A new round of Medicaid rules is beginning to take effect in Illinois, changing coverage for some noncitizens this month and setting the stage for broader eligibility requirements for some adults beginning in 2027. The first major change began Oct. 1.
Under a new federal law, the definition of which noncitizens can receive full federally funded Medicaid coverage has narrowed. Illinois officials say many people who previously qualified based on immigration categories including refugees, asylees, humanitarian parolees and certain trafficking survivors may no longer qualify for full Medicaid unless they fall into one of the categories that remain eligible under the new law.
Among those who can continue qualifying are lawful permanent residents who have met the five-year eligibility requirement or are exempt from it, certain Cuban and Haitian entrants and people living in the United States under the Compacts of Free Association. Lawfully residing children younger than 19 and pregnant people also remain eligible. Illinois-funded programs including Health Benefits for Immigrant Seniors, certain medical coverage for asylum applicants and torture victims, programs for survivors of domestic violence and coverage for kidney or renal disease are not being eliminated by the federal change. Emergency Medicaid also remains available to people who otherwise qualify for Medicaid but do not meet immigration requirements for full coverage when they have a qualifying medical emergency.
Illinois began notifying potentially affected Medicaid customers before the Oct. 1 change. People whose immigration status cannot immediately be verified may receive a request for additional documentation and have 90 days to submit updated immigration-status information. More changes are coming Jan. 1, 2027, and this time they will affect some adults currently covered through the Affordable Care Act Medicaid expansion. Illinois describes this group as ACA Adults, generally people ages 19 to 64 who do not have dependent children younger than 18 living at home and who are not enrolled in Medicare. Other Medicaid populations, including All Kids, Moms and Babies and many people receiving disability-related Medicaid, are not subject to the new work requirement or six-month redetermination schedule. Beginning in 2027, ACA Adults must either meet a new work requirement or qualify for an exemption in order to remain eligible.
Illinois says the requirement can generally be met through at least 80 hours per month of paid or unpaid work, volunteering or certain education activities, or by being enrolled in school at least half time. It can also be satisfied by having at least $580 in monthly income. Qualifying activities may be combined. Current Medicaid members will not all face the new requirement on Jan. 1 at once. Existing ACA Adult members will be reviewed when their first Medicaid redetermination occurs on or after Jan. 1, 2027. Illinois says the first group expected to face the requirement through redetermination will be people whose renewal dates occur in March 2027. New applicants are treated differently. ACA Adult applications submitted after 5 p.m. Central Time on Dec. 31, 2026, will be subject to the new requirements. Illinois says a new applicant generally must show that the work requirement was met during the month before applying, unless the person qualifies for an exemption. At the same time, ACA Adult Medicaid members will begin going through eligibility reviews every six months instead of once a year. The six-month redeterminations will also roll out based on each members individual renewal schedule
State officials say HFS will first use information already available through state data systems to determine whether someone has met a work requirement or qualifies for an exemption. If the state does not have enough information, the member will receive a request for documentation and generally have 30 days to respond. Failure to provide the requested information could result in coverage ending.
Marketplace coverage is changing alongside Medicaid.
Get Covered Illinois says many lawfully present immigrants losing Medicaid because of the Oct. 1 change may continue receiving financial assistance for marketplace coverage through Dec. 31, 2026. Additional restrictions on federal premium tax credits take effect in 2027. Beginning in 2027, people who lose Medicaid because they fail to meet the new work, education or community-service requirement, and who do not qualify for an exemption, will not be eligible for federal tax credits to lower the cost of a marketplace plan.
There is another change marketplace customers should know about: Cigna and Molina plans will no longer be offered through Get Covered Illinois beginning Jan. 1, 2027. People enrolled in those plans remain covered through the end of 2026 but will need to select another plan during open enrollment for 2027. For Medicaid recipients, the immediate advice from the state is straightforward: make sure HFS has a current mailing address, phone number and email address, regularly check a Manage My Case account and open any correspondence from the state as soon as it arrives.
Chicago News Weekly will continue examining these Medicaid and health coverage changes, including who may be affected, how exemptions will work and what residents should know before the 2027 requirements take effect.