Medicaid is the primary payer for long-term care (LTC) in the U.S. and pays for more than two-thirds of the LTC delivered in home- and community-based settings. Most home care (also known as “home- and community-based services” or HCBS) is optional for states to provide and is frequently offered through “waivers,” which allow states to cover a wide range of benefits and to choose—and limit—the number of people who receive services. KFF estimates that more than 5 million Medicaid enrollees use home care, and that about half of people are using home care through waivers. States’ ability to cap the number of people enrolled in home care waivers can result in waiting lists when the number of people seeking services exceeds the number of waiver slots available.

Passed last year, the 2025 reconciliation law made substantial changes to Medicaid that are expected to significantly reduce federal funding for Medicaid and lead to coverage loss for many current enrollees, placing new financial pressures on states, providers, and enrollees. Given the substantial share of Medicaid spending that pays for home care, and the optional nature of most home care programs, cuts to home care programs could occur as states respond to reduced federal spending. If states cut home care by reducing the number of people who can receive waiver services, waiting lists could increase. Proposals to cut home care may face challenges because people who rely on such services have complex health care needs and because elections may make it more difficult to restrict coverage. Recent tracking of programmatic changes to Medicaid home care highlights that some states have cut their programs, but in many cases, proposed cuts were not enacted, and other states continue to make enhancements.

Waiting lists could also increase because of changes to immigration policy in states that use waiting lists to manage shortages of home care workers. Three in 10 direct care workers are immigrants, and recent federal policy changes could further exacerbate the challenge of retaining and growing the workforce.

This data note provides new information about waiting lists in Medicaid home care before many of the provisions in the reconciliation law go into effect. Waiting lists are an incomplete measure of unmet need (Box 1) and are not necessarily comparable across states or over time. The data come from the 24^th KFF survey of officials administering Medicaid home care programs in all 50 states and the District of Columbia (hereafter referred to as a state), which states completed between April and August 2026. The survey was sent to each state official responsible for overseeing home care benefits (including home health, personal care, and waiver services for specific populations such as people with physical disabilities). All states except Florida and South Carolina responded to the 2026 survey. To facilitate comparisons over time, Florida’s responses to the 2022 survey and South Carolina’s responses to the 2025 survey were included with their permission. Survey findings are reported by state and waiver target population, although states often offer multiple waivers for a given target population. Key takeaways include:

• Forty states maintain waiting lists or interest lists for people who would like to receive home care, a number that fluctuated little between 2016 and 2026.
• In all years since 2016, there have been at least 0.5 million people on waiting lists or interest lists, with a total of almost 650,000 in 2026.
• In 2026, two states reported having at least one new waiting list (across three waivers), and 32 states reported an increase in the number of people on waiting lists or interest lists compared with only 7 states reporting a decrease.

• Most people on waiting lists or interest lists have intellectual or developmental disabilities (I/DD), and most live in states that do not screen any people for eligibility prior to adding them to waiting lists.
• Most people on waiting lists or interest lists are eligible for personal care provided through states’ regular Medicaid programs or for services provided through specialized state plan home care benefits.

KFF also recently updated the waiting list indicators on State Health Facts, which show data by state and target population.

How Many States Have Waiting Lists for Home Care?

Between 2016 and 2026, the number of states with waiting lists has fluctuated between 37 and 41 and is currently at 40 states (Figure 1). While some Affordable Care Act (ACA) opponents have cited waiver waiting lists to argue that expanding Medicaid diverts funds from adults ages 65+ and those with physical disabilities, research shows that ACA Medicaid expansion has led to gains in coverage for people with disabilities and chronic illnesses. Waiting lists for home care predate the ACA Medicaid expansion, which became effective in most states in 2014, and both expansion and non-expansion states have waiting lists. Waiver enrollment caps have existed since home care waiver authority was added to federal Medicaid law in the early 1980s.

While the overall number of states with waiting lists did not change much from 2025 to 2026, there were more changes in waiting lists for specific states and for specific types of waivers. Seven states (across eight waivers) removed waiting lists, including Nebraska, which no longer reported any waiting lists, and Oregon, which eliminated a waiting list of 1,000 people from its Section 1115 waiver for adults ages 65+ and those with physical disabilities. Two states (across three waivers) reported new waiting lists. Washington reported new waiting lists for people with I/DD (275 people) and adults ages 65+ and those with physical disabilities (waiting list size unknown), and Kentucky reported a new waiting list for individuals with traumatic brain or spinal cord injuries (5 people).

