How will Federal changes impact Medicaid?

In September 2026, HFS will begin a paid advertising component of a larger public awareness campaign targeted to ACA Adult Medicaid customers. Communications will be ongoing throughout calendar year 2027, including written materials like fact sheets and toolkits, paid advertising, and earned media components.

This continuing campaign will include mailed notices, as well as alerts in Manage My Case, and texts for customers signed up for those modes of communication. Customers wishing to stay informed about upcoming Medicaid changes should update their contact information (address, phone number, and email) by visiting abe.illinois.gov or calling 877-805-5312 to ensure any communication reaches them.

We also recommend that customers create an account in our Manage My Case portal (or make sure you can log in if you already have an account) so you can manage your Medicaid case online. Manage My Case provides access to key information about an individual’s benefits and allows them to report or update their information.

Transparent and frequent engagement with stakeholders, including community partners, advocates, providers, and customers, will be essential as we navigate these changes together.

For additional HFS HR 1 communications materials, visit this website.

1. Work requirements for ACA Adults will be effective January 1, 2027, but you will not be required to demonstrate compliance with these requirements until your redetermination date.  At your redetermination, you will need to report qualifying work, education, and/or volunteer activities, or request an exemption. More details about work requirements and exemptions are below.
2. ACA Adults will be required to renew their coverage, also known as going through “redetermination,” every six months, rather than once per year, starting on January 1, 2027. This will happen on a rolling basis, based on when the customer’s redetermination date comes up in 2027.
3. Eligibility definitions for immigrant populations will narrow on October 1, 2026.
4. Effective January 1, 2027, retroactive coverage will be decreased from 3 months to 2 months for all Illinois Medicaid customers.

Individuals can check notices received in the mail or their account on Manage My Case to view their Medical Group coverage category. You will see “ACA” on the mailed notice or on the “Benefit Details” tab in your Manage My Case account if you are an ACA Adult.

This is what to look for on a mailed notice:

This is what to look for on Manage My Case:

Individuals with other Medicaid coverage (for example: Moms and Babies, All Kids, or Family Health Plans) are NOT subject to the new work requirement or 6-month redeterminations. These groups also include adults 65 years and older, and many people with disabilities. 

Beginning on January 1, 2027, individuals receiving medical benefits under the ACA Adult Medicaid expansion group (“ACA Adults”) must fulfill a work requirement to be eligible for benefits.

These requirements are mandated by a law passed by Congress and signed by the President in July 2025. Illinois must follow this law.

Work requirements can be met either by having income of $580 or more in a month, being in school half-time or more in a month, or working (paid or unpaid), volunteering, or less than parttime school for 80 hours in one month (including a combination of hours from different activities). Individuals can also be exempt from work requirements which is explained below. 

Individuals who are ACA Adults must fulfill work requirements to be eligible at application and to maintain eligibility at renewals unless they qualify for an exemption. Generally, ACA Adults:

• Are ages 19-64,
• Do not have a child under 18 residing in your home who is related to you, and
• Are not receiving (or entitled to) Medicare Part A or Part B.

There are many circumstances that can exempt individuals from the Medicaid work requirement. 

The groups below will at no time need to meet a work requirement for Medicaid benefits:

• Individuals under 19 and over 64 years old
  • You are exempt from Medicaid work requirements if you are 18 or younger or if you are 65 and older. This information is determined by your date of birth and does not need to be reported.
• Individuals in an eligibility group other than ACA Adult
  • Medicaid work requirements only apply to ACA Adults. You are exempt if you are receiving medical benefits under any other program (for example, Moms & Babies, Family Health Plans, AABD).
  • Medical program information is included in your case record and can be found on customer notices and in Manage My Case (MMC) under the Benefit Details tab.
  • You do not need to report what program you are enrolled in.
• Individuals enrolled in Medicare Part A or Part B, or are entitled to Medicare Part A
  • Pregnant people or people receiving postpartum coverage under the Moms & Babies Program
• If you receive partial coverage from Medicaid (i.e. not full benefits), such as in the Family Planning Program or those with a “met” or “unmet” spenddown balance

Individuals ages 19-64 applying for Medicaid coverage or enrolled in ACA Adult coverage must meet work requirements to qualify for Medicaid starting January 1, 2027.

