among his recommendations are creating a 9/11-style commission for AI in health, adding AI safety to health system board agendas, a 30-minute rule for tackling rogue agents, and giving frontline staff the authority to pull the plug.

The Host


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

Sr. Visiting Fellow

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

Guest


Chief Executive Officer, Health Assurance Foundation

Stephen K. Klasko, MD, MBA, is Chief Executive Officer (CEO) of the Health Assurance Foundation, a philanthropic platform affiliated with General Catalyst dedicated to accelerating the shift from “sick care” to health assurance. He previously served as Executive in Residence at General Catalyst, where his book UnHealthcare: A Manifesto for Health Assurance, co-authored with GC CEO Hemant Taneja, became the intellectual foundation for the firm’s health assurance investment strategy.

For nine years, Klasko served as president of Thomas Jefferson University and CEO of Jefferson Health in Philadelphia, transforming a $1.8 billion regional player into a $10 billion enterprise and the nation’s fastest-growing academic medical center. He has served as board chair of two public companies: Teleflex, a $7 billion medical-device company, and DocGo, a NASDAQ health company. He advises startups such as Hippocratic AI, Aidoc, and AmplifyMD.

Modern Healthcare previously ranked him No. 2 among its 100 Most Influential People in Healthcare, and in 2026 he was named to the Top 100 Most Influential People in HealthTech. Fast Company has named him one of its 100 Most Creative People in Business. His next book, Hitchhiker’s Guide to the Healthcare Galaxy, arrives in 2026.

He holds a BS from Lehigh University, an MD from Hahnemann University, and an MBA from the Wharton School.


SERIES

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

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