A Brookings Institution analysis accuses the Centers for Medicare & Medicaid Services (CMS) of using flawed, unjustified assumptions in its June 2026 Medicaid work requirements rule. While CMS predicts only 3.1 million to 3.3 million people will lose coverage and projects $350.3 billion in savings, Brookings researchers Sherry Glied and Richard Frank argue these figures contradict research. Meanwhile, over two dozen states are suing, and eight Republican-led states are enforcing stricter timelines.
Brookings critique of CMS assumptions
- ▪Brookings Institution researchers Sherry Glied and Richard Frank stated that the Centers for Medicare & Medicaid Services' assumption that 29% of affected beneficiaries will move into qualifying activities is more than six times larger than any estimate in existing research.
- ▪A Brookings Institution report by Sherry Glied and Richard Frank accused the Centers for Medicare & Medicaid Services of using "complete random assumptions" without justification in its Medicaid work requirements rule.
Medicaid work requirements rule
- ▪A Republican-led reconciliation bill passed in summer 2025 created a national mandate requiring approximately 21 million Affordable Care Act expansion Medicaid beneficiaries to work, volunteer, or attend school for 80 hours a month starting in 2027.
- ▪The Centers for Medicare & Medicaid Services released a rule in June 2026 that created high hurdles for sick beneficiaries to prove they are exempt from the Medicaid work mandate.
CMS enrollment projections
- ▪The Centers for Medicare & Medicaid Services predicted that only 3.1 million to 3.3 million people will lose Medicaid coverage over the next decade due to the work requirements rule.
- ▪The Congressional Budget Office forecasted in October 2025 that approximately 5.7 million people will lose Medicaid coverage by 2034 due to the work requirements policy.
Federal savings estimates
- ▪The Centers for Medicare & Medicaid Services projected that the federal government will save $350.3 billion over the next decade from the Medicaid work requirements rule, which is 10% higher than the Congressional Budget Office's estimate.
- ▪Brookings Institution researcher Sherry Glied argued that the Centers for Medicare & Medicaid Services' high savings projections are inconsistent with its low disenrollment estimates, as administrative disenrollment typically affects healthier, lower-cost beneficiaries.
State enforcement variations
- ▪At least eight Republican-led states are bypassing a one-year grace period and requiring Medicaid beneficiaries to prove exemption eligibility earlier than the federal rule mandates.
- ▪More than two dozen states filed a lawsuit against the Trump administration over the June 2026 Medicaid work requirements rule, arguing it is less flexible than prior guidance.
Trump administration data manipulation
- ▪The Trump administration has faced criticism from researchers for twisting or ignoring scientific and health policy data to support political goals, including in a summer 2026 Department of Health and Human Services report on Medicaid work requirements.
- ▪Trump administration Medicaid Director Dan Brillman defended the June 2026 rule as a commonsense implementation of the work requirements, asserting that exempt individuals can easily prove their status.
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