End Notes
[1] A manager’s amendment considered during the House Rules Committee made changes to the House reconciliation legislation as reported by the House Budget Committee. See Amendment to Rules Committee Print 119-3 Offered by Mr. Arrington of Texas, May 21, 2025, https://amendments-rules.house.gov/amendments/RCP_119-3_Managers_xml%20(002)250521201648156.pdf.
[2] Based on a Congressional Budget Office (CBO) score of an earlier version of the House bill that does not include the more draconian changes made before final passage, this includes at least $716 billion in cuts to Medicaid. CBO, “Estimated Budgetary Effects of a Bill to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14, the One Big Beautiful Bill Act As Ordered Reported by the House Committee on the Budget May 18, 2025,” May 20, 2025, https://www.cbo.gov/publication/61420.
[3] People without a documented immigration status are already ineligible for coverage through these programs.
[4] CBO May 20, 2025.
[5] Laura Harker, “Pain but No Gain: Arkansas’ Failed Work-Reporting Requirements Should Not Be a Model,” CBPP, August 8, 2023, https://www.cbpp.org/research/health/pain-but-no-gain-arkansas-failed-medicaid-work-reporting-requirements-should-not-be; Matt Fiedler, “How would implementing an Arkansas-style work requirement affect Medicaid enrollment?” Center on Health Policy at Brookings, April 30, 2025, https://www.brookings.edu/articles/how-would-implementing-an-arkansas-style-work-requirement-affect-medicaid-enrollment/.
[6] Gideon Lukens and Elizabeth Zhang, “Harsh Work Requirements in House Republican Bill Would Take Away Medicaid Coverage From Millions: State and Congressional District Estimates,” CBPP, May 13, 2025, https://www.cbpp.org/research/health/harsh-work-requirements-in-house-republican-bill-would-take-away-medicaid-coverage.
[7] Streamlining Medicaid; Medicare Savings Program Eligibility Determination and Enrollment, 88 Fed. Reg. 65230, September 21, 2023, https://www.govinfo.gov/content/pkg/FR-2023-09-21/pdf/2023-20382.pdf.
[8] Streamlining the Medicaid, Children’s Health Insurance, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes, 89 Fed. Reg. 22780, April 2, 2024, https://www.govinfo.gov/content/pkg/FR-2024-04-02/pdf/2024-06566.pdf.
[9] CBO May 20, 2025.
[10] Jennifer Wagner, “Setting the Record Straight on the Medicaid Eligibility and Enrollment Rules,” CBPP, January 21, 2025, https://www.cbpp.org/blog/setting-the-record-straight-on-the-medicaid-eligibility-and-enrollment-rules.
[11] See “Reducing Churn Keeps Eligible Families Connected,” in Jennifer Wagner, “Medicaid Ex Parte Renewals Are an Efficient Strategy to Ensure Eligible Enrollees Have Health Care, Increase Accuracy, and Reduce Administrative Costs,” CBPP, February 25, 2025, https://www.cbpp.org/blog/medicaid-ex-parte-renewals-are-an-efficient-strategy-to-ensure-eligible-enrollees-have-health; Jennifer Wagner and Judith Solomon, “Continuous Eligibility Keeps People Insured and Reduces Costs,” CBPP, May 4, 2021, https://www.cbpp.org/research/health/continuous-eligibility-keeps-people-insured-and-reduces-costs.
[12] CBO May 20, 2025. This cut also is likely to increase once CBO updates its estimate to reflect that more frequent redeterminations will start earlier than proposed (December 31, 2026, rather than October 1, 2027) in the version of the legislation that CBO scored.
[13] In state-based marketplaces, 73 percent of re-enrollments were completed through automatic re-enrollment in 2025, compared to 46 percent of re-enrollments in states with the federally facilitated marketplace. Centers for Medicare & Medicaid Services (CMS), “2025 Marketplace Open Enrollment Period Public Use Files,” updated May 12, 2025, https://www.cms.gov/data-research/statistics-trends-reports/marketplace-products/2025-marketplace-open-enrollment-period-public-use-files.