How Many People Are on Waiting Lists for Home Care?

Between 2025 and 2026, total enrollment in waiting lists and interest lists increased by about 7% and is almost 650,000 in 2026 (Figure 2). Overall, there was an increase in the number of people on waiting or interest lists in 32 states and a decrease in 7 states. One factor that contributes to changes over time is changes in states’ policies for managing their waiting lists. In 2026, several states changed their policies, but those changes did not result in any major increases or decreases in waiting lists. However, that has not been true in past years. For example, between 2018 and 2020, the total number of people on waiting lists decreased by 155,000, or 19%. Nearly half of that change came from Ohio’s implementation of a waiting list assessment of waiver eligibility, which reduced the size of the state’s waiting list by nearly 70,000 people. In 2026, most states (32) with waiting lists screen individuals for waiver eligibility for at least one waiver, but even among those states, four (California, Maryland, Mississippi, and Washington) do not screen for all waivers. The eight states that do not screen for eligibility among any waivers (Alaska, Florida, Iowa, New Mexico, Oklahoma, Oregon, South Carolina, and Texas) account for over half (56%) of all people on waiting lists.

In 2026 and earlier years, a disproportionate number of people on home care waiting lists or interest lists lived in states that did not screen people on waiting lists for eligibility. One reason waiting lists provide an incomplete picture of need is that not all people on waiting lists will be eligible for services. The number of states that do not screen for eligibility on any waiting lists ranged from six to eight states between 2022 and 2026, yet the share of individuals on waiting lists in these states ranged from 40% to 56%. Interviews about home care waiting lists found that when waiver services are provided on a first-come, first-served basis, people enroll in waiting lists in anticipation of future need. That study found that in some states, families would add their children to waiting lists for people with I/DD at a young age, assuming that by the time they reached the top of the waiting list, their children would have developed the immediate need for services. Many of those waivers offer comprehensive home care packages that include supported employment, supportive housing, or round-the-clock services. Among the eight states that do not screen people for eligibility on any lists, seven have only waiting lists and one has only interest lists.

Who Is on Waiting Lists for Home Care?

Most people on waiting lists have I/DD, particularly in states that do not screen for waiver eligibility before placing someone on a waiting list. People on waiting lists for waivers serving people with I/DD (which include waivers specific to people who have autism) make up 78% of waiting lists in states that do not screen for waiver eligibility, compared with 61% in states that do determine waiver eligibility before placing someone on a waiting list. People with I/DD make up almost three-quarters (72%) of the total waiver waiting list population (Figure 3). Adults ages 65+ and those with physical disabilities account for one-quarter (25%), while the remaining share (3%) includes children who are medically fragile or technology dependent, people with traumatic brain or spinal cord injuries, people with mental illness, and people with HIV/AIDS. People who are on home care waiting lists are generally not representative of the Medicaid population or the population that uses home care. Most people on waiting lists have I/DD, but KFF analysis shows that people with I/DD make up fewer than half of the people served through 1915(c) waivers (the largest source of Medicaid home care spending).

How Long Are People on Waiting Lists for Home Care?

In 2026, people on waiting or interest lists accessed services after an average of 34 months (35 of 40 states responding), up from 32 months in 2025. People with I/DD wait 38 months on average. The average waiting period for other waiver populations ranged from 8 months for waivers targeting medically fragile and technology-dependent children to 65 months for waivers that serve people with autism.

Most people on waiting or interest lists for whom living arrangements are known live in community settings while they wait. Among the 649,900 people on lists for waiver services in 2026, living arrangements are unknown for more than 425,000. Among the people whose living arrangements are known, 95% (213,800) live in the community and 5% (10,900) live in institutional settings. Although most people on waiting lists live in the community, that may not be true for all waivers. In one California waiver for adults ages 65+ and those with physical disabilities, nearly half of the 16,100 people on the waiting list are living in institutions.

While waiting for waiver services, people living in the community are likely to be eligible for other home care through Medicaid state plans. Of the more than 5 million people who use home care, KFF estimates that roughly half use services provided through the Medicaid state plan, such as personal care to help with bathing or preparing meals, therapies to help people regain or acquire independent living skills, and assistive technology. States may not use waiting lists to restrict the number of people eligible to use such services, and over 80% of people on home care waiting lists are eligible for personal care or other state plan services. They would not, however, have access to more specialized services such as supported employment or adult day care. People on waiting lists who receive state plan services may also have fewer hours of personal care than they would in a waiver program, or they may not have assistance with some of the activities they need help with, such as bathing, dressing, preparing meals, or managing medication.

