Come October 1, immigrants seeking Medicaid benefits – including lawful immigrants – will face a new array of eligibility criteria and requirements.

KFF has presented a broad look at those new criteria, ushered in as a result of last year’s federal budget reconciliation bill – also known as H.R. 1 and the One Big Beautiful Act Bill –  and how they are expected to be implemented.

The major aspects of the coming changes are (all quoted directly from the KFF review):

• States must redetermine eligibility for all “potentially affected” existing Medicaid enrollees under the new rules by October 1, 2026, and conduct new eligibility determinations consistent with the new rules beginning October 1, 2026.
• For potentially affected enrollees, states must first attempt to reverify satisfactory immigration status under the new rules through existing information and automated data matches before contacting the enrollee.
• If the state is unable to verify satisfactory immigration status through existing information and data matches, it must request additional information from the enrollee and give the enrollee a reasonable period of time to respond.
• States must update eligibility systems and financial claiming and enrollment data reporting to be consistent with the new eligibility rules.

The major challenges both the states and immigrant applicants, again quoted directly from KFF, are:

• Individuals no longer eligible for Medicaid under the new rules will be disenrolled from coverage and left with limited comprehensive coverage options.
• Individuals who remain eligible for Medicaid may experience procedural disenrollments or coverage disruptions due to fear, confusion, or challenges completing verification requirements.
• Adequate and accessible outreach, information, and assistance will be key for preventing potential administrative coverage losses.
• Comprehensive information on notices provided to enrollees about Medicaid immigrant eligibility changes is not publicly available across states, but KFF analysis of notices collected from 16 states illustrates there is variation in the information they provide and their accessibility.
• States will face increased administrative burden to conduct outreach, reverify enrollees, and update systems and other materials to reflect new immigrant eligibility rules amid implementation of other Medicaid changes included in the 2025 reconciliation law.
• States have limited federal guidance to implement the new eligibility rules among certain groups of noncitizens.
• States may face additional uncertainties due to a lack of CMS guidance.

The implications of the possible loss of Medicaid eligibility for some immigrants poses a particular challenge for community safety-net hospitals because so many of those hospitals serve communities with both large numbers of immigrants and large numbers of low-income residents.  Whether they are insured or not, such individuals will continue turning to community safety-net hospitals and those mission-driven hospitals will continue serving them – raising the prospect of new, greater uncompensated care obligations.

Learn much more about the details underlying all of these concepts and their implications for immigrants and state Medicaid programs in the comprehensive KFF report “Implementation of Medicaid Immigrant Eligibility Restrictions Under the 2025 Reconciliation Law: Issues to Consider.”