• For new Illinois Medicaid applicants, Medicaid work requirements will apply to individuals who qualify for ACA Adult coverage and who submit an application for benefits after 5:00 p.m. on December 31, 2026.
• ACA adults who are currently enrolled in Medicaid, will have to meet work requirements at their first 2027 redetermination date. The first group of people subject to work requirements will be those whose redetermination dates are in March 2027.

If the application is started and submitted by 5:00 p.m. Central Time on December 31, 2026, then eligibility will be determined using current rules rather than the new H.R.1 rules—regardless of the date it is processed by the State. If approved, these applicants will be subject to work requirements as of their first redetermination in 2027. 

• If you apply for medical benefits after December 31, 2026, and HFS determines that you are an ACA Adult, you will have to have met the Medicaid work requirement in the month before you apply to be approved.
  • For example, if you apply for medical benefits in April 2027, you must have met the Medicaid work requirement in March 2027 to be approved.
  • However, if you have an exemption, you can show proof of that exemption in the month you apply.
• If you already have an active ACA Adult medical case and are attempting to renew coverage, HFS will review your case at your first regular redetermination in 2027 to see if you have met the Medicaid work requirement.
  • If you are an ACA Adult, you are required to meet or be exempt from the Medicaid work requirement either at the time of your redetermination or for at least one month since your last redetermination. 
• HFS will check data sources we have access to and see if you have met the Medicaid work requirement or if any exemptions apply to you at your redetermination. If we have enough information from those sources, then you will not have to give us any more information about work requirements.
• If we do not have enough information to determine if you met the work requirement or qualify for an exemption, you will receive a notice with your redetermination form requesting more information.
• You will have 30 days to provide this information to HFS. If this information is not returned, your medical benefits will end.

If Medicaid work requirements apply to you and you do not qualify for an exemption, you can meet them with any of the following “qualifying activities”:

• Have monthly income of $580 per month or more
• Work at least 80 hours per month (work includes a full-time or part-time job, self-employment, seasonal work, and unpaid work like an internship)
• Have at least 80 hours of community service (volunteering) per month
• Participate in a work program for at least 80 hours per month (visit snapworkrequirements.illinois.gov to view qualifying work programs)
• Are in school (high school, GED, or college or trade school) at least half-time as determined by your school
• Are a seasonal worker with an average monthly income in the last 6 months that is not less than $580 per month

You can also meet work requirements by doing a combination of work, community service, work programs, or school for a total of at least 80 hours per month.

Example 1: Jane receives ACA Adult medical benefits. In February, she worked a total of 87 hours. Jane met the Medicaid work requirement by working at least 80 hours in February.

Example 2: Mike receives ACA Adult medical benefits.  He has a part-time job and also volunteers at his local food pantry.  In June, he worked for 50 hours and volunteered for 30 hours. Mike met the Medicaid work requirement by working and doing community service for a total of 80 hours in June.

Example 3: Jessica receives ACA Adult medical benefits and participates in a work program. In May, Jessica participated in the work program for 50 hours. Jessica did not meet the Medicaid work requirement in May because she did not participate for at least 80 hours. 

Example 4: Logan receives ACA Adult medical benefits and is enrolled in a trade school half-time. Logan is meeting the Medicaid work requirement because he is enrolled in an educational program at least half-time.

Example 5: Vera receives ACA Adult medical benefits. In August, she worked 65 hours and earned $975. Vera met the Medicaid work requirement by earning more than $580 in the month of August. 

You can also meet the Medicaid work requirement if the total income we attribute to you is equal to or more than the Federal Minimum Wage multiplied by 80 hours—currently $580 per month. Depending on who is on your case, income from other people may count as “your” income for work requirements purposes. If the other person is also an ACA Adult, the income may be able to be used for BOTH people to meet the $580 threshold. 

Example 1: Alex is receiving ACA Adult medical benefits. Alex worked a total of 50 hours in October and earned $650. Even though he did not complete 80 hours of a qualifying activity, Alex met the Medicaid work requirement in October because his total income was more than $580.