The Centers for Medicare & Medicaid Services (CMS) has just released information about Medicare Part D plans for 2027, including plan availability and premiums for the coming year. The agency emphasized stability in the Part D prescription drug plan (PDP) marketplace for 2027 (as it did for 2026) and estimated only a modest $1 increase in the average monthly PDP premium from $35 to $36. KFF analysis of PDP availability and premiums for 2027 shows a mixed picture, with modest premium increases for many Part D enrollees for their current plan but steeper increases for others, and a reduction in the number of PDP options for the fourth year in a row. Key takeaways include:

• The number of stand-alone PDPs available to the average beneficiary will fall for the fourth year in a row, from 11 in 2026 to 9 in 2027. PDP availability in 2027 varies by state, ranging from 8 PDPs in 15 states to 12 PDPs in 1 state, the same range as in 2026 but with most states having 8 or 9 PDPs rather than 10 or more.
• Many PDP enrollees will see premium reductions or only modestly higher premiums in 2027 if they keep their current plan, but others will face substantially higher premiums. Enrollees in six of the eight PDPs that will continue to be offered on a national basis in 2027 will see premium reductions in some states if they keep their current plan, but enrollees in many other states will see higher premiums for these same plans if they don’t switch. Centene continues to offer the lowest-premium PDPs in 2027, with premiums for both Wellcare PDPs under $10 per month in many states, while enrollees in United’s AARP-branded PDPs will face substantially higher premiums and monthly increases of $50 or more in many states if they keep their current plan.
• There will be no zero premium PDPs available for Part D enrollees who do not receive low-income subsidies (LIS) in 2027. All 4 million PDP enrollees who paid no monthly premium in 2026 will face higher premiums in 2027 whether they keep their current plan or switch to a new PDP.
• With 56% of all Part D enrollees in Medicare Advantage drug plans in 2026, a majority of Part D enrollees will not be affected by PDP premium changes and may not face premium increases of any magnitude. Medicare Advantage plans can use rebate dollars from the federal government to reduce premiums for prescription drug coverage, funds that are not available to plan sponsors for PDPs.
• Ending the Part D Premium Stabilization Demonstration did not result in substantially higher across-the-board PDP premiums but still likely affected premium levels for 2027. The disappearance of zero premium PDPs for Part D enrollees without low-income subsidies and monthly premium increases greater than $50 for some PDP enrollees if they keep their current plan are possibly related to the termination of extra subsidies that were provided to PDP plan sponsors under the demonstration.

Findings

The number of stand-alone PDPs available to the average beneficiary will fall for the fourth year in a row, from 11 in 2026 to 9 in 2027, while the total number of stand-alone drug plans available will fall from 360 plans nationwide offered by 17 parent organization in 2026 to 316 plans offered by 15 parent organizations in 2027. The reduction in PDP offerings is largely due to two plan sponsors scaling back: Health Care Service Corporation is withdrawing the HealthSpring Extra Rx PDP from 22 regions, and CVS Health is withdrawing the Silverscript Choice PDP from 13 regions. Humana remains the only insurer offering three PDPs in all 34 PDP regions. PDP availability in 2027 varies by state, ranging from 8 PDPs in 15 states to 12 PDPs in 1 state (Figure 1) – the same range as in 2026 but with most states having 8 or 9 PDPs rather than 10 or more. Medicare Part D enrollees in almost all states will see a modest reduction in the number of PDPs for 2027, except Florida which is gaining 1 PDP and no change in 4 other states (Table 1).

Many PDP enrollees will see premium reductions or only modestly higher premiums in 2027 if they keep their current plan, but others will pay substantially higher premiums. Enrollees in six of the eight PDPs that will continue to be offered on a national basis in 2027 will see premium reductions in some states if they keep their current plan, but enrollees in many other states will see higher premiums for these same plans if they don’t switch (Figure 2).

