The short answer
The 2025 budget law, Public Law 119-21, gave four federal programs the same short list of eligible noncitizens: lawful permanent residents (green card holders), Cuban and Haitian entrants, and citizens of the Compact of Free Association nations living here lawfully. Refugees, asylees, parolees and others outside that list generally lose eligibility. For SNAP the change took effect on July 4, 2025, and states apply it to current households at recertification. Federal Medicaid and CHIP funding followed on October 1, 2026, with emergency Medicaid unchanged. From January 1, 2027, Marketplace premium tax credits go only to citizens and the three groups, and people already on Medicare who fall outside the list lose it on January 4, 2027. U.S. citizen family members keep their own eligibility throughout.
One short list for four programs
Before the law, each program kept its own, longer list of immigration statuses that could qualify. Refugees and people granted asylum, for example, could usually get SNAP and Medicaid soon after arriving. The 2025 law replaced those lists with the same three groups for SNAP, federally funded Medicaid and CHIP, Marketplace premium tax credits and Medicare:
- Lawful permanent residents, the people who hold a green card.
- Cuban and Haitian entrants, a status defined in federal immigration law.
- Citizens of the Compact of Free Association nations—the Federated States of Micronesia, the Marshall Islands and Palau—who live in the United States lawfully.
U.S. citizens and U.S. nationals are not affected. Everyone else who is lawfully present, including refugees, asylees, people paroled into the country and people with temporary protected status, now falls outside the list. The dates and the exceptions differ by program, so each is covered separately below.
The changes at a glance
Swipe sideways to see the whole table.
| Program | What changed | When it applies |
|---|---|---|
| SNAP | Only the three groups remain eligible among noncitizens; refugees and asylees, including children, lose eligibility | Since July 4, 2025; current households at their next recertification |
| Medicaid and CHIP | Federal funding for full coverage limited to the three groups; emergency Medicaid continues | October 1, 2026 |
| Marketplace premium tax credit, first change | No credit for lawfully present people below the poverty line who are barred from Medicaid by their status | Coverage for 2026 |
| Marketplace premium tax credit and cost-sharing reductions | Only citizens, nationals and the three groups can get them | January 1, 2027 |
| Medicare | Limited to citizens, nationals and the three groups | January 4, 2027, for people enrolled on July 4, 2025 |
SNAP: in force since the law was signed
The SNAP change came first. It took effect on July 4, 2025, the day the law was signed, and USDA told states to apply it at once to new applications and to review households already receiving benefits at their next recertification.
Refugees and asylees, including those under 18, are no longer eligible on the strength of that status, and neither is anyone else outside the three groups. A refugee or asylee who later becomes a lawful permanent resident can qualify again, and USDA's guidance says the five-year waiting period does not apply to them. For other green card holders, the five-year wait for most adults and its existing exceptions did not change.
Households with mixed status keep an important protection. A member who is not eligible does not have to apply or give an immigration status, and the rest of the household can still receive SNAP, though part of that member's income is counted. Our SNAP guide explains how a household is counted, and the SNAP calculator estimates a benefit for the members who remain eligible.
Medicaid and CHIP: the change that began October 1
Since October 1, 2026, the federal government pays its share of Medicaid and CHIP for noncitizens only if they belong to one of the three groups, with a few exceptions. States had until that date to redetermine eligibility for enrollees the change might affect, so a renewal request or a termination notice may already have arrived.
Three things stay in place. Emergency Medicaid, which pays for treatment of an emergency medical condition, remains available to people who meet the program's other rules, whatever their status. States that chose the option to cover lawfully residing children and pregnant women, often called the CHIPRA 214 option, can keep that coverage. And the five-year bar for most green card holders is unchanged, while Cuban and Haitian entrants and COFA citizens are exempt from it.
Separate CHIP programs lose federal funds for noncitizens outside the three groups, because separate CHIP has no emergency-only coverage to fall back on. Some states use their own money to cover people the federal government no longer pays for; CMS has said it will not require them to. Your state Medicaid agency can tell you what it offers, and our guide to Medicaid eligibility covers the income rules that still apply to everyone else.
Marketplace coverage: one change now, a bigger one in January
Two changes reach the health insurance Marketplace. Starting with coverage for 2026, lawfully present people with income below the poverty line who are barred from Medicaid because of their status no longer receive a premium tax credit. They had been the one group under the poverty line allowed to use the credit.
From January 1, 2027, the premium tax credit, and the cost-sharing reductions that lower deductibles and copays, go only to citizens, nationals and the three groups. Others who are lawfully present, including refugees, asylees and people with temporary protected status, can still buy a Marketplace plan, but at the full premium.
