End Notes
[1] Last year’s reconciliation law (Public Law 119-21) adds unprecedented red tape to the expansion that will make it harder for people to enroll and stay enrolled in Medicaid. Beginning in 2027, applicants will have to meet a work requirement by documenting that they are working (or participating in another qualifying activity) at least 80 hours a month or that they have an allowable exemption. Expansion enrollees will also have to prove their eligibility every six months to stay covered, instead of annually. These two provisions will cause some 6 million people to become uninsured (not accounting for interactions between the provisions), according to the Congressional Budget Office, with many people who should be eligible being denied coverage due to administrative burdens. CBPP, “By the Numbers: Harmful Republican Megabill Will Take Health Coverage Away From Millions of People and Raise Families’ Costs,” updated August 27, 2025, https://www.cbpp.org/research/health/by-the-numbers-harmful-republican-megabill-will-take-health-coverage-away-from.
[2] These estimates do not incorporate the impact of the work requirement provision in the reconciliation law. The work requirement impacts eligibility for the small subset of people in the expansion population who do not work or engage in other qualifying activities for the requisite hours, or who do not meet standards for an exemption. But the bulk of the work requirement’s coverage losses will likely come from the additional red tape it imposes. Many of those who will be denied coverage should in fact be eligible because they are working or meet an exemption, but they will get caught up in the administrative burden of documenting eligibility.
[3] Laura Harker and Breanna Sharer, “Medicaid Expansion: Frequently Asked Questions,” CBPP, updated June 14, 2024, https://www.cbpp.org/research/health/medicaid-expansion-frequently-asked-questions-0; Gideon Lukens and Laura Harker, “Closing Medicaid Coverage Gap Would Help Diverse Groups and Reduce Inequities,” CBPP, updated July 15, 2024, https://www.cbpp.org/research/health/closing-medicaid-coverage-gap-would-help-diverse-groups-and-reduce-inequities.
[4] Specifically, the Republican reconciliation law places additional restrictions on provider taxes and state-directed payments for expansion states compared to non-expansion states. For more detail, see Edwin Park and Sabrina Corlette, “Medicaid, CHIP, and Affordable Care Act Marketplace Cuts and Other Health Provisions in the Budget Reconciliation Law, Explained,” Georgetown University Center for Children and Families, July 22, 2025, https://ccf.georgetown.edu/2025/07/22/medicaid-chip-and-affordable-care-act-marketplace-cuts-and-other-health-provisions-in-the-budget-reconciliation-law-explained/.
[5] Bryce Ward, “The Impact of Medicaid Expansion on States’ Budgets,” The Commonwealth Fund, May 5, 2020, https://www.commonwealthfund.org/publications/issue-briefs/2020/may/impact-medicaid-expansion-states-budgets.
[6] Meghana Ammula and Madeline Guth, “What Does the Recent Literature Say About Medicaid Expansion?: Economic Impacts of Providers,” KFF, January 18, 2023, https://www.kff.org/affordable-care-act/what-does-the-recent-literature-say-about-medicaid-expansion-economic-impacts-on-providers/.
[7] Emmaline Keesee et al., “Uncompensated Care is Highest for Rural Hospitals, Particularly in Non-Expansion States,” Medical Care Research and Review, November 18, 2023, https://journals.sagepub.com/doi/10.1177/10775587231211366; American Hospital Association, “Medicaid Coverage Supports Rural Patients, Hospitals, and Communities,” June 5, 2025, https://www.aha.org/fact-sheets/2025-06-05-medicaid-coverage-supports-rural-patients-hospitals-and-communities.
[8] Although it is a non-expansion state, Wisconsin extends Medicaid eligibility to adults up to 100 percent of the poverty level through a waiver. Therefore, Wisconsin has no coverage gap population.
[9] KFF, “Medicaid Income Eligibility Limits for Adults as a Percent of the Federal Poverty Level,” https://www.kff.org/affordable-care-act/state-indicator/medicaid-income-eligibility-limits-for-adults-as-a-percent-of-the-federal-poverty-level.