Other takeaways from an initial analysis of 2027 PDP premiums and changes from 2026 include:

• There will be no $0 premium PDPs available for Part D enrollees who do not receive low-income subsidies (LIS) in 2027. According to KFF analysis, 28% of PDP enrollees without LIS, or 4 million PDP enrollees, paid no monthly premium in 2026. All these enrollees will face higher premiums in 2027 whether they keep their current plan or switch to a new PDP. This includes:
  • Humana Basic Rx PDP enrollees in 28 states, facing premium increases of $6.30 to $30.60 per month if they keep this plan;
  • Wellcare Value Script and Wellcare Classic enrollees in 16 states, facing monthly increases of $5.30 and $7.30 respectively;
  • HealthSpring Assurance Rx enrollees in 11 states, facing monthly increases of $9.30 to $14.70;
  • Humana Value Rx enrollees in 5 states, facing monthly increases of $17.20 to $22.30; and
  • AARP Medicare Rx Saver enrollees in 3 states, facing a monthly increase of $10.30.
• Centene continues to offer the lowest premium PDPs, with 2027 monthly premiums of $5.30 for Wellcare Value Script in 45 states and $7.30 for Wellcare Classic in 33 states. For the 5.9 million non-LIS enrollees in Wellcare Value Script in 2026, those in 29 states will see premium reductions in 2027 ranging from less than $1 to $17.50 if they keep their current plan, while those in another 22 states will see premium increases in 2027 ranging from less than $1 to $5.30.
• Enrollees in United’s AARP-branded PDPs will face substantially higher premiums in many states if they keep their current plan, with monthly premium increases of $50 or more in all 50 states and DC for AARP Medicare Rx Preferred (including 37 states with premium increases greater than $75 and 4 states with premium increases of more than $100) and increases of $50 or more in 33 states for AARP Medicare Rx Saver. Together, these plans enroll more than 2 million non-LIS enrollees in 2026. Switching to a less expensive PDP is an option in all areas, but KFF analysis shows that many enrollees don’t compare plans or switch during open enrollment.

With 56% of all Part D enrollees in Medicare Advantage drug plans in 2026, a majority of Part D enrollees will not be affected by PDP premium changes and may not face premium increases of any magnitude. According to CMS, the average Medicare Advantage drug plan premium for 2027 will continue to be considerably lower than the average monthly PDP premium, and it’s likely that most MA-PD enrollees will be in plans charging zero premium in 2027, as in 2026 and previous years. This is because Medicare Advantage plans can use rebate dollars from the federal government to reduce premiums for prescription drug coverage, funds that are not available to plan sponsors for PDPs.

Ending the Part D Premium Stabilization Demonstration did not result in substantially higher across-the-board PDP premiums but still likely affected premium levels for 2027. CMS’s decision to terminate the Part D Premium Stabilization Demonstration for 2027, rather than continue it for a third year as originally planned when the demonstration was announced, seemed to point in the direction of higher premiums for PDP coverage in 2027. The demonstration provided extra subsidies to PDP plan sponsors, and by extension PDP enrollees, in two ways – reducing the base beneficiary premium, which is used in the calculation of individual plan premiums, and capping the year-over-year increase in the monthly premium. CMS determined that the extra financial support provided to PDP sponsors under the demonstration was no longer needed after 2026, and in fact, across-the-board substantial PDP premium increases for 2027 didn’t materialize. However, the disappearance of zero premium PDPs for Part D enrollees without low-income subsidies is a possible outcome of the termination of the demonstration, and eliminating the cap on the year-over-year increase in the monthly PDP premium has meant that monthly premium increases greater than $50 are possible for some PDP enrollees if they keep their current plan.

Even if the monthly premium for a given Part D drug plan is decreasing or increasing only modestly, premiums are only one feature for beneficiaries to consider when evaluating their Part D coverage. As is commonly advised during open enrollment, Medicare beneficiaries may want to evaluate what other features of their Part D plan might be changing, including what drugs are and aren’t covered on the plan’s formulary, tier placement of covered drugs, deductibles, and cost-sharing requirements. With Part D costs overall on the rise, the tradeoff Part D enrollees might face as their premium increases are kept in check is that their coverage may be getting less generous, which could mean fewer drugs covered, higher cost-sharing requirements, or greater utilization management restrictions – or possibly a combination of all three.

Earlier this week, the Centers for Medicare and Medicaid Services (CMS) published information about the Medicare Advantage plans that will be available for the coming 2027 plan year. Starting October 1^st, insurers, brokers, and other third-party entities can market Medicare Advantage plans, and during the annual open enrollment period, which runs from October 15^th through December 7^th, Medicare beneficiaries can make changes to their Medicare coverage for the coming year. In a press release, CMS emphasized stability in the Medicare Advantage marketplace overall. This analysis explores Medicare Advantage plan availability for the average beneficiary and at the state level.

