Health vs. Work Requirements
The cost of Marketplace insurance plans appears likely to increase again in 2027, based on reporting from Kaiser Family Foundation. They outline the impact that ACA insurance consumers are bearing to maintain coverage with the loss of enhanced premium tax credits (ePTC). From data collected in January 2026, over 21% of enrollees did not make their premium payments at the start of the year, a major increase from years prior. ACA enrollment is expected to drop down as low as 16.5 million people in 2026, from 22.3 million enrollees last year. We will know more about the impact of tax credit loss on ACA enrollment in the months ahead. The Center on Budget and Policy Priorities (CBPP) reported recently on the impacts to consumers from the loss of ePTCs. In the next decade, over 4 million people are expected to lose coverage from the loss of enhanced premium tax credits alone, with an additional 7.5 million expected to lose Medicaid coverage.
Work Requirements Take Shape in Medicaid Rules
On Monday, June 1st, the Centers for Medicare and Medicaid Services (CMS) are expected to announce their interim final rule on Medicaid work requirements. The rule will be posted to the Federal Register. This rule will designate the specific community engagement required of adults receiving healthcare under Medicaid expansion. The requirement mandates 80+ hours per month of community involvement or documented work activities of enrollees.
Some states, like Nebraska, have implemented work requirements ahead of the deadline outlined under HR 1. Under current legislation, states must implement work requirements by January 1, 2027. The Center on Budget and Policy Priorities has an interactive timeline you can use to view different scenarios for how the work requirements may roll out in different places.
Depending on how CMS and the current administration outline these requirements, states that adopted requirements early might need to refine their eligibility criteria. Issues like how medical frailty and substance abuse disorder are defined could create a challenge for some people with disabilities who should be exempt from work requirements. Many people with disabilities eligible for Medicaid are at risk of losing their health care under these rules and AAHD will continue to monitor and report on the implementation of these requirements.
People who have not had access to stable health insurance might have a harder time proving their need for medical exemption if they have been unable to get a diagnosis of their condition. Proving inability to work because of a medical condition is another layer of complexity for people with disabilities. Pay attention to the rules that come out next week, since this will have major implications for your Medicaid enrollees with disabilities and complex health conditions. We will share updates on the rules in our next newsletter on June 12th. Follow AAHD’s Policy Updates page for updates on the rule change in the coming week.
Previously, we had reported on the proposed Notice of Benefit and Payment Parameters (NBPP) rules. AAHD had submitted comments to CMS on these rules opposing the changes as we believe the proposals stood in opposition to the ACA’s goals of eligibility, affordability and access to coverage. CMS has now released the final NBPP with most of the proposed changes in effect. If you want to learn more about what is included in the changes, Health Affairs has released a series of explainer posts about the sweeping Marketplace changes:
- Part 1: Higher Bronze Deductibles And Expansion Of Catastrophic Plans
- Part 2: OBBBA Implementation, Eligibility Verification, And More
- Part 3: Essential Health Benefits, Non-Network Plans, And More
The NDNRC Newsletter is published biweekly through the summer. Archives of our weekly updates are available on the NDNRC website. Follow AAHD’s other newsletters to stay current on research opportunities and policy developments supporting people with disabilities. This newsletter is supported by the American Association on Health and Disability (AAHD). Sign up to become an AAHD member today to support ongoing projects like this.