Example 2: Francis and Ricky live together and are in the same Eligibility Determination Group (EDG), as determined by a caseworker based on your household relationships and tax filing status. Fran makes $600 a month working as a delivery driver. Ricky currently has no income. Because they are in the same EDG, the $600 total monthly income will qualify as meeting the work requirement for both Fran and Ricky since the total monthly income is more than $580.

Work has been defined by the federal government as:

• Work in exchange for money
• Unpaid work other than community service (for example, an unpaid internship at a private company)
• Self-employment
• Seasonal work

The federal government also provides guidelines about what can qualify as community service: “unpaid work with a structured program that is completed for the direct benefit of the community.” 

Yes. ACA Adults must meet work requirements or have an exemption to be eligible for Medicaid at the time of application and to maintain eligibility through future coverage renewals. 

You can be exempted from work requirements if you are:

• A former foster youth who is under 26 years old
• Pregnant or are receiving benefits after your pregnancy under the Moms & Babies program
• An American Indian/Alaska Native, an American Urban Indian, a California Indian, a member of a recognized tribe, or qualified to receive healthcare through the Indian Health Service (IHS)
• A parent, guardian, caretaker relative, or family caregiver (paid or unpaid) of a dependent child who is under 14 years old or a person with a disability
• A Veteran with a Veterans’ Administration disability rating of 100%
• A person with special medical needs (“medically frail”), meaning that you have health issues that prevent you from meeting work requirements, like:
  • Being blind or disabled under Social Security standards
  • Having a substance use condition (drug or alcohol)
  • Having a serious mental health condition
  • Having a physical, intellectual, or developmental disability that makes it hard for you to perform daily activities
  • Having a serious or complex medical condition that requires regular treatment
• Receiving TANF benefits and meeting TANF work requirements
• A member of a household receiving SNAP benefits and are NOT exempt from SNAP work requirements
• Participating in a drug addiction or alcohol treatment program
• An inmate of a public institution (prison or jail) currently or within the last 3 months

You may also be exempted from work requirements if you are experiencing a short-term hardship. These hardships include:

• Living in a county with a federally declared emergency or with a high unemployment rate.
  • We will determine this and notify you if you meet this exemption.
• Being an inpatient in a hospital, rehab facility, intermediate care facility for individuals with intellectual disabilities, or inpatient psychiatric hospital.
  • You must request this exemption in order to receive it.
• Having to travel outside of your community for an extended period for medical services to treat a serious or complex medical condition that are not available in your community.
  • You must request this exemption in order to receive it.

Individuals with special medical needs may qualify for the medical frailty exemption from the new work requirements. This means that you have health issues that prevent you from meeting work requirements, like:

• Being blind or disabled under Social Security standards
• Having a substance use condition (drug or alcohol)
• Having a serious mental health condition
• Having a physical, intellectual, or developmental disability that makes it hard for you to perform daily activities
• Having a serious or complex medical condition that requires regular treatment

The federal Centers for Medicare and Medicaid Services has said that they will be releasing additional information about how to comply with the medical frailty exemption. HFS will update this response once that guidance is released.

ACA Adults who are members of a household that receives SNAP and who are subject to SNAP work requirements are exempted from the new Medicaid work requirements.

This means that your Medicaid won’t be impacted if:

1. You are meeting SNAP work requirements or
2. You are in your 3-month grace period for SNAP work requirements.

HFS and DHS share the same eligibility system, so we can see whether you are meeting the SNAP work requirement or if you are within your 3-month grace period. We will automatically mark you as exempt from the Medicaid work requirement, and you will not be asked to provide additional proof or fill out additional documentation.

• Example: Bill has both SNAP and Medicaid. He is considered an ABAWD (Able-bodied Adult without Dependents) for SNAP and gets ACA Adults Medicaid coverage. Bill met the SNAP work requirement for April 2027, which is also within the 6-month lookback timeframe for his current Medicaid redetermination. Bill will automatically be considered exempt from the Medicaid work requirement without any action required from him.

However, if you are exempt from SNAP work requirements, you will still have to meet Medicaid work requirements, unless you have an exemption that applies to both SNAP and Medicaid work requirements. Exemptions that overlap for both programs include being pregnant, being an American Indian or Alaska Native, or being in a substance use disorder treatment program.