[14] Claire Heyison, “Republican Proposals Would Raise Taxes for Enrollees in Affordable Care Act Marketplaces,” CBPP, February 7, 2025, https://www.cbpp.org/blog/republican-proposals-would-raise-taxes-for-enrollees-in-affordable-care-act-marketplaces
[15] CMS, “CMS Announcement on Federal Navigator Program Funding,” February 14, 2025, https://www.cms.gov/newsroom/press-releases/cms-announcement-federal-navigator-program-funding.
[16] Jennifer Wagner, “More Frequent Medicaid Renewals Would Increase Errors and Lead Eligible People to Lose Health Coverage,” CBPP, May 12, 2025, https://www.cbpp.org/blog/more-frequent-medicaid-renewals-would-increase-errors-and-lead-eligible-people-to-lose-health.
[17] “US consumer confidence plunges in April,” Reuters, April 29, 2025, https://www.reuters.com/business/us-consumer-confidence-plunges-april-2025-04-29/.
[18] Medicaid enrollees cannot be charged cost-sharing for certain emergency services, family planning services and supplies, and pregnancy-related services. States can apply the 5 percent cap on cost-sharing on either a monthly or quarterly basis. A change in the text that the House Rules Committee adopted before House passage broadens exemptions to prevent cost-sharing for any primary care services, mental health care services, or substance use disorder services. One Big Beautiful Bill Act, Rules Committee Print 119-3, May 18, 2025, https://rules.house.gov/sites/evo-subsites/rules.house.gov/files/documents/rcp_119-3_final.pdf.
[19] CBO May 20, 2025.
[20] Madeline Guth, Meghana Ammula, and Elizabeth Hinton, “Understanding the Impact of Medicaid Premiums & Cost-Sharing: Updated Evidence from the Literature and Section 1115 Waivers,” KFF, September 9, 2021, https://www.kff.org/medicaid/issue-brief/understanding-the-impact-of-medicaid-premiums-cost-sharing-updated-evidence-from-the-literature-and-section-1115-waivers/; Samantha Artiga, Petry Ubri, and Julia Zur, “The Effects of Premiums and Cost Sharing on Low-Income Populations: Updated Review of Research Findings,” KFF, June 1, 2017, https://www.kff.org/medicaid/issue-brief/the-effects-of-premiums-and-cost-sharing-on-low-income-populations-updated-review-of-research-findings/.
[21] CMS, “2025 Marketplace Open Enrollment Period Public Use Files,” updated May 12, 2025, https://www.cms.gov/data-research/statistics-trends-reports/marketplace-products/2025-marketplace-open-enrollment-period-public-use-files.
[22] U.S. Department of the Treasury, “Affordable Care Act Marketplace Coverage for the Self-Employed and Small Business Owners,” September 20, 2024, https://home.treasury.gov/news/press-releases/jy2608.
[23] CBO, Response to Letter from Ranking Member Pallone, Neal, and Wyden, May 11, 2025, https://democrats-energycommerce.house.gov/sites/evo-subsites/democrats-energycommerce.house.gov/files/evo-media-document/cbo-emails-re-e%26c-reconcilation-scores-may-11%2C-2025.pdf.
[24] Gideon Lukens and Elizabeth Zhang, “Premium Tax Credit Improvements Must Be Extended to Prevent Steep Rise in Health Care Costs,” CBPP, November 14, 2024, https://www.cbpp.org/research/health/premium-tax-credit-improvements-must-be-extended-to-prevent-steep-rise-in-health.
[25] Gideon Lukens and Elizabeth Zhang, “Proposed ACA Marketplace Rule Would Raise Health Care Costs for Millions of Families,” CBPP, April 1, 2025, https://www.cbpp.org/research/health/proposed-aca-marketplace-rule-would-raise-health-care-costs-for-millions-of.
