by Carolyn Chu, MD, MSc, AAHIVS, AAHIVM Chief Medical Officer
April 7, 2026
Vyas DA, Mein SA, Tale AP, Wadhera RK. Functional Status of Adults at Risk of Medicaid Disenrollment Under National Work Requirements. Ann Intern Med. 2026 March 31. doi:10.7326/ANNALS-25-04811.
This study describes potential consequences of extending Medicaid work requirements nationally by estimating the number of working-age adults at risk of Medicaid disenrollment and measures of functional status and physical and mental health among at-risk beneficiaries. Using pooled data from the 2022-2023 Medical Expenditure Panel Survey, investigators examined primary outcomes of self-reported functional status measures across 3 domains: physical, neuropsychological, and independent living. The study population included adult Medicaid enrollees (19 to 64 years) who did not meet exemption criteria listed in H.R. 1, and the population at risk of disenrollment was defined as individuals who self-reported unemployment or working less than 20 hours/week. Out of 2,140 working-age Medicaid enrollees (representing a weighted population of 16,467,580), an estimated 50.4% would not meet work requirements if implemented nationwide and would be at risk of disenrollment. At-risk beneficiaries were significantly more likely to have incomes below 200% FPL, a high school education or less, and higher prevalence of several chronic conditions. Among at-risk beneficiaries, 33.5% reported an illness/disability that limited their ability to work, and severe physical impairment was nearly three times more common (neuropsychological impairment and limitations in independent living were also more prevalent). Among at-risk adults, 32.7% reported poor physical health and 28.2% reported poor mental health (12.3% reported both). In subgroup analyses, differences in functional impairment, poor physical health, and poor mental health were generally greater for men and older adults.
Author’s Commentary:
This analysis, which estimates that half of working-age Medicaid beneficiaries would be at risk of disenrollment due to not meeting work requirements if such requirements were extended throughout the U.S., highlights a critical need for states and policymakers to closely examine the “hidden burden” of functional impairment as they consider exemption criteria. A significant proportion of enrollees experience various health-related impairments and limitations which impact the ability to sustain work, yet do not qualify them for formal disability protections. Further, high levels of health-related burden and unmet needs among at-risk beneficiaries signal especially harsh consequences if Medicaid coverage is lost.
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