In a July 14, 2026 Informational Bulletin, the Centers for Medicare and Medicaid Services (CMS) reminded states of their obligations to conduct Medicaid eligibility redeterminations on populations for which eligibility circumstance changes are known. In light of future changes to legal status for noncitizens like parolees and temporary protected status holders from the Department of Homeland Security (DHS), CMS emphasized states’ ongoing obligation to maintain accurate program enrollment. The bulletin makes a direct line to states’ obligations to redetermine eligibility for Medicaid for individuals in the United States (previously) legally via terminated parole programs for aliens from Cuba, Haiti, Nicaragua, and Venezuela. CMS points states to the DHS self-service portal, “Status Change Report”.
States who have determined individuals’ unsatisfactory immigration status must still comply with advance notice requirements prior to the state taking any adverse action (such as disenrollment) and notification of fair hearing rights. States will no longer receive matching funds for coverage of individuals without satisfactory immigration status. As states conduct redeterminations on this population, some individuals will surely lose Medicaid coverage, which could put payment for services provided following a disenrollment at risk.
The full bulletin is available here.
