Medicaid eligibility and enrollment in Utah

During the COVID pandemic, from March 2020 through March 2023, states were prohibited from disenrolling anyone from Medicaid. But this rule ended March 31, 2023 and states are once again disenrolling people who are no longer eligible for Medicaid, or who don’t respond to a renewal notification. States had a 12-month “unwinding” period during which they had to initiate eligibility redeterminations for everyone enrolled in the program.

Medicaid disenrollments resumed in May 2023 in Utah, and CHIP premiums began to be assessed starting in mid-2023, after being suspended during the pandemic.l¹³

223,241 people were disenrolled from Utah Medicaid during the year-long “unwinding” period. In most cases, the disenrollments were due to procedural reasons (meaning the state didn’t have enough information to determine whether they were still eligible).¹⁴

Medicaid enrollment in Utah had peaked at about 489,000 people in April 2023. By the end of the unwinding process, in the spring of 2024, it stood at about 340,000.¹⁴ It was still at roughly that same level a year later, in mid-2025.¹⁰

Many Medicare beneficiaries receive Medicaid’s help with paying for Medicare premiums, affording prescription drug costs, and covering expenses not covered by Medicare – such as long-term care.

Our guide to financial assistance for Medicare enrollees in Utah includes overviews of these benefits, including Medicare Savings Programs, long-term care coverage, and eligibility guidelines for assistance. Utah’s Medicaid 1115 waiver which was approved in 2019 (described above) provides dental benefits to Medicaid enrollees who are 65 or older.

No, Utah does not have a Medicaid work requirement as of 2025.

But the state is seeking federal approval to implement a work requirement for the Medicaid expansion population starting in mid-2026.⁷

Utah previously had federal permission for a Medicaid work requirement,⁵ which was briefly in effect in early 2020 before it was suspended due to the pandemic.

In 2021, CMS renewed Utah’s waiver, but only after the state removed the Medicaid work requirement.⁶ However, Utah is working to regain federal approval for a work requirement.

The federal “One Big Beautiful Bill,” enacted in 2025, requires states to have work requirements for the Medicaid expansion population by January 2027. Utah is among the states targeting an earlier effective date, and has asked CMS to approve a Medicaid work requirement with a July 2026 start date.⁷

Medicaid work requirements are controversial, as they ultimately result in people losing coverage no matter what (and most Medicaid enrollees who can work are already doing so). Work requirements in several other states had been overturned or pended due to lawsuits as of early 2020. Michigan and Utah were the only states where Medicaid work requirements were in effect as of early 2020, and both were soon suspended (Michigan’s was overturned by a judge in March) and not reimplemented. However, Georgia has since implemented a work requirement in conjunction with a partial expansion of Medicaid.

By 2018, Utah was in its fifth year of rejecting federal funding to expand Medicaid under the Affordable Care Act’s guidelines. But during the 2018 legislative session, Utah enacted H.B.472, which directed the state to submit an 1115 waiver proposal to CMS by January 1, 2019, requesting approval for Medicaid expansion in Utah, but only for people earning up to 95% of the federal poverty level (essentially 100%, after the 5% income disregard).

For perspective, the ACA calls for Medicaid expansion to adults with income up to 138% of the poverty level, so Utah lawmakers wanted to only cover part of that population. Their proposed solution did eliminate the coverage gap in the state, but continued to use private plans in the exchange for people with income over the poverty level.

In the waiver amendment that Utah submitted in June 2018 (to partially expand Medicaid), Utah asked the federal government to pay 90% of the cost (under the ACA, this is only available if a state expands Medicaid to individuals earning up to 138% of the poverty level), and allow Utah to impose a work requirement on some Medicaid enrollees. (As discussed below, the Trump administration rejected the state’s request to receive enhanced federal Medicaid funding without a full expansion of Medicaid.)