[10] Some may be ineligible for premium tax credits because they have an offer of employer-sponsored coverage that is considered affordable. However, this number is likely small because many people working in low-paying occupations do not have an offer of employer-sponsored coverage through their job. KFF, “2025 Employer Health Benefits Survey,” October 22, 2025, https://www.kff.org/health-costs/2025-employer-health-benefits-survey/.
[11] Nicole Rapfogel, “People With Low Incomes May Lose $0 Premium Plans — a Lifeline — Unless Congress Acts,” CBPP, September 29, 2025, https://www.cbpp.org/blog/people-with-low-incomes-may-lose-0-premium-plans-a-lifeline-unless-congress-acts.
[12] Centers for Medicare & Medicaid Services, “2025 Marketplace Open Enrollment Period Public Use Files,” May 2, 2025, https://www.cms.gov/data-research/statistics-trends-reports/marketplace-products/2025-marketplace-open-enrollment-period-public-use-files.
[13] Matthew Buettgens et al., “4.8 Million People Will Lose coverage in 2026 If Enhanced Premium Tax Credits Expire,” Urban Institute, September 17, 2025, https://www.urban.org/research/publication/48-million-people-will-lose-coverage-2026-if-enhanced-premium-tax-credits.
[14] Starting October 1, 2028, the Republican reconciliation law requires states to charge Medicaid expansion enrollees with incomes over 100 percent of poverty new cost-sharing fees of up to $35 for many health care services. However, individual charges could be much lower, and total out-of-pocket costs remain capped at 5 percent of family income. For many people, those costs would likely still fall below total out-of-pocket costs in marketplace plans with the highest tier of cost-sharing reductions. These plans have an average maximum out-of-pocket limit of almost $2,000 for an individual. For an analysis of the Medicaid cost-sharing provision, see Jennifer Tolbert and Priya Chidambaram, “Cost Sharing Requirements Could Have Implications for Medicaid Expansion Enrollees With Higher Health Care Needs,” KFF, June 27, 2025, https://www.kff.org/medicaid/cost-sharing-requirements-could-have-implications-for-medicaid-expansion-enrollees-with-higher-health-care-needs/. For a chart on cost-sharing features of marketplace plans, see Jennifer Sullivan, “How to Evaluate Proposals to Address Expiring Premium Tax Credit Enhancements,” CBPP, December 4, 2025, https://www.cbpp.org/blog/how-to-evaluate-proposals-to-address-expiring-premium-tax-credit-enhancements.
[15] Although it is a non-expansion state, Wisconsin extends Medicaid eligibility to adults up to 100 percent of the poverty level through a waiver. Therefore, Wisconsin has no coverage gap population. And while Georgia provides Medicaid to certain low-income adults who meet work requirements through a waiver program, enrollment was only 15,000 after over two years — well below the 240,000 uninsured people estimated to be eligible. Therefore, we do not consider eligibility for this program in our estimates of the coverage gap. Georgia Pathways, Data Tracker enrollment as of February 28, 2026, https://www.georgiapathways.org/data-tracker.
[16] KFF, “Kaiser Family Foundation ACA Eligibility Analysis, Technical Appendix B: Immigration Status Imputation,” October 2015, https://files.kff.org/attachment/technical-appendix-b-new-estimates-of-eligibility-for-aca-coverage-among-the-uninsured.
[17] Center for Migration Studies, “Estimates of Undocumented and Eligible-to-Naturalize Populations by State,” http://data.cmsny.org/state.html; Bryan Baker and Robert Warren, “Estimates of the Unauthorized Immigrant Population Residing in the United States: January 2018–January 2022,” U.S. Department of Homeland Security, April 2024, https://ohss.dhs.gov/sites/default/files/2024-06/2024_0418_ohss_estimates-of-the-unauthorized-immigrant-population-residing-in-the-united-states-january-2018%25E2%2580%2593january-2022.pdf
[18] Missouri Census Data Center, “Geocorr 2022: Geographic Correspondence Engine,” version 1.8, revised October 2022, https://mcdc.missouri.edu/applications/geocorr2022.html. We use geographic crosswalks of 2020 population and consider any area outside of a metropolitan statistical area to be rural.