For more information about meeting the SNAP work requirement, please view the SNAP work requirements FAQ page on the DHS website.

Remember, work requirements have not started yet, and you do not need to be reporting to Illinois Medicaid right now. We recommend that you think about whether you are going to meet work requirements or try to be exempted from them and start to plan now.

In late 2026, you will be able to go to abe.illinois.gov and click on “Check to see if I meet Medicaid Work Requirements.” This will be a screener where you can answer questions that will help you understand if work requirements apply to you, how to meet them, and how to request an exemption.

When we are reviewing your Medicaid at the end of your eligibility period, we will first use the information we already have to attempt to verify if you are exempt from the work requirement. If we can verify you through our existing data and other sources, you will not need to take any action to prove that you meet or are exempt from work requirements. If we do need more information, we may ask you to provide proof that you meet one of the exemptions above to get or keep your Medicaid eligibility.  

The State must provide notice of noncompliance and allow the applicant or beneficiary 30 calendar days to either demonstrate compliance or prove that they qualify for an exemption.

An enrolled individual will continue to have coverage during this 30-day period. The notice of noncompliance and the 30-day response period will overlap with the redetermination form and the time the individual has to return it. If you are a current beneficiary and cannot demonstrate compliance or qualify for an exemption within that 30-day period, you will not be renewed for Medicaid benefits and your coverage will end at the end of your certification period (which will be listed in your notice).

If you are denied Medicaid or your benefits are terminated, you can submit an appeal if you think the State made a mistake. An appeals request must be submitted within 60 days of the adverse determination. When you appeal an action as an applicant, you are asking for a fair hearing about the action.

A fair hearing is a meeting with a fair hearing officer, someone from the Department, and the applicant. Applicants may not get a fair hearing if the action happened because of a change in the law.  

An appeal request can be made in writing or by completing an Appeal Request Form, Spanish Appeal Request Form pdf and mailing to: Bureau of Administrative Hearings, 401 South Clinton, 6th Floor, Chicago, IL 60607. The form can also be faxed to 1-312-793-0095 or submitted to an FCRC, via telephone, or through ABE.illinois.gov.  To make an appeal over the telephone, call 1-800-435-0774 (TTY: 1-877-734-7429). The call is free.

States will be required to verify that ACA Adults continue to meet all eligibility requirements, including work requirements, every 6 months. You will need to meet or be exempt from work requirements at your first redetermination in calendar year 2027 and will be set on a 6-month redetermination schedule at that time. This applies only to ACA Adults.

Eligibility periods are set on an individual basis so each member of this household will have a different eligibility period. Only ACA Adults will have to renew every 6 months.

Example 1: Charlie is an ACA Adult who lives alone. His first renewal in 2027 is on March 2. His next renewal will be 6 months later on September 2, 2027.

Example 2: Tina and Gabe live together in the same household. Gabe is blind and has AABD coverage, but Tina is an ACA Adult. Gabe will continue to receive one renewal letter each year. However, Tina will start receiving a renewal letter every 6-months starting at her first renewal date in 2027. Even though Tina and Gabe live in the same household, they have different renewal dates and timelines.

HFS uses two primary methods to confirm eligibility for Medicaid benefits. The first is Form A (Ex-Parte) where the department accesses data sources to confirm eligibility without having to contact you. This aims to ease the paperwork burden on both you and on State staff. HFS will continue to use Form A (Ex-Parte) to implement the new requirements of H.R.1, but the new requirements in federal law may require HFS to seek more information directly from customers and may decrease the number of redeterminations we can make this way.

The other method HFS uses to confirm eligibility for Medicaid benefits known as Form B. If you are sent Form B, then you must complete it and return it in order for your benefits to continue. HFS will continue to use Form B with some modifications.

An eligibility period that was set in 2026 for 12 months ahead will not be changed. However, at the first redetermination in 2027, work requirements will apply and future redeterminations will happen every six months, not twelve.  