While lawmakers in Utah were considering a scaled-back version of Medicaid expansion, consumer advocates were working to gather enough signatures to get a Medicaid expansion initiative on the 2018 ballot in Utah. They were successful, and the Utah Medicaid Expansion Initiative passed with more than 53% support in the 2018 election. The Utah Medicaid expansion ballot initiative, which called for Medicaid to be expanded to households with income up to 138% of the poverty level — with no strings attached — garnered support from numerous groups in the state, including AARP Utah and the Utah chapter of the American Academy of Pediatrics.

The text of the ballot initiative called for Medicaid expansion in Utah to take effect as of April 1, 2019, and for Utah to raise the state sales tax by 0.15% (from 4.7% to 4.85%) to fund the state’s portion of the cost of Medicaid expansion.

Utah’s then-Governor, Gary Herbert, said that he would not block Medicaid expansion if the ballot measure passed — which it did — despite his opposition to the ballot initiative (this was in contrast with Maine’s former Governor LePage, who blocked Maine’s voter-approved Medicaid expansion ballot initiative for more than a year; it was eventually implemented when a new governor took over in 2019).

But just weeks after the 2018 election, GOP lawmakers in Utah intervened to stop the implementation of the Medicaid expansion that voters had approved, opting instead for a version of Medicaid expansion that would cover fewer people and cost the state more, at least in the first few years. S.B.96 was enacted in the 2019 legislative session, reiterating H.B.472’s call for Medicaid expansion only to those with income up to the poverty level.

S.B.96 was enacted in February 2019. The state’s Medicaid expansion ballot initiative had called for expansion to take effect by April 2019, which meant there was very little time to secure federal approval for the modifications the GOP lawmakers wanted to make to Utah’s version of Medicaid expansion.

But since the state already had a pending waiver proposal at CMS with very similar terms to those called for in S.B.96, CMS was able to grant a modified approval of that earlier proposal — albeit at the state’s regular federal funding match rate of about 68%, instead of the 90% federal funding rate that applies in states that have fully expanded Medicaid.

This meant that although the state would cover fewer people under the partial Medicaid expansion program (compared with how many would be covered under full expansion), it would be more expensive for the state.

The approval came in late March, just in time for the state to implement its limited Medicaid expansion on April 1, 2019. Utah residents with income up to the poverty level were able to begin applying for expanded Medicaid at that point.

In addition to partial Medicaid expansion, Utah’s approved waiver also allowed the state to impose a Medicaid work requirement starting in 2020 (this continued to be allowed under the full expansion waiver approval that was granted in late 2019, although the work requirement was suspended due to the COVID pandemic and approval was subsequently withdrawn by the Biden administration).

It was only when Utah fully expanded Medicaid, in January 2020, that the state began to receive the full 90% federal funding match for the Medicaid expansion population.

Although the federal government rejected Utah’s proposal to receive full federal funding for a partial Medicaid expansion, and also rejected the state’s proposal to allow people with income above the poverty level to have a choice between Medicaid and a subsidized plan in the exchange, Utah had already outlined contingency plans earlier in 2019.

The state submitted its “fallback plan” waiver proposal to CMS in November 2019, after accepting public comments earlier in the fall. The fallback plan called for expanding Medicaid eligibility in Utah to households with income up to 138% of the poverty level (ie, what voters approved in the 2018 election), but with a work requirement as well as a lock-out period for “intentional program violations,” premiums for enrollees with income above the poverty level, a ban on presumptive eligibility determinations under Medicaid expansion guidelines, and various other provisions.

CMS granted approval in December 2019, and the new Medicaid eligibility guidelines took effect in January 2020. The work requirement provision of the waiver proposal was approved and took effect in 2020, but it was suspended by April due to the COVID pandemic, and approval for it was later withdrawn by the Biden administration.

Utah had a contingency plan in case its work requirement was rejected. In that case, Utah’s final plan, if no waiver approval had been granted by July 1, 2020, was to simply implement Medicaid expansion as called for in the ACA (and in the state’s ballot initiative), without a waiver.

The state had created an at-a-glance chart that compared the details of the bridge plan, the per capita cap plan, the fallback plan and the regular expansion plan. The Utah Department of Health has also published a chart showing enrollment over time in both the partial expansion and the full expansion program.