A new report released Thursday warns that upcoming changes to Medicaid work eligibility requirements could reverse recent gains in reducing opioid-related overdose deaths in Massachusetts. The report highlights concerns that a significant portion of adults with opioid use disorder enrolled in MassHealth may face difficulties maintaining their insurance coverage under the new federal work rules.

The report estimates that about 55 percent of Massachusetts adults with opioid use disorder currently enrolled in MassHealth—approximately 33,647 residents—will need to meet new federal work requirements mandated by the One Big Beautiful Bill Act (OBBBA) starting in January 2027. While the act provides exemptions for individuals deemed medically frail, including those with substance use disorders actively engaged in treatment, the report cautions that many affected individuals could struggle to navigate the administrative process needed to prove eligibility for these exemptions.

Overdose deaths statewide have declined for three straight years, with fatalities dropping below 1,000 in 2025 for the first time in more than a decade. This marks a significant improvement from the record high of 2,364 overdose deaths in 2022. However, the report warns that bureaucratic barriers could hinder people with opioid use disorder from securing timely exemptions, potentially resulting in loss of coverage.

Currently, states are allowed to accept self-attestation to verify exemptions and work requirements, a policy set to continue through 2027. Beginning in 2028, stricter verification procedures will be implemented, which may increase the risk of coverage lapses. Despite MassHealth’s efforts to maintain enrollment and automate eligibility verification, the report suggests many individuals with opioid use disorder could nonetheless “fall through the cracks.”

Losing MassHealth coverage could have serious consequences, as many people rely on medications for opioid use disorder (MOUD) to manage their condition. The report highlights that interruptions in treatment due to loss of insurance could raise the risk of overdose and death. Because the policy changes will take effect in 2027 and verification processes tighten in 2028, the report anticipates that any resulting increases in overdose fatalities may not be evident in state data until 2028 or later.

In summary, the report raises concerns that the new Medicaid work requirements may unintentionally jeopardize the health and safety of thousands of Massachusetts residents with opioid use disorder by creating barriers to continuous treatment and care.