Medicaid Policy Explainer: Implications for Refugee and Immigrant Communities

Under new federal law set to take effect on October 1, 2026, hundreds of thousands of lawfully present immigrants will lose access to federally funded health coverage. These changes arise from H.R. 1 (Public Law: 119-21), also known as the One Big Beautiful Bill Act, which was signed into law on July 4, 2025. The law restricts eligibility for Medicaid, the Children’s Health Insurance Program (CHIP), and coverage through the Affordable Care Act (ACA) marketplaces. USCRI has previously reported on the scope of these changes for lawfully present noncitizens who have historically had access to federally funded assistance programs.

This explainer provides an overview of the historical framework governing immigrant access to Medicaid, the changes resulting from the 2025 legislation, and the health care coverage options that remain available, including Refugee Medical Assistance (RMA) for certain eligible populations.

How We Got Here

Since enactment of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, federal law has linked public-benefit eligibility to immigration status. Most lawfully present immigrants must wait five years after obtaining a qualifying status before enrolling in federal programs such as Medicaid. ^[1]

Congress, however, exempted individuals admitted on humanitarian grounds from this waiting period and subsequently added other eligible categories. These categories include refugees admitted through the U.S. Refugee Admissions Program, individuals granted asylum, certified survivors of human trafficking, Cuban and Haitian entrants, Amerasian immigrants, and Afghan and Iraqi nationals admitted on Special Immigrant Visas (SIVs) who supported U.S. combat operations. Individuals in these groups could enroll upon obtaining a status that qualified them for Medicaid.

This exemption reflected the practical circumstances of humanitarian populations, whose arrival is generally determined by government processes rather than individual choice. Many arrive after experiencing persecution, torture, or exploitation and many have untreated medical conditions, limited resources, no employer-sponsored coverage, and little or no family support in the United States to fall back on. A five-year waiting period could therefore leave serious health needs unaddressed during the same period in which individuals are expected to secure employment and establish financial stability. Immediate health coverage was accordingly recognized as an important foundation for achieving one of the resettlement program’s central objectives: self-sufficiency as quickly as possible.

Changes Under H.R. 1

Effective October 1, 2026, the categories of immigration status that qualify for federally funded Medicaid and CHIP will be narrowed. As a result, many individuals admitted on humanitarian grounds will no longer qualify for federally funded, full Medicaid benefits on the basis of those statuses.

Individuals who will remain eligible include U.S. citizens, lawful permanent residents (LPRs), Cuban/Haitian entrants, and nationals of countries covered by the Compacts of Free Association (COFA): the Republic of Palau, the Federated States of Micronesia, and the Republic of the Marshall Islands.

Some affected individuals may remain eligible through another Medicaid pathway. For example, refugees and asylees who have adjusted to lawful permanent resident status, and Afghan and Iraqi SIV recipients, who are admitted as LPRs, may qualify under the rules applicable to LPRs. In addition, states that have adopted the Children’s Health Insurance Program Reauthorization Act of 2009 (Public Law 111-3) Section 214 option may continue to provide federally funded Medicaid or CHIP coverage to certain lawfully residing children and pregnant individuals.

Individuals who will become newly ineligible include refugees, individuals granted asylum, individuals granted humanitarian parole for at least one year, including Afghan and Ukrainian parolees, survivors of human trafficking, and certain survivors of domestic violence.

Importantly, the law withdraws federal funding for coverage but does not prohibit states from providing it. States may therefore continue to cover these populations with state funds, and some are expected to do so. Emergency Medicaid also remains unchanged and is available, regardless of immigration status, to individuals who satisfy their state’s other Medicaid eligibility requirements and require treatment for a qualifying emergency medical condition, including life-threatening or acute medical emergencies, and childbirth.

H.R. 1 also changes eligibility for coverage through health insurance marketplaces, where consumers can compare and enroll in health plans offered under the Affordable Care Act. As of 2026, lawfully present noncitizens with incomes below 100% of the federal poverty level who are barred from Medicaid because of their status are no longer eligible for premium tax credits to enroll in coverage. Beginning in 2027, the newly ineligible immigrant groups identified above will also lose access to the subsidies that have made marketplace coverage affordable. As a result, many immigrant families may have no affordable coverage option.