That makes this fall's open enrollment, when coverage for 2027 is chosen, the moment to plan. If someone in your household will lose the credit, compare the full-price plans with other options, such as coverage through a job, before you renew. Our guide to Marketplace subsidies explains how the credit is figured for those who keep it, and the ACA calculator estimates it.
Medicare: the last change, in January 2027
The law limits Medicare, including Part A, Part B and the private Medicare plans, to citizens, nationals and the three groups. The 2027 edition of Medicare & You states the same rule.
People who were already enrolled on July 4, 2025, and fall outside the list lose Medicare on January 4, 2027. Social Security had until July 4, 2026, to identify them and must notify each one before coverage ends. In July 2026 CMS proposed rules to carry out the change, including appeal rights and a way back in for people who later gain an eligible status, such as a refugee who becomes a lawful permanent resident.
If you or a family member receives a notice, keep it, check that it lists the right immigration status, and contact Social Security quickly if it does not. The Medicare calculator can help someone who stays eligible estimate what the coverage will cost.
What did not change
- Citizen family members. A U.S. citizen child keeps full eligibility for each program on the child's own terms, whatever the parents' status.
- Applying for someone else. For SNAP, a parent who is not eligible can apply for an eligible child without giving an immigration status of their own.
- Emergency care. Emergency Medicaid still pays for emergency treatment for people who meet the other rules.
- The waiting periods. Green card holders face the same five-year rules as before, with the same exceptions.
- Buying a plan. Lawfully present people outside the list can still enroll in a Marketplace plan; only the financial help ends.
Example (hypothetical): one family, four dates
Amal and Karim were granted asylum in 2023. Their two younger children were born in the United States; their oldest, who is 15, arrived with them and is also an asylee.
At the family's SNAP recertification, the parents and the oldest child are no longer eligible, but the two citizen children are. The household keeps a smaller benefit, with part of the parents' income counted.
When the state redetermines Medicaid for October 1, 2026, the citizen children stay covered and the parents lose federally funded coverage. The oldest child can stay covered if the state uses the CHIPRA 214 option. For 2027 the parents can still buy a Marketplace plan, without the tax credit. If they later become permanent residents, they can apply for SNAP again without a five-year wait.
If your household is affected
Because each program changed on its own schedule, a family can be affected by one change and not yet by another. Work through them in this order:
- Answer any notice from your SNAP or Medicaid office by the date it gives, even if you expect to lose eligibility; a late answer can end benefits for members who still qualify.
- Check whether anyone's status has changed. A refugee or asylee who has become a permanent resident may qualify again.
- Keep benefits for the members who are eligible, such as citizen children, by applying or renewing for them.
- Plan 2027 health coverage during open enrollment if a member will lose the Marketplace credit on January 1.
- Read any Medicare notice closely and contact Social Security if your status is listed wrongly.
Common questions
Do refugees lose SNAP right away?
Under USDA's guidance, states applied the new rule at once to new applications and to households already receiving SNAP at their next recertification. A refugee or asylee who becomes a lawful permanent resident can qualify again, and USDA says the five-year wait does not apply in that case.
Does the change affect U.S. citizen children?
No. A citizen child's eligibility for SNAP, Medicaid, CHIP and Marketplace help depends on the child's own status and the usual income rules. A parent who is not eligible can still apply for the child.
Can I still buy Marketplace coverage without the tax credit?
Yes. People who are lawfully present but outside the three eligible groups can still enroll in a Marketplace plan for 2027. They pay the full premium, without the premium tax credit or cost-sharing reductions.
Official sources
- USDA Food and Nutrition Service — SNAP implementation of the 2025 law: noncitizen eligibility (memo)
- USDA Food and Nutrition Service — Noncitizen SNAP eligibility questions and answers
- Medicaid.gov — State Health Official letter #26-001 on noncitizen Medicaid eligibility
- CMS — Guidance on noncitizen eligibility for Marketplace tax credits, plan year 2027
- CMS — Calendar year 2027 Physician Fee Schedule proposed rule (Medicare noncitizen eligibility)
Mark the two January dates
Two of the four changes are already in force, and the other two arrive within days of each other: Marketplace tax credits narrow on January 1, 2027, and Medicare coverage ends for affected enrollees on January 4. Put both on the calendar now, settle 2027 health coverage before open enrollment closes, and keep every notice you receive. For the year's other changes to benefit amounts and rules, see our roundup of 2026 changes.










