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National Health Law Program

Health-access litigation, policy advocacy and legal-aid support

Research time: 24 min on GPT-6 Astra Light
  • Research — reviewed programs, finances and impact evidence.

Updated: 2026-09-14

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Summary

What do they do? National Health Law Program protects access to care through litigation, policy analysis and support for legal-aid advocates. A current national opportunity is preserving meaningful medical-frailty exemptions as statutory Medicaid work requirements are implemented. Our weak-confidence best estimate is about $8.9 million per 10 USA QALYs; policy influence and marginal capacity—not filings—drive the result.

Why we’re interested in this organization:

  • National implementation changes can preserve effective care for many people.

  • A current amicus and detailed external enrollment model identify a concrete, narrower policy difference.

  • Randomized Medicaid evidence supplies a health bridge; current audits reveal full recipient costs.

Our main reservations:

  • Neither NHeLP's incremental policy influence nor its funding additionality is measured.

  • Enrollment forecasts are not uninsured person-years; replacement coverage and effective access need discounts.

  • Existing grants and reserves weaken demonstrated next-dollar urgency; zero and adverse health remain possible.

What do you get for your dollar? $8.9M per better life: ten additional quality-adjusted life years in USA. Medicaid-rule health only; policy effect modeled.

Additional Medicaid enrollment, then genuinely additional insured person-years with effective access; finite QALY utility differences. Filings, fiscal transfers and legal wins are not health units.

1. What do they do?

NHeLP's national strategy combines litigation, regulatory analysis and state partnerships. It also works on disability services, reproductive health, eligibility and California access. All recipient functions remain charged. Its September 2026 amicus supports state plaintiffs challenging medical-frailty and self-attestation restrictions. Being an amicus differs from leading the states' lawsuit, and neither establishes new-donation impact.

2. Monitoring and information sharing

Manatt's original forecast projects 1.9 million more Medicaid enrollment losses under strict implementation than its statute-only scenario in each of 2028 and 2029. It assumes 40% versus 30% disenrollment among affected people, informed by earlier state experience. This is a forecast, not an experiment on the new rule. We halve the difference for forecast/remedy uncertainty and halve it again for enrollment that genuinely prevents uninsurance. Track effective coverage-person-years, not filings or the entire enrollment population.

The forecast describes enrollment at a point within each year, not integrated insured person-years. Our central calculation assumes that difference persists for a full benefit year; a half-year average reduces modeled health by half. Replacement coverage and the scope a legal remedy could actually change are discounted separately.

3. Qualitative assessment

The CMS announcement confirms statutory work requirements and public implementation support. The opportunity modeled is narrower administration and enforcement, not repeal. States and other counsel continue without NHeLP, and existing work is not caused by future donations.

The Oregon experiment analysis maps the self-rated health difference at approximately one year to about .05 utility units; early physical-health and mortality effects were not statistically significant. We assume a .02 utility gain sustained for each credited insured year, allowing different patients, provider access and mapping uncertainty. Depression, mortality and financial protection are not added again. Rights and financial relief also have value outside this health measure.

4. What do you get for your dollar?

Three years at the latest recipient cost yields a modeled 2,206 discounted, attributable insured person-years and about 44 USA QALYs over two benefit years: roughly $8.9 million per 10 QALYs. Favorable assumptions yield about $53,000; very weak influence and access about $218 billion. These are judgment scenarios, not confidence limits.

Central policy attribution is .1 incremental coalition probability/intensity improvement multiplied by .1 NHeLP share, followed by .25 funding additionality. These deliberately modest but subjective values recognize specialist capacity alongside strong substitutes. This is not the cost of a single brief. Other portfolio health is set net zero, not proven absent or a rigorous lower bound.

Public treatment expenditures and displaced uses of government resources are outside the recipient numerator. Insurance can finance previously uncompensated care as well as induce new treatment, so this is not a full social cost-effectiveness estimate.

