Georgetown tracks 2.56 million fewer children in public coverage since January 2025, and employer plans must honor 60-day requests
Medicaid and Children's Health Insurance Program (CHIP) enrollment among children fell by 2.56 million between January 2025 and August 2026, according to Georgetown University's Center for Children and Families (CCF). The figure is a net decline in enrollment, not a count of children who lost coverage and became eligible for an employer plan.
For employer plans, the relevant rule is older than the numbers. A group health plan must allow an employee or dependent who is otherwise eligible to enroll if the request comes within 60 days after Medicaid or CHIP coverage ends, according to the Department of Labor's guidance on special enrollment rights. The 60-day window covers losing Medicaid or CHIP eligibility. Most other special enrollment events carry a 30-day window.
What the 60-day right requires
The right applies regardless of when a plan's open enrollment falls. Coverage should begin no later than the first day of the month after the plan receives a timely request, according to benefits adviser Lawley. The Children's Health Insurance Program Reauthorization Act of 2009 also created notice obligations, and plan documents should describe the additional special enrollment rights, Lawley noted. The Department of Labor publishes a model notice.
In July 2023, the Departments of Labor, Health and Human Services and the Treasury encouraged plan sponsors to extend the window for people losing Medicaid or CHIP, though the request did not require it, according to The Horton Group.
Why requests could increase
Georgetown said in February that it is unlikely many of the children leaving Medicaid have moved to affordable employer-sponsored dependent coverage, because the cost of that coverage continues to rise. Workers with employer family coverage pay an average of $7,471 a year toward premiums in 2026, up 9 percent from 2025, according to KFF's Employer Health Benefits Survey. HRD America reported that ACA subsidy expiration pushes workers toward employer health plans, and that employee affordability concerns add to employers' benefits dilemma.
More change is scheduled. States must condition Medicaid expansion eligibility on work requirements by January 1, 2027, according to KFF, and Manatt Health notes that six-month redeterminations for expansion adults begin by the same date. The Congressional Budget Office has projected that 3 million fewer children will be covered by Medicaid between 2026 and 2036, according to Georgetown.
Those provisions apply to expansion adults rather than children, so any effect on dependents would be indirect.
Three items are worth confirming. The plan's special enrollment notice should list loss of Medicaid or CHIP eligibility as a trigger with the 60-day window. Plan administrators, including third-party administrators, should be able to process a request received at any point in the year. Employers with large Medicaid-exposed workforces can also tell employees the window exists, since a worker who does not know about it may let it close.