[26] The House-passed legislation also stipulates that CSR payments may not be used for plans that include abortion coverage (other than “if necessary to save the life of the mother or if the pregnancy is a result of rape or incest”). This would have implications in the 12 states where plans are currently required by state law to include abortion coverage as well as in the 13 states that allow plans to include abortion coverage.
[27] CBO, “Re: Appropriation of Cost-Sharing Reduction Subsidies,” March 19, 2019, https://www.cbo.gov/system/files/115th-congress-2017-2018/reports/53664-costsharingreduction.pdf.
[28] National Immigration Law Center, “‘Lawfully Present’ Individuals Eligible Under the Affordable Care Act,” updated May 2024, https://www.nilc.org/wp-content/uploads/2015/11/Lawfully-Present-Individuals-Eligible-Under-ACA-2024.pdf.
[29] The Compacts of Free Association (COFA) allow citizens of Micronesia, the Marshall Islands, and Palau to live, work, and study in the U.S. as lawfully present noncitizens.
[30] People who are eligible for Medicare because of a disability, end-stage renal disease diagnosis, or amyotrophic lateral sclerosis (ALS) diagnosis may be able to get coverage despite having worked in the U.S. for fewer than 40 quarters.
[31] A 1996 law created the “qualified alien” immigration standard to be used in determining eligibility for Medicaid; a narrow list of immigration statuses are defined as “qualified,” and many people with “qualified alien” status are only eligible for Medicaid after they have had that status for five years.
[32]This group would otherwise meet the federal immigration-related eligibility requirement for federally funded Medicaid after a five-year waiting period, but for the purposes of this penalty, the House bill excludes them from the “qualified alien” standard, meaning that states would trigger the penalty if they continued to cover this group in Medicaid.
[33] The House-passed bill exempts states that have taken up this “lawfully residing” option (created by 2009 legislation) to provide coverage through Medicaid, but the bill language is unclear as to whether the penalty could still be levied on states that have taken up this option under CHIP.
[34] The earlier House Energy & Commerce Committee version of the bill would have severely penalized 14 states plus the District of Columbia that have created comprehensive health coverage programs, solely using their own state funds, for adults and children without a documented immigration status. The provision would have cut federal Medicaid funding in these states, forcing them to choose between cutting or dropping their state-funded programs for people who are undocumented and cutting enrollment, benefits, or provider payments in Medicaid. Gideon Lukens, Elizabeth Zhang, and Shelby Gonzales, “House Republican Bill Would Cut Medicaid Funding to States Providing Own Health Coverage to People Who Are Undocumented,” CBPP, updated May 19, 2025, https://www.cbpp.org/research/health/house-republican-bill-would-cut-medicaid-funding-to-states-providing-own-health.
[35] CBO May 20, 2025.
[36] The ACA outlines ten categories of Essential Health Benefits (EHB) (such as emergency care and mental health care) that insurance plans in the individual and small-group markets must cover, and states decide many of the details about specific health services within federal rules. Under the House provision, states would be able to require coverage of gender-affirming care in their insurance markets, but they would have to defray the costs that marketplace plans would incur by covering gender-affirming care. The provision affects most Medicaid expansion enrollees because the EHB forms the basis of what’s covered under alternative benefit plans that states frequently adopt for that group.
[37] David A. Klein, Scott L. Paradise, and Emily T. Goodwin, “Caring for Transgender and Gender-Diverse Persons: What Clinicians Should Know,” American Family Physician, Vol. 98, No. 11, December 2018, https://www.aafp.org/pubs/afp/issues/2018/1201/p645.html.
[38] Planned Parenthood Federation of America, “The Irreplaceable Role of Planned Parenthood Health Centers,” April 2024, https://www.plannedparenthood.org/uploads/filer_public/44/fd/44fdb4f0-33c2-4993-8087-3e862183c1de/2024-irreplaceable-role-factsheet.pdf.