Model, assumptions and sensitivity

Three years of all recipient programs/support at FY2025 audited resource cost including donated legal labor. One national implementation pathway quantified; other portfolio net health set zero, not a proven lower bound. Public treatment and wider social costs excluded.

50-state/DC resident beneficiaries only; no headquarters share or California-only allocation. Immigration status does not exclude resident health. Territorial/foreign spillovers not counted.

A=sum(t=start..start+T−1)1/(1+discount)^t; V=N*r*u*A; H=V*q; Q_all=b*(p*a*H−h); Q_USA=g*Q_all; Cost=C*Y; Price10=10*Cost/Q_USA if positive. Central start=2,T=2. Local marginal rate assumes proportional capacity adjusted by b.

C
13035827 USD annual recipient resources (observed). Full audited expense, all functions and recognized donated professional services; original review reused from CA worker. [audit25]
Y
3 funding years (judgment). Three-year capacity cohort, not a priced brief; constant latest expense.
N
1900000 annual Medicaid enrollment difference (observed). Published forecast, not realized outcome: Figure 1 2028 8.6m−6.7m and 2029 8.8m−6.9m; visually verified rounded values. Point-in-year forecast treated as sustained for a full year; this is a temporal approximation, not an observed person-year integral. [nhelp-manatt]
r
0.5 realized/remediable share of forecast (judgment). Half allows forecast error, narrower remedy and incomplete state implementation. [nhelp-manatt] [nhelp-amicus]
u
0.5 share genuinely preventing uninsurance (judgment). Half allows other public/private insurance and enrollment-accounting differences. Effective health among newly insured is separately q. [oregon]
q
0.02 QALYs per additional insured year (judgment). .02 transfer below Oregon's .05 self-rated mapping. No separate mortality, depression or financial benefit added. Assumes the utility improvement persists throughout each credited insured year. [oregon]
p
0.1 incremental coalition probability/intensity improvement (judgment). Ten percentage points from further coalition work over three years beyond baseline public action; not overall litigation success probability. [nhelp-prepare] [nhelp-cms]
a
0.1 NHeLP share of coalition effect (judgment). Ten percent recognizes co-authorship and national expertise; 90% remains with states, other counsel and organizations. Not 1/71 arithmetic or filing credit. [nhelp-amicus] [cases]
b
0.25 marginal capacity additionality (judgment). Quarter allows grants, reserves and other donors; local linearity could fail and zero is possible. [audit25] [careers]
start
2 first benefit year (judgment). Year two approximately 2028, allowing preparation lag; no first-year credit.
T
2 benefit years (judgment). Two years approximately 2028–29 then paths reconverge; no perpetual entitlement credit.
discount
0.03 annual discount fraction (judgment). 3% applied by health event year; no remaining-life multiplication.
g
1 resident share of modeled population (judgment). Population explicitly defined as resident beneficiaries in 50 states/DC; no foreign or territorial spillovers. [nhelp-manatt]
h
0 other net health harm before b (judgment). Net zero for unpriced portfolio and public-resource displacement, not established zero; adverse sensitivities independent of p*a.

Weak-confidence national implementation estimate: Cost: $39.1M; USA QALYs: 44.12126725156421; all-population QALYs: 44.12126725156421. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.02,"p":0.1,"a":0.1,"b":0.25,"start":2,"T":2,"discount":0.03,"g":1,"h":0}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=17648.50690062568.

Broader sustained effect: Cost: $39.1M; USA QALYs: 7405.326138414443; all-population QALYs: 7405.326138414443. {"C":13035827,"Y":3,"N":1900000,"r":1,"u":0.8,"q":0.05,"p":0.3,"a":0.15,"b":0.6,"start":2,"T":4,"discount":0.03,"g":1,"h":0}; A=3.608833400786766; conditional discounted insured person-years=5485426.7691958845; conditional QALYs=274271.33845979423.

