Changes to Medicaid Eligibility for Immigrants
Medicaid provides comprehensive health and long-term care coverage to over 81 million low-income individuals in the United States. Administered by states with federal oversight, eligibility traditionally requires U.S. Citizenship or qualified immigration status. Recent legislation and administrative actions are altering these requirements, impacting access to care for many lawfully present immigrants.
Federal Restrictions on Immigrant Eligibility
Federal rules currently limit Medicaid and the Children’s Health Insurance Program (CHIP) eligibility to U.S. Citizens and certain lawfully present immigrants. Undocumented immigrants are not eligible for federally funded coverage, including Medicare and the Affordable Care Act (ACA) Marketplaces. Lawfully present immigrants generally must have a “qualified non-citizen” status and, in many cases, wait five years after obtaining that status before enrolling in Medicaid or CHIP [1].
Refugees and asylees are exempt from the five-year waiting period. However, those with temporary protected status do not have a qualified status and are ineligible for Medicaid and CHIP, even after five years. The Trump administration reversed Biden administration actions that had expanded ACA Marketplace coverage to Deferred Action for Childhood Arrivals (DACA) recipients, rendering them once again ineligible for Marketplace coverage as of August 25, 2025 [2].
The 2025 Reconciliation Law and Further Restrictions
The 2025 reconciliation law, enacted on July 4, 2025, introduces further restrictions to immigrant eligibility for Medicaid and CHIP, effective October 1, 2026. Eligibility will be limited to lawful permanent residents (LPRs), Cuban and Haitian entrants, residents of the Freely Associated Nations (Marshall Islands, Micronesia, and Palau), and lawfully residing children and pregnant immigrants in states that cover them under existing Medicaid or CHIP options [3].
These changes will eliminate eligibility for many other groups of lawfully present immigrants, including refugees and asylees without a green card.
Emergency Medicaid and the 2025 Reconciliation Law
Emergency Medicaid provides reimbursement to hospitals for emergency care delivered to individuals ineligible for Medicaid due to their immigration status. This program covers undocumented immigrants and lawfully present immigrants who otherwise meet Medicaid eligibility requirements but are excluded due to their immigration status. Spending on Emergency Medicaid accounts for less than 1% of total Medicaid expenditures.
The 2025 reconciliation law will limit federal matching payments for Emergency Medicaid in states that have expanded Medicaid under the ACA. For individuals who would be eligible for expansion coverage except for their immigration status, federal matching payments will be reduced to the state’s regular Medicaid match rate, rather than the expansion rate of 90% [4].
Citizenship and Immigration Status Verification
States are required to verify citizenship and immigration status with the Social Security Administration (SSA) and the Department of Homeland Security (DHS) during the initial Medicaid application process. U.S. Citizens must provide documentation of citizenship, while non-citizens must demonstrate a qualified immigration status. Verification is typically conducted through the DHS Systematic Alien Verification for Entitlements (SAVE) system.
Applicants are granted a “reasonable opportunity period” of 90 days to provide additional documentation if their immigration status cannot be verified in real-time. Federal matching funds are available for services provided during this period. If an applicant is determined ineligible, eligibility must be terminated within 30 days, and the applicant has the right to a fair hearing.
Reverification Requirements
States are sometimes required to reverify immigration status during annual redetermination of eligibility. The 2025 reconciliation law mandates that states conduct eligibility redeterminations at least every six months for Medicaid expansion adults, starting December 31, 2026.
In August 2025, the Centers for Medicare & Medicaid Services (CMS) announced a new initiative requiring states to reverify the citizenship and immigration status of certain Medicaid enrollees using T-MSIS enrollment data and the SAVE system. States must reverify the status of individuals flagged by CMS and disenroll those who cannot verify a satisfactory status. This process may increase administrative burdens and potentially lead to coverage lapses for eligible individuals.
CMS will require states to report on these redeterminations and may issue disallowances or deferrals of federal matching funds if states cannot verify an enrollee’s satisfactory immigration status.