Medicaid After Redeterminations: What Enrollment Looks Like Entering 2026

77 million Americans are enrolled in Medicaid and CHIP, with enrollment appearing relatively flat as we enter 2026. This is a welcome change after the Medicaid “unwinding” - when states resumed eligibility redeterminations after the pandemic-era continuous coverage requirement ended in April 2023. The increased burden on billing teams lasted until mid-2024, and in total they conducted more than 80 million eligibility reviews that had been frozen for three years. 25 million people were disenrolled while 56 million had their coverage renewed.

By comparison, the past year’s flat enrollment looks like stability returning to Medicaid after a long period of upheaval. But that appearance is deceiving. Major policy changes taking effect in late 2026 are likely to create the same kind of eligibility chaos as was seen during 2023-2024. And this time there is no clear end date - billing teams will have to deal with ongoing eligibility churn.

What's Coming in 2026-2027

Two dates will reshape Medicaid operations and affect billing teams' verification workload. Starting December 31, 2026, six-month redetermination cycles will replace the current 12-month standard, doubling the frequency of eligibility changes that billing teams must track. The next day, work requirements will kick in nationwide - where patients must demonstrate 80 hours monthly or face loss of coverage - creating a new category of coverage disruption that will hit some patients mid-treatment.

Medicaid enrollment is expected to decline sharply over the next two years as these policies take effect. The Congressional Budget Office projects work requirements alone will generate $326 billion in federal savings through millions of patients losing coverage - when those patients can’t pay, their bill will become bad debt or charity care on provider balance sheets.

States must launch outreach campaigns by mid-2026 to address these changes, yet most lack the systems to handle this scale of eligibility tracking and verification. This means billing teams will discover coverage gaps only at claim submission, just as they did in 2023 and 2024.

Operational Impact for Billing Teams

Shorter redetermination cycles and year-round terminations due to work requirements mean a heavier verification burden. Patient eligibility confirmed in January could be invalid by March once 6-month redetermination cycles take effect - with double the likelihood of this occurring under annual reviews. Work requirement noncompliance will trigger terminations year-round, creating coverage gaps that are harder to predict than the 2023-2024 disenrollment waves were. Meanwhile, MCO instability - such as UCare's Minnesota exit and Louisiana dropping UnitedHealthcare - will continue to contribute to the challenges providers face.

What Providers Should Do Now

Providers can't wait for the next wave of eligibility disruption to hit. We recommend that they:

• Start building systems now to re-verify Medicaid patients on shorter cycles before claims go out. Catching coverage gaps early prevents the denials that compressed redetermination cycles will create, as well as churn due to work requirements.
• Keep close tabs on MCO changes in your markets, as MCO exits are reshuffling plan codes and prior authorization requirements faster than before.

Nirvana tracks these policy developments so your team has the full picture  - because staying ahead of coverage changes is how you protect both patient trust and revenue.