KFF’s analysis of plan offerings shows that, on average, Medicare beneficiaries will have the option of 28 Medicare Advantage prescription drug (MA-PD) plans in 2027, a decline from the 32 options available in 2026 (excluding employer plans and special needs plans not available for general enrollment). The number of MA-PD options grew steadily between 2010 and 2024, reaching a peak of 36 options for the average Medicare beneficiary in 2024. The number of options available for 2027 will be higher than the number available in 2021 (27) and every year before (Figure 1).

Across all Medicare Advantage plans for general enrollment, including those with and without prescription drug coverage, the average Medicare beneficiary can choose from among 35 plans in 2027, compared to 39 plans in 2026. Similar to the trend for MA-PDs, the total number of Medicare Advantage plans available to the average beneficiary is higher than the average number of plans available in every year between 2010 and 2021. While Medicare Advantage plans are required to cover all Medicare Part A and Part B benefits, plans decide whether to include Part D prescription drug coverage as part of the benefit package. Enrollees may pay a separate premium for Part D coverage, or plans can use the rebate portion of their payment from the federal government to cover these costs. Most Medicare Advantage enrollees are in plans that include prescription drug coverage and most pay no premium beyond the Part B premium.

The modest decrease in the number of Medicare Advantage plans available to the average beneficiary means that some Medicare beneficiaries will find that their current coverage is no longer an option for next year. In most cases, these beneficiaries live in counties where they will continue to have robust Medicare Advantage plan options available for 2027, as well as traditional Medicare. Some beneficiaries in plans that have exited the market will have the option to enroll in a plan offered by the same insurer, and in many cases, enrollees will be moved into a new plan offered by the same insurer automatically if the contract includes another plan of the same type (i.e., HMO or PPO) in the same county. Others will have to make an active choice about their Medicare coverage if they wish to enroll in another Medicare Advantage plan or will be automatically covered by traditional Medicare.

The number of Medicare Advantage plans with prescription drug coverage available to the average beneficiary varies across states (Figure 2). In 26 states and Puerto Rico, the average Medicare beneficiary has at least 20 MA-PD options in 2027, including 3 states (PA, MI, and OH), where the average beneficiary has at least 40 MA-PD options. In 9 states and DC, the average Medicare beneficiary has fewer than 10 MA-PD options in 2027. This includes Alaska, which has no plans available in 2027, as in 2026 (Alaska has historically had few or no Medicare Advantage plans available for general enrollment). Connecticut is not included in this calculation because of differences in how counties are reported across CMS enrollment and plan files.

Across most states, the average beneficiary will have fewer Medicare Advantage plan options in 2027 compared to 2026. The states with the largest drop in the number of MA-PDs available for general enrollment are Texas (-9), Illinois and Ohio (-8), and Minnesota, New Mexico, and Washington (-7). In nine states beneficiaries will have the same number of MA-PD options in 2027 as in 2026 (excludes Alaska where no MA-PDs are available in 2026 or 2027), and in four states beneficiaries will have more options (Figure 3).

Choosing how to receive Medicare benefits remains a challenge for Medicare beneficiaries. Beyond the number of plans available, every year there are changes to Medicare Advantage plan benefits and costs, including the scope and generosity of extra benefits, cost sharing for Medicare-covered benefits, out-of-pocket limits, rules for using covered services (such as referral requirements and prior authorization), drug formularies, and provider networks. (These data are released separately by CMS and a comprehensive analysis from KFF will follow.) Despite these changes, most Medicare beneficiaries report that they do not compare coverage options on an annual basis. Further, prior Medicare focus groups indicate that Medicare enrollees are often overwhelmed by the number of Medicare Advantage choices and have difficulty sorting through all plan options. With more than two dozen MA-PDs available in 2027, on average, and year-to-year changes in benefits and costs, understanding how plans differ and how these differences could affect costs and access remains a challenge for beneficiaries.

This updated chart collection uses federal labor data to compare jobs and wages in the health care sector with the rest of the economy. Health sector employment has grown steadily while job growth in other non-farm sectors has plateaued. Over the past year, the health sector added 378,500 jobs—a 2% increase—compared with 0.2% growth in non-health, non-farm employment. Health care wage growth has slowed slightly compared to other industries over the past three years.

Health care jobs now account for 11.6% of all non-farm jobs, up from 10.7% a decade ago. Since 1990, health sector employment has grown over three times as much as all other non-health, non-farm employment sectors, increasing most in outpatient settings (up 40% since August 2016.)

The chart collection is available on the Peterson-KFF Health System Tracker, an online information hub dedicated to monitoring and assessing the performance of the U.S. health system

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. 

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. 

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.

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.

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.

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.