Medicaid work requirement rule: Making a harmful law worse for people with HIV

When the “One, Big, Beautiful Bill Act” (H.R. 1) was signed into law in July 2025, HIVMA raised concerns that the Medicaid provisions in the law would put health care coverage at risk for hundreds of thousands of people with HIV. An interim final rule released June 1 by the Centers for Medicare and Medicaid Services outlining how states must implement H.R. 1’s Medicaid work requirements (referred to as the “community engagement” requirement in the legislation) heightens those concerns and increases fears about the consequences of our country’s eroding HIV response.

• The interim final rule makes a harmful law worse by disregarding H.R. 1’s exemption of certain populations, including those with a “serious or complex condition,” such as HIV or cancer, from the work requirements. Instead, the interim final rule goes further than the legislation by requiring an individual with a “serious or complex condition” to prove that their condition significantly impairs them from fulfilling the work or community engagement activities to qualify for an exemption. 
  
  
• The subjective assessment required for the exemption will increase administrative burdens on people with HIV and their providers and will be invasive, likely requiring the disclosure of personal health information for a disease that is still highly stigmatized. The additional strain on safety-net HIV clinics and clinicians whose patients disproportionately are covered by Medicaid comes at a time when HIV clinics and the workforce are already stretched thin as demand for their services grows due to spikes in health care costs.
  
  
• Forty percent of people with HIV in the U.S. are covered by the Medicaid program. In the 40 states and the District of Columbia that have expanded Medicaid, more than half (51%) of adults with HIV are covered through the expansion. Under the interim final rule, a large majority of them will, as of January 2027, be required to report, at least every six months, 80 hours of monthly work or volunteer activities to maintain the health coverage that is their lifeline to the care and treatment they need to stay healthy and be able to work. 
  
  
• The interim final rule will compromise the health of people with HIV and be costly to our health system. Without access to routine care and HIV treatment, people with HIV will develop serious infections as the virus rebounds and will be forced to turn to emergency rooms for treatment.  

In this era of highly effective HIV treatment that keeps people with HIV healthy and stops HIV transmission, we should be reducing barriers to health care for people with HIV rather than erecting them. We urge members of Congress to call on CMS to withdraw this rule that will devastate access to health coverage for low-income people with HIV and dramatically set back efforts to end the HIV epidemic in our country.

About HIVMA
The HIV Medicine Association is a community of nearly 6,000 health care professionals who advance a comprehensive and humane response to the HIV pandemic, informed by science and social justice. HIVMA works to increase access to health care services and coverage for people with HIV and populations heavily impacted by HIV and to foster a robust, diverse and culturally competent HIV workforce. HIVMA is part of the Infectious Diseases Society of America. Visit hivma.org to learn more.