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Medicaid and ACA for Immigrants: Who Qualifies After the 2026 Changes

RussiansInUSA editorial team · Updated October 29, 2026 · Facts checked October 28, 2026

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Medicaid and ACA coverage for immigrants changed in 2026. Since October 1, 2026, federal Medicaid and CHIP money covers only citizens, green card holders (usually after a 5-year wait), Cuban/Haitian entrants and COFA migrants. Refugees, asylees and parolees, including Ukrainians under U4U, lost full federal Medicaid, though emergency care and, in many states, coverage for children and pregnant people remain. Lawfully present immigrants can still buy a plan on healthcare.gov, but from January 1, 2027, only green card holders, Cuban/Haitian entrants and COFA migrants get the premium tax credit.

Below: what changed, who waits 5 years, where children and pregnant people are covered, when to enroll, and how public charge works now. For a general overview of coverage for newcomers, see our guide to health insurance for immigrants.

What changed for Medicaid and immigrants in 2026

Section 71109 of the 2025 budget law (Public Law 119-21) limited federal funding for Medicaid and CHIP for noncitizens. According to a CMS letter to states dated April 8, 2026, starting October 1, 2026, federal money for full Medicaid and CHIP goes only to US citizens and nationals, lawful permanent residents (LPRs), Cuban/Haitian entrants and Compact of Free Association (COFA) migrants.

Other "qualified noncitizens" lost federal coverage. CMS names asylees, refugees, parolees and trafficking victims among them. States may still cover these groups with their own money, but CMS does not require it and does not count that coverage as Medicaid.

StatusFull Medicaid before Oct 1, 2026Full Medicaid from Oct 1, 2026Emergency Medicaid
Green card, 5-year wait met or not requiredyesyesnot needed
Green card, still in the 5-year waitnonoyes
Refugeeyesnoyes
Asyleeyesnoyes
Paroled for at least one yearyesnoyes
Certain Ukrainian parolees (2022 law)yesnoyes
Cuban/Haitian entrantyesyesnot needed

Checked October 28, 2026, against CMS letter SHO #26-001 on medicaid.gov.

If you already have Medicaid under one of the affected statuses, your state must review your eligibility. It first checks your status through the DHS SAVE system and contacts you if it cannot confirm it. Answer Medicaid letters on time, and report a status change such as a new green card.

The Medicaid 5-year bar: who waits and who does not

A 1996 law (PRWORA) makes many immigrants wait five years after getting a "qualified" status before they can get full Medicaid or CHIP. The 2025 law did not change this. Green card holders still wait.

No 5-year wait applies to:

  • green card holders who were previously refugees or asylees;
  • veterans and active-duty service members and certain family members;
  • Cuban/Haitian entrants and COFA migrants.

Example: if you got a green card through marriage in March 2024, full Medicaid opens no earlier than March 2029. A former refugee who adjusted to a green card does not wait. In the meantime, the Marketplace is open to you.

CHIP for immigrant children and coverage for pregnant people

Since 2009, states may cover children and pregnant people who are "lawfully residing" in the US without the 5-year wait: children under 21 in Medicaid and under 19 in CHIP. This is known as the CHIPRA 214 option. The 2025 law left it untouched, so federal money still flows for these children and pregnant people after October 1, 2026.

This matters for families with parole, TPS or a work visa: in a CHIPRA 214 state, a lawfully residing child can get Medicaid or CHIP even when the parents cannot. Most states and DC use the option, but not all. The list, showing whether a state covers children, pregnant people or both, is on medicaid.gov (updated April 2, 2026). DACA recipients do not qualify under this option.

ACA marketplace for immigrants: who can buy a plan

The Marketplace is open to citizens, US nationals and lawfully present immigrants. Undocumented immigrants cannot buy coverage there, and healthcare.gov says DACA recipients are not eligible either. If you are in your 5-year Medicaid wait, you can use the Marketplace.

The healthcare.gov status list includes, among others: green card holders, refugees and asylees; parolees; people with an employment authorization document (EAD); nonimmigrants such as workers, students and U or T visa holders; TPS holders; applicants for adjustment to permanent residence; and children under 14 with a pending asylum application.

Mixed-status families can apply only for the members who qualify. Family members who are not applying for themselves will not be asked about their immigration status, and a state cannot deny an applicant because such a relative did not share it. You will need a Social Security number for many other things too; see our SSN guide.

