April 9, 2026

AHA: New CMS guidance restricts full Medicaid and CHIP benefits for “certain noncitizens”

By: Joe Paone
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The Centers for Medicare and Medicaid Services (CMS) on Wednesday released guidance that, according to the American Hospital Association (AHA), describes limits to Medicaid and Children’s Health Insurance Program (CHIP) funding for “certain noncitizens.”

AHA stated the guidance involves the implementation of a provision within last July’s federal reconciliation bill regarding “federal matching funds for full Medicaid and CHIP benefits for certain U.S. residents.” It stated that, beginning Oct. 1, federal matching funds for full Medicaid and CHIP benefits will be restricted to “legal permanent residents, certain Cuban and Haitian immigrants, and Compact of Free Association migrants lawfully residing in the U.S.”

AHA stated that “other lawfully present noncitizens, including refugees, asylees, parolees and victims of trafficking, will no longer be eligible for full Medicaid or CHIP benefits with federal matching funds.”

According to AHA, CMS “clarified that the law does not change the Personal Responsibility and Work Opportunity Act’s definitions or underlying immigration eligibility rules, but instead limits when federal match is available, and that states are not required to provide state-only coverage where federal funding is unavailable.”

AHA stated that the guidance “outlines required state actions to implement these changes, including eligibility redeterminations for current enrollees, updates to eligibility and verification systems, managed care and financial claiming procedures and submission of Medicaid and CHIP state plan amendments.” It added that CMS “reiterated that federal matching funds remain available for emergency Medicaid.”

Download CMS’ full letter here.

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