Very weak influence and access: Cost: $39.1M; USA QALYs: 0.0017909322273541334; all-population QALYs: 0.0017909322273541334. {"C":13035827,"Y":3,"N":1900000,"r":0.1,"u":0.2,"q":0.005,"p":0.02,"a":0.01,"b":0.05,"start":2,"T":1,"discount":0.03,"g":1,"h":0}; A=0.9425959091337544; conditional discounted insured person-years=35818.644547082666; conditional QALYs=179.09322273541332.

Use .05 health mapping: Cost: $39.1M; USA QALYs: 110.30316812891056; all-population QALYs: 110.30316812891056. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.05,"p":0.1,"a":0.1,"b":0.25,"start":2,"T":2,"discount":0.03,"g":1,"h":0}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=44121.26725156421.

Only 5% additional capacity: Cost: $39.1M; USA QALYs: 8.824253450312844; all-population QALYs: 8.824253450312844. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.02,"p":0.1,"a":0.1,"b":0.05,"start":2,"T":2,"discount":0.03,"g":1,"h":0}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=17648.50690062568.

No implementation change: Cost: $39.1M; USA QALYs: 0; all-population QALYs: 0. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.02,"p":0,"a":0.1,"b":0.25,"start":2,"T":2,"discount":0.03,"g":1,"h":0}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=17648.50690062568.

No additional health from coverage: Cost: $39.1M; USA QALYs: 0; all-population QALYs: 0. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0,"p":0.1,"a":0.1,"b":0.25,"start":2,"T":2,"discount":0.03,"g":1,"h":0}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=0.

Only substitute existing financing: Cost: $39.1M; USA QALYs: 0; all-population QALYs: 0. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.02,"p":0.1,"a":0.1,"b":0,"start":2,"T":2,"discount":0.03,"g":1,"h":0}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=17648.50690062568.

No policy benefit plus 50 QALYs harm: Cost: $39.1M; USA QALYs: -12.5; all-population QALYs: -12.5. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.02,"p":0,"a":0.1,"b":0.25,"start":2,"T":2,"discount":0.03,"g":1,"h":50}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=17648.50690062568.

200 QALYs other net harm: Cost: $39.1M; USA QALYs: -5.878732748435787; all-population QALYs: -5.878732748435787. {"C":13035827,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.02,"p":0.1,"a":0.1,"b":0.25,"start":2,"T":2,"discount":0.03,"g":1,"h":200}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=17648.50690062568.

Twofold future cost: Cost: $78.2M; USA QALYs: 44.12126725156421; all-population QALYs: 44.12126725156421. {"C":26071654,"Y":3,"N":1900000,"r":0.5,"u":0.5,"q":0.02,"p":0.1,"a":0.1,"b":0.25,"start":2,"T":2,"discount":0.03,"g":1,"h":0}; A=1.857737568486914; conditional discounted insured person-years=882425.3450312841; conditional QALYs=17648.50690062568.

Counterfactual: Existing state litigation, other amici, public administrators, grants and clinical care continue. Only further work's change in strict versus less restrictive administration counts, not repeal or all losses. r removes forecast/remedy overreach, u removes replacement coverage, b removes financial substitution.

Attribution: p=.1 incremental coalition contribution, a=.1 NHeLP share and b=.25 funding additionality are separate subjective factors. Current amicus and strategy show a live role but identify none of them. Existing work receives no automatic future-donation credit.

Weak-confidence best-estimate opinion, not measured return or statistical interval. Root may reject numeric acceptance if these judgments are insufficiently supported. Policy influence and funding additionality dominate; zero/harm explicitly retained.

