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What CDC's 2024 HIV Monitoring Data Shows, and What the Next Survey May Miss

11 minutes ago
6 min read

On September 10, 2026, the Centers for Disease Control & Prevention (CDC) published the 2024 cycle of its Medical Monitoring Project (MMP), which CDC calls "the only source of locally and nationally representative information" on what affects treatment success among U.S. adults with HIV. Data collection ran from June 2024 through May 2025 and closed about five weeks before H.R. 1 became law. That makes it the last full look at people living with HIV (PLWH) before H.R. 1's changes to Medicaid and food assistance, though its final months overlapped with the first federal disruptions to HIV programs.

MMP interviewed 3,784 people and weights their answers to represent adults with diagnosed HIV nationwide. Their care runs through public programs: an estimated 50.8% had Medicaid in the past year and 47.4% received help from the Ryan White HIV/AIDS Program. Both programs now face new rules and proposed cuts. So does the survey that measures them.

Read the Numbers Carefully

MMP reports 62.4% of adults virally suppressed at their most recent test, against 68.5% in the National HIV Surveillance System (NHSS) data behind our May analysis "The Last Clean Snapshot." Both count people with no viral load result as not suppressed, but MMP checks only each person's main HIV care facility. In the 2022 cycle MMP ran above NHSS (67.2% to 65%), so the six-point gap is new.

Compared with the 2023 cycle, documented prescriptions for antiretroviral therapy (ART) fell from 82.9% to 79.6% and sustained suppression from 62.3% to 58.7%, while self-reported ART use was 95.4%, against 94.5% a year earlier. CDC counts anyone with no medical record abstraction as having no documented prescription, and by our calculation the number of respondents with no retention-in-care result rose from 126 to 209. That pattern fits missing records better than declining health, though CDC ran no statistical tests and the public tables cannot settle it. The timing fits too, though the link is our inference: KFF Health News reported that the surveys' grants "ended while [CDC's HIV researchers] were on administrative leave in May" 2025, the month collection closed. CDC's most recent published protocol tracks completed record abstractions by project area. CDC should publish those counts.

The Conditions Around Treatment Did Not Improve

An estimated 21.5% of adults with diagnosed HIV experienced hunger or food insecurity, up from a series low of 15.7% in the 2021 cycle. The 2022-2025 National HIV/AIDS Strategy (NHAS) set 2025 targets for six measures drawn from MMP: HIV stigma and five quality-of-life indicators. Only one moved measurably toward its goal:

Indicator

NHAS baseline (year)

2024

2025 target

Good or better self-rated health

71.5% (2018)

69.7%

95%

Unmet need for mental health services

24.2% (2017)

23.6%

12%

Unstable housing or homelessness

21.0% (2018)

19.8%

11%

Unemployment

14.9% (2017)

14.9%

7%

Hunger or food insecurity

21.1% (2017)

21.5%

11%

Median stigma score (0-100 scale)

31.2 (2018)

28.8

16

Stigma improved, all of it by the 2020 cycle, and remains far from its target. The comparison is ours, since NHAS is now archived. Among adults who needed them, 49.7% went without housing services and 39.5% without meal or food services. Sustained suppression reached 53.9% among Black adults compared with 61.5% among White adults.

Medicaid's Frailty Test and Well-Managed HIV

Disclosure: CANN signed the HIV Health Care Access Working Group's comment opposing this rule and asking the Centers for Medicare & Medicaid Services (CMS) to recognize HIV as a serious or complex condition without an impairment test.

H.R. 1 excludes from Medicaid's new work requirements anyone "who is medically frail or otherwise has special medical needs (as defined by the Secretary)," including people with a "serious or complex medical condition," a category the statute leaves without an impairment test. Using that definitional authority, CMS added one in its interim final rule, in effect since July 31. HIV/AIDS counts only when it "significantly impairs" the ability to comply, "which is less likely to be the case if the acuity of their condition is not severe." CMS wrote that it considered naming conditions such as HIV/AIDS and declined. KFF's assessment: "a blanket exclusion for people with HIV will not be possible."