Refugee Medical Assistance (RMA) is a related but distinct program administered by the Office of Refugee Resettlement. It provides time-limited coverage to newly arrived refugees and other ORR-eligible populations who are not eligible for Medicaid. ORR reduced the eligibility period from 12 months to four months in March 2025 and subsequently increased it to eight months in July 2026. For additional information, see USCRI’s call to restore a longer RMA eligible period.

For some ORR-eligible individuals who lose Medicaid coverage beginning October 1, RMA may provide temporary coverage if they remain within the applicable RMA eligibility period. The loss of Medicaid, however, does not restart that period. An individual who has already used part of the applicable eligibility period may receive only the remaining months of RMA coverage, while an individual whose eligibility period has expired may have no RMA coverage available.

RMA therefore serves as an important safety net for some individuals affected by the Medicaid changes, but it does not replace continued Medicaid eligibility. Because RMA is time-limited, affected refugees and other humanitarian populations may be left without an affordable, comprehensive coverage option once their RMA eligibility period ends.

Work Requirements and Administrative Burdens

In addition to narrowing the scope of coverage, H.R. 1 establishes new work requirements that will increase administrative obligations for applicants and states. Beginning January 1, 2027, adults ages 19 to 64 who are neither disabled nor pregnant must document at least 80 hours per month of employment, education, training, or volunteer service, or earnings equivalent to 80 hours at the applicable state minimum wage. States must also redetermine eligibility every six months, rather than annually, for low-income adults who gained coverage through the ACA’s Medicaid expansion.

When a similar policy was implemented in Arkansas in 2018, thousands of individuals lost health coverage. Many were meeting the policy’s substantive requirements but were unable to demonstrate compliance because of administrative barriers and confusion. Refugees and immigrants may face additional challenges in completing these requirements, including language barriers, changes of address, and limited familiarity with U.S. public agencies.

Policy Options and Next Steps

Beginning October 1, 2026, many individuals admitted to the United States through lawful humanitarian pathways, and who were assured access to care as part of their reception and resettlement, will face substantially reduced access to health coverage.

At the federal level, Congress has the authority to restore eligibility for humanitarian populations. The HEAL for Immigrant Families Act (S. 2149 / H.R. 4104) is one example of legislation that would restore enrollment in full-benefit Medicaid and CHIP to all otherwise eligible, lawfully present immigrants.

Congress can also strengthen the health care safety net for refugees and other ORR-eligible populations by restoring a longer RMA eligibility period. Although the increase from four to eight months provides additional protection, time-limited RMA cannot fully replace the ongoing Medicaid coverage that many humanitarian populations will lose under H.R. 1.

October 1, 2026, represents one stage in a broader contraction of benefit eligibility for immigrants rather than a single, universal cutoff date. Although federal law defines the scope of these changes, individual outcomes remain dependent in part on state policy. H.R. 1 does not prohibit states from using state funds to maintain coverage for affected populations. State decisions will therefore play a significant role in determining how many individuals ultimately remain without coverage.

More Resources

Working Families Tax Cut Legislation – Medicaid.gov

- Official government resources, home to guidance and technical assistance documents for Medicaid and CHIP

- Also see: CMS State Implementation Tool

USCRI’s Medicaid Immigration Eligibility Changes

- Note: This information is tailored specifically to 13 RMA locations including Alaska, Arkansas, Washington DC, Kansas, Kentucky, Maine, Missouri, Nevada, New Jersey, Oklahoma, Rhode Island, Tennessee, and Texas.

Medical Assistance Programs for Immigrants in Various States – National Immigration Law Center (NILC)

- A table outlining state policies for extending health coverage to more immigrant groups, including lawfully residing children and pregnant persons, regardless of their U.S. entry date

- Also see NILC’s Health Care Coverage Maps

Implementation of Medicaid Immigrant Eligibility Restrictions Under the 2025 Reconciliation Law: Issues to Consider – KFF (formerly known as Kaiser Family Foundation)

- Breaks down how the rules have changed, including new eligibility restrictions

State by State Medicaid and CHIP Enrollment Data – Georgetown University’s Center for Children and Families

- This tracker shows enrollment data for Medicaid and the Children’s Health Insurance Program (CHIP) in all 50 states and DC, from January 2025 to the most recent month available.

^ 1. Undocumented immigrants are not eligible for federally funded Medicaid outside of emergency care, despite some misinformation.