Sensitivity

  • Conditional central H=17,648.51 QALYs; p*a=.01 and b=.25 reduce this to 44.12. Expected discounted attributable insured person-years are 2,206.06, not millions of observed recipients.
  • At other central inputs, p*a must exceed .088636 for $1 million per 10 USA QALYs, or .886364 for $100,000; central .01. These are requirements, not evidence of achievable influence.
  • Halving q or u doubles the price. A Medicaid enrollment forecast cannot replace genuinely additional insured person-years.
  • Other net harm above 176.485 QALYs over the three-year cohort erases central benefit before b; harm is not discounted by policy success probability.
  • The favorable four-year case is finite, not perpetual. Setting p, q or b to zero removes this pathway.
  • A social comparison needs public payer costs, uncompensated-care transfers, provider capacity and alternative government uses; recipient price does not include those.
  • If the point-in-year enrollment difference persists for only half of each modeled benefit year, health is halved and cost per 10 QALYs doubles. This temporal assumption is distinct from replacement coverage.

Unresolved inputs

  • Costed unfunded implementation plan and staffing/output response given current grants and reserves.
  • Case/administrative outcomes with and without incremental NHeLP capacity, separate from states and other counsel.
  • Actual state implementation, remedy scope, duration, uptake and alternative coverage.
  • Current beneficiary utility, public treatment/opportunity costs and other portfolio health/harms.

5. Funding and previous grants

Shared original-audit review verifies 2025 expenses of $13,035,827, including $339,667 donated professional services. Revenue was $20,349,524; unrestricted net assets $21,527,078 within $33,596,890 total. These balances do not identify an unfunded opportunity. The 25% marginal-capacity assumption allows existing grants, reserves and donor substitution.

Audited expenses were $11,023,768 in 2023, $11,725,264 in 2024 and $13,035,827 in 2025, averaging $11,928,286.33. 2024 audit with comparative Historical job advertisements are not current evidence of a cash bottleneck. A costed incremental implementation workplan and committed-grant restrictions are important beta inputs.

Annual expenses

Organization-level spending, including programs, administration and fundraising. The research list averages three comparable, consecutive full fiscal years when available.

  • FY 2023: $11.0M; National Health Law Program, Inc., 12-month period, GAAP accrual audited. Source
  • FY 2024: $11.7M; National Health Law Program, Inc., 12-month period, GAAP accrual audited. Source
  • FY 2025: $13.0M; National Health Law Program, Inc., 12-month period, GAAP accrual audited. Source

6. Sources

  1. 2025 audited financial statements. National Health Law Program. Published: not stated; retrieved: 2026-09-13.
  2. 2024 audited financial statements with 2023 comparative. National Health Law Program. Published: not stated; retrieved: 2026-09-13.
  3. Current original financial-document index. National Health Law Program. Published: not stated; retrieved: 2026-09-13.
  4. Strategic framework 2023–2027. National Health Law Program. Published: not stated; retrieved: 2026-09-13.
  5. Current litigation portfolio. National Health Law Program. Published: not stated; retrieved: 2026-09-13.
  6. The Value of Medicaid: Interpreting Results from the Oregon Health Insurance Experiment. Finkelstein, Hendren and Luttmer, Journal of Political Economy. Published: not stated; retrieved: 2026-09-13.
  7. Current job opportunities. National Health Law Program. Published: not stated; retrieved: 2026-09-13.
  8. Official donation route. National Health Law Program. Published: not stated; retrieved: 2026-09-13.
  9. National Medicaid implementation strategy. National Health Law Program. Published: not stated; retrieved: 2026-09-14.
  10. Medically-frail exemption amicus. NHeLP and co-amici. Published: 2026-09-10; retrieved: 2026-09-14.
  11. Work requirement IFR comments. National Health Law Program. Published: 2026-07-31; retrieved: 2026-09-14.
  12. Nationwide Medicaid work requirement framework. CMS. Published: 2026-06-01; retrieved: 2026-09-14.
  13. 50-state additional coverage-loss model, Figure 1 and methodology. Manatt Health / Boozang and colleagues. Published: 2026-07-16; retrieved: 2026-09-14.