RWJF: Between 5M and 10M people could lose Medicaid coverage in 2028 under work requirements
By Paige Minemyer / March 25,2026
As many as 10 million people could lose Medicaid coverage in 2028 following the rollout of new work requirements established under H.R. 1, a new study shows.
Analysts at the Urban Institute, a left-leaning think tank, estimate that between 4.9 million and 10.1 million individuals would lose access to Medicaid, depending on how intensive eligibility checks ultimately become. The study estimates that between 2 million and 3.1 million will lose their Medicaid coverage because their eligibility would be checked more frequently, while between 3 million and 7 million would lose coverage due to the work requirements alone.
The report notes that states have significant leeway in how to implement work requirements, and categorized potential outcomes into three buckets: high, medium and low mitigation models. In the former, a state would establish broad data-matching capabilities for eligibility determinations and determining compliance with work requirements, taking more of the work off of individual enrollees.
In a low-mitigation set-up, by contrast, less of the administrative work would be automated, requiring more effort from individual enrollees, the researchers said.
While the report estimates that millions will lose Medicaid coverage regardless of model, the researchers project that states that choose low-mitigation options will see the largest enrollment drop-offs.
Work requirements have been implemented in a limited capacity to date, so making it a national policy will mark a substantial shift. In Arkansas, for example, individuals encountered significant barriers in complying with the requirements, including limited awareness of policy, confusion around notices and struggles in accessing and using online portals.
Studies into Arkansas' program found that 95% of people who would be subject to the work requirements were either eligible for an exemption or were already working the necessary number of hours. Research also did not find that the requirements led to an increase in employment.
Given these compliance barriers, the Urban Institute analysts estimate that between 19% and 37% of working people would lose their Medicaid coverage due to the compliance burden they would have to navigate.
Similarly, the researchers expect that individuals who meet exemptions, such as having a disability or being a family caregiver, may lose coverage due to the compliance requirements needed to remain eligible. Caregivers, students, the self-employed, people who work irregular schedules and those over age 50 are at a particularly high risk, per the study.
“Even in a best-case scenario, work requirements will cause millions of people to lose their Medicaid coverage, and if states do not implement the law with care, that number could double,” said Katherine Hempstead, senior policy adviser at the Robert Wood Johnson Foundation, which supported the research, in a press release. “Among the most affected will be older adults, the self-employed, and those with physical and mental health conditions.”