Behind the Estimated National Loss of Coverage for Nearly 5.6 Million CHC Patients, Impact of Medicaid Work Requirements at the State Level


June 10, 2025

Data Note Placeholder Image

Data Note

June 2025

Kay Johnson, Maddie Krips, Feygele Jacobs

The budget reconciliation bill, as passed in the U.S. House of Representatives on May 22, conditions Medicaid eligibility on work for adults whose coverage is based on the Affordable Care Act (ACA) Medicaid expansion (i.e., for low-income adults 19 to 64). To enroll or maintain continuous enrollment in Medicaid, these adults must demonstrate that they either fulfill the work requirements or qualify for an exemption, for example by caring for children or disabled family members or having a serious health condition. Documenting compliance with work or exemption status will require frequent and potentially complex reporting; community health center (CHC) patients would be less likely to benefit from automated systems, and largely reliant on manual reporting. Our earlier analysis estimates that up to 72% of working-age adult CHC Medicaid patients in expansion statesor 5.6 million peopleare at risk of losing coverage, whether or not they work or qualify for an exemption.

Due to differences in states’ Medicaid income eligibility levels as well as center capacity, the proportion of working-age adult CHC patients who are covered by Medicaid varies considerably by state.

  • Across expansion states, the proportion of working- age adult CHC patients covered by Medicaid was 53%, compared to 25% in the non-expansion states (2023).
  • The percentage of adult CHC patients covered by Medicaid ranged from 72% in California to 15% in South Dakota and Wyoming.

While the impact of work requirements on CHCs and their patients will vary significantly by state, all expansion states will be affected.

In two states (CA and OR) with large numbers of Medicaid-covered adults and millions cared for by health centers, about half of all CHC working-age adult patients could be expected to lose Medicaid coverage. Overall, in seven states, at least 40% of adult CHC a patients would lose coverage.

Major impacts will be felt in smaller as well as larger states. Of the total number of adult CHC patients, Medicaid coverage would be lost by approximately:

  • 1 in 3 in AZ, CO, DE, IA, KY, MD, MN, MO, NJ, NM; and VA;
  • 1 in 4 in AK, AR, ID, MT, NV, and WV; and
  • 1 in 5 in ME, NE, NH, and VT.

 

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