Changes from the 2025 CMS Final Rule and the One Big Beautiful Bill Act (OBBBA) may affect you and your family’s health coverage through Medicaid and healthcare.gov.
DACA recipients are no longer eligible for healthcare.gov coverage, changes are coming to immigrant eligibility for health coverage and affordability programs, the low-income special enrollment period is no longer be available, and the automatic re-enrollment process has changed. See the graphic(s) below for a full timeline of changes.
Some upcoming changes scheduled to take effect have been paused due to recent Federal court decisions. The policy changes affected by the court rulings are not in the timeline or the graphic below, but you can read more about them by clicking here.
August 25, 2025
ACA Changes
- DACA recipients are no longer eligible for Marketplace coverage.
- Low-income Special Enrollment Period (SEP) is eliminated.
January 1, 2026
ACA Changes
- Advance Premium Tax Credit (APTC) repayment limits end, regardless of income.
- A safe harbor remains for consumers up to 138% of the federal poverty level (FPL) who receive excess subsidies.
- APTC eligibility ends for lawfully present immigrants with income below 100% of the FPL.
- Automatic bronze-to-silver cost-sharing reduction (CSR) crosswalk is eliminated.
- HSAs may be paired with catastrophic and bronze plans.
- Consumers enrolling through a SEP that is not tied to a qualifying life event are no longer eligible for APTCs or CSRs.
- Insurers are prohibited from covering gender-affirming care as an Essential Health Benefit (EHB).
October 1, 2026
Medicaid Changes
- Medicaid eligibility for immigrant groups is limited to:
- Lawful permanent residents
- COFA migrants residing in the U.S.
- Certain Cuban and Haitian refugees
- Lawfully residing children and pregnant adults
December 2026 / January 1, 2027
Medicaid Changes
- Medicaid work requirements begin January 1, 2027.
- A Medicaid expansion denial or disenrollment for failure to meet work requirements negates Marketplace APTC eligibility .
- States must conduct eligibility determinations every 6 months for Medicaid expansion beneficiaries.
- Retroactive Medicaid coverage is limited to:
- 1 month prior to application for Medicaid expansion enrollees
- 2 months prior to application for traditional Medicaid enrollees
ACA Changes
- APTC and CSR eligibility for immigrants is limited to:
- Lawful permanent residents
- COFA migrants
- Certain Cuban and Haitian refugees
January 1, 2028
Medicaid Changes
- The maximum home equity limit for certain long-term care Medicaid enrollees is reduced to $1 million.
ACA Changes
- Pre-enrollment verification of APTC eligibility is required for subsidized Marketplace coverage.
- This effectively ends automatic reenrollment for many subsidized consumers.
October 1, 2028
Medicaid Changes
- States must begin imposing cost-sharing for certain medical services for Medicaid expansion beneficiaries with incomes between 100% and 138% FPL.