The problem is circular. HIV stays well managed because people stay on treatment, and treatment depends on coverage. The requirement reaches adults covered through Medicaid expansion, which KFF finds covers 60% of adults under 65 with HIV in expansion states. PLWH whose HIV is under control and who fit no other exclusion must show 80 hours a month of work or other qualifying activity to keep the coverage that keeps it that way.

States will make the first cut through claims data and diagnosis-code lists. Under U.S. coding guidelines, anyone who has had an HIV-related illness is coded B20; HIV without symptoms or prior illness is coded Z21. Nebraska, which began enforcing on May 1, lists B20 but not Z21, so people coded Z21 must self-declare. CMS's September slide deckoffers one HIV example, B22.0, a World Health Organization code that does not exist in the U.S. code set. Twenty-three states and the District of Columbia are challenging the rule; a federal court hearing is set for October 20.

Funding is in play too. Congress held Ryan White and CDC HIV prevention level for FY2026 and raised Housing Opportunities for Persons With AIDS (HOPWA) to $529 million. For FY2027, the President's budget and the House Appropriations Committee's bill each remove $793.7 million, or 78%, from CDC's domestic HIV prevention line, leaving only the $220 million Ending the HIV Epidemic (EHE) initiative. The President would eliminate HOPWA, and the House committee, which keeps HOPWA level, would cut Ryan White by $224.9 million. Neither chamber has passed a bill, and a stopgap law holds FY2026 levels through December 11.

The Survey Absorbed the Same Disruptions

MMP's prior awards ended May 31, 2025, and CDC did not issue new ones until September 29, four months after the next planned cycle start. The gap may have cost a year of data. Virginia's health department told partners in June 2025 that "the CDC Medical Monitoring Project (MMP) has ended," then in October that its first grant year "will be used to recruit staff and re-establish the program." We found no evidence that a 2025 cycle, covering June 2025 through May 2026, was fielded anywhere. CDC's resource pages list a 2024 questionnaire and 2026-cycle calendars, and nothing for 2025. CDC has not said whether a year is missing.

CDC continued 21 project areas this summer; Florida shows no second-year award in federal spending data as of October 2, Chicago received no new award, and CDC's MMP page omits both. A July Federal Register notice proposes cutting the sample from 9,700 to 9,500 "[d]ue to a streamlining of operations in one state," which it does not name.

The questions changed too. Citing Executive Order 14168, CDC asked in a March 2025 request "to delete questions and response options that ask about gender," and approval came three weeks before collection closed. The 2022-cycle report counted transgender respondents; the 2023 and 2024 releases report only male and female.

The House funding bill names neither MMP nor National HIV Behavioral Surveillance (NHBS), though it expects its $220 million to cover "nationwide HIV surveillance." Current NHBS awards end December 31. CDC forecast the next funding notice for July 3 and has not posted it.

What Needs to Happen Before December 11 and January 1

The stopgap funding law expires December 11. January 1 is the federal deadline for states to begin Medicaid work requirements and the day after NHBS awards end.

Congress should fund CDC's domestic HIV prevention line at no less than FY2026's $1,013,712,000, Ryan White at no less than $2,571,041,000 including its $165 million EHE component, and HOPWA at no less than $529 million, and should name MMP and NHBS in report language.

CMS should amend its rule to treat diagnosed HIV as a serious or complex condition without an impairment test, correct its slide deck to U.S. codes B20 and Z21, and confirm that states may accept Ryan White and AIDS Drug Assistance Program enrollment, shared with consent, as verification.

States should list both B20 and Z21, accept self-attestation at every verification through December 31, 2027, as the rule allows, and end no one's coverage before January 1.

CDC should publish completed record abstractions by project area, say whether a 2025 cycle was fielded, release the gender identity data it collected before the questions were dropped, and post the NHBS funding notice or extend current awards.

Measure What We Fund

Ending the HIV Epidemic aims to reduce new HIV transmissions "by at least 90 percent by 2030." CDC's summary of this release says "more can be done to broaden the reach of HIV prevention programs and services." The FY2027 proposals would narrow that reach, and the survey that could show the effect has an apparent gap covering the year H.R. 1 became law. We cannot close gaps we stop measuring.

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