Health insurance for green card holders and others: subsidies from 2027

Buying a plan and getting the premium tax credit are separate. Healthcare.gov says that due to a law change, starting January 1, 2027, only three immigrant groups qualify for savings:

StatusCan buy a plan in 2027Premium tax credit in 2027
Green card holder (LPR)yesyes, if income qualifies
Cuban/Haitian entrantyesyes, if income qualifies
COFA migrantyesyes, if income qualifies
Refugee, asylee, parolee, TPS, EAD, work or student visayesno
DACA, undocumentednono

Rules checked October 28, 2026, on healthcare.gov.

Healthcare.gov describes income between 100% and 400% of the federal poverty level (FPL) as the range where the tax credit may apply. For a Ukrainian parolee or a TPS holder, a 2027 Marketplace plan will cost full price, so compare it with employer coverage and any state program.

When to enroll: open enrollment and special enrollment

Open enrollment for 2027 coverage runs from November 1, 2026, to January 15, 2027.

Enroll and pay the first premiumCoverage starts
November 1 to December 15, 2026January 1, 2027
December 16, 2026, to January 15, 2027February 1, 2027
From January 16, 2027only with a Special Enrollment Period

Dates checked October 28, 2026, on healthcare.gov.

A Special Enrollment Period follows certain events, usually with a 60-day window. Healthcare.gov lists moving to the US from another country, moving to a new ZIP code or county, marriage, a new baby, losing other coverage and becoming a US citizen. Medicaid and CHIP accept applications all year. The Marketplace phone line is 1-800-318-2596.

Emergency Medicaid and public charge

Emergency Medicaid pays for treatment of an emergency medical condition for people who meet all other Medicaid eligibility rules in their state but lack an eligible immigration status. The 2025 law did not change it. It covers only that emergency care, not regular medical care.

Public charge is a test applied when someone seeks a visa, admission or a green card. A new DHS rule took effect September 18, 2026. It applies to applications for admission made on or after that date and to green card (adjustment of status) applications postmarked or submitted online on or after that date. Officers may consider any means-tested public benefits received on or after September 18, 2026. For benefits received before that date, only cash assistance for income maintenance and long-term institutional care at government expense are considered.

The rule sets no list of programs that count or do not count, and DHS says it does not exclude any means-tested benefit from consideration, including Medicaid. Healthcare.gov notes that DHS has issued new public charge guidance for people applying for a visa, entry to the US or a green card. The rule does not change who is eligible for benefits. Congress exempted some groups from the public charge test; the rule names refugees and asylees, at admission and when they apply for a green card.

If you are waiting for a green card and deciding whether to take Medicaid for yourself or your children, talk to an immigration attorney first. Our lawyer directory lists Russian-speaking ones.

Health insurance for refugees and U4U parolees

Ukrainians who came through Uniting for Ukraine were treated like refugees under a 2022 law and could get full Medicaid. Since October 1, 2026, there is no federal money for that. What remains: Medicaid or CHIP for children and pregnant people in CHIPRA 214 states, emergency Medicaid, a Marketplace plan (without the tax credit from January 1, 2027), and any state-funded program your state runs; ask your state Medicaid agency.

Refugees and asylees are in the same position until they get a green card; after that, federal Medicaid opens again without the 5-year wait. For more on Ukrainian status options, see our U4U and TPS guide. To find a Russian-speaking doctor who takes your plan, use our doctor directory.

Questions people ask

Can a green card holder get Medicaid right away?

Usually not. Most green card holders wait five years after getting their status, and the 2025 law kept that rule. Former refugees and asylees, veterans, active-duty service members and certain family members are exempt. During the wait, a green card holder can buy a plan on healthcare.gov and may get the premium tax credit with income between 100% and 400% of the federal poverty level.

Do Ukrainians with U4U parole keep Medicaid after October 1, 2026?

Adults with U4U parole lost full federally funded Medicaid on October 1, 2026. Children and pregnant people keep coverage in states that chose the CHIPRA 214 option, and emergency Medicaid remains. Parolees can still buy a plan on healthcare.gov, but from January 1, 2027, they cannot get the premium tax credit for it.

Can I insure my child if I do not have an eligible status?

Yes. Healthcare.gov lets families apply only for members who qualify, and family members who are not applying are not asked about their immigration status. A lawfully residing child can get Medicaid or CHIP without the 5-year wait in a state that chose the CHIPRA 214 option.

Can using Medicaid hurt my green card application?

It can. Under the DHS rule in effect since September 18, 2026, officers may consider any means-tested public benefits received on or after that date for adjustment applications filed on or after it. The rule gives no list of programs. Anyone waiting for a green card should talk to an immigration attorney before applying for Medicaid.

Sources

Related guides

Medicaid and ACA for Immigrants: 2026-2027 Rules | RussiansInUSA