Implementation of Medicaid Immigrant Eligibility Restrictions Under the 2025 Reconciliation Law: Issues to Consider Authors: Akash Pillai, Alisha Rao, and Samantha Artiga Published: Sep 22, 2026

https://www.kff.org/immigrant-health/implementation-of-medicaid-immigrant-eligibility-restrictions-under-the-2025-reconciliation-law-issues-to-consider/?utm_medium=email&_hsenc=p2ANqtz-_MxAZyLTTXepqdVRV6pmWl5Xpr3a-VlMxfDV5pI5BgdxRKixGaj1r2oapT0p2s42ZHo6D0w-T_Rq8ijuphvY4I_uxInQ&_hsmi=440229550&utm_content=440229550&utm_source=hs_email KFF Examines Implementation of New Medicaid Immigrant Eligibility Restrictions A new KFF brief examines how states will implement new Medicaid and Children’s Health Insurance Program (CHIP) eligibility restrictions for lawfully present immigrants under the 2025 reconciliation law and based on CMS guidance. The changes take effect October 1. The law limits federally funded Medicaid and CHIP eligibility to certain groups of lawfully present immigrants, including lawful permanent residents (LPRs or green card holders), Cuban and Haitian entrants, people residing in the U.S. under Compacts of Free Association, and, in states that elect the option, lawfully residing children and pregnant immigrants. Many other lawfully present immigrants, including refugees and asylees without green cards, will lose eligibility. Undocumented immigrants are already ineligible for federally funded coverage in Medicaid and CHIP. The Congressional Budget Office estimates the changes will reduce federal spending by $6.2 billion and result in 100,000 more people becoming uninsured by 2034. States will face increased administrative burden to conduct outreach, reverify potentially affected enrollees, and update systems and other materials to reflect new immigrant eligibility rules starting October 1. While states first must attempt to verify immigration status through existing data, individuals may be asked to provide additional documentation. Even people still eligible for Medicaid or CHIP may experience procedural disenrollments or coverage disruptions due to fear, confusion, or challenges completing verification requirements, underlining the importance of adequate state outreach and assistance to enrollees, including linguistically accessible materials. A KFF review of 16 states’ notices to potentially affected enrollees finds considerable variation in the information they provide, including the extent to which they advise enrollees about other potential