•  For example, if your eligibility period started in June 2026 and would end at the end of May in 2027, you will not be redetermined according to the new Medicaid rules until May 2027. It will not be until your redetermination process begins in April 2027, when as an ACA adult you will be subject to both the work requirements and ongoing 6-month redetermination requirement. 

Congress passed a law that changes who can receive Medicaid coverage and Marketplace subsidies.

Under this federal law, starting on October 1, 2026, many noncitizens who have long been eligible for coverage will lose access to federal Medicaid programs. 

October 1, 2026

If you no longer qualify for full Medicaid as of October 1, 2026, you will receive:

• A notice from the state
• A request for updated immigration information (if needed)
• A 90-day period to submit your most current immigration status documents if your immigration status cannot be verified right away

The last day of federal medical coverage for noncitizens due to the H.R.1 changes will be September 30, 2026. Individuals are encouraged to seek any medical treatment and medication prior to that date.

Beginning October 1, 2026, only the following noncitizens will keep Medicaid coverage:

• Lawful Permanent Residents (LPRs or “green card” holders) who:
  • Have met the 5-year eligibility bar, OR
  • Are not subject to the five-year eligibility bar (for instance, refugees, asylees, and trafficking survivors who adjust to LPR from that status)
• Cuban/Haitian entrants
• Compacts of Free Association (COFA) migrants
• Children under the age of 19 (All Kids) and pregnant individuals (Moms & Babies)
• People already enrolled in the Health Benefits for Immigrant Seniors (HBIS)
• People enrolled in Illinois-funded:
  • AATV Medical coverage
  • Illinois’s medical program for survivors of domestic violence
  • Illinois’s medical program for kidney/renal disease

No.  LPRs remain subject to the waiting period unless they fall under an existing exemption.

LPRs who are exempt from the five-year waiting period include:

• Asylees and refugees
• Cuban/Haitian entrants
• Victims of trafficking and their spouse, child, sibling, or parent or individuals with a pending application for a victim of trafficking visa
• Individuals granted withholding of deportation
• Member of a federally recognized Indian tribe or American Indian born in Canada
• Citizens of the Marshall Islands, Micronesia, and Palau who are living in one of the U.S. states or territories (referred to as COFA or COFA migrants)
• Veterans or active-duty military and their spouses or unmarried dependents who also have “qualified non-citizen” status
• Child receiving foster care or adoption assistance
• Individuals admitted as an Amerasian immigrant
• Individuals granted Iraqi or Afghan special immigrant status
• Lawfully residing children or pregnant individuals

Yes.  This coverage is not affected by H.R. 1. 

No. Illinois decides whether and how to continue or modify its state-funded programs and these programs are unchanged.

Yes. Emergency Medicaid will continue to be available for qualifying emergency medical needs regardless of noncitizen status.

Emergency Medicaid pays for treatment of an emergency medical condition for people who:

• Meet all Medicaid eligibility rules (including income eligibility and Illinois residency) except immigration status, and
• Present with a qualifying medical emergency.

Starting January 1, 2026:

Lawfully present individuals with income below 100% FPL, who were ineligible for Medicaid due to immigration status, have also become ineligible for premium tax credits. 

Lawfully present individuals are still eligible for a Marketplace plan at full price and that does not change in 2027.

Starting January 1, 2027:

Only the following noncitizens (with incomes between 100-400% FPL) are eligible for Marketplace premium tax credits:

• LPRs
• Cuban Haitian entrants
• COFA migrants

Yes. The new federal law significantly changed noncitizen eligibility for Medicare. For new Medicare applicants on or after July 4, 2025, only these noncitizens can be eligible:

• Lawful permanent residents (Green Card holders),
• Cubans or Haitians, with a range of current or past statuses, and
• People from Micronesia, Palau, or the Marshall Islands living in the U.S.

If you were already enrolled in Medicare as of July 4, 2025, you can keep your coverage until January 4, 2027, when it ends.

• Update your address, phone number, and email with HFS to ensure you receive communications from HFS and IDHS.
• Look out for letters or other communications from IDHS or HFS about your benefits.
• Respond promptly to any request for current immigration documents to ensure that HFS and IDHS have your most up-to-date immigration status.
• If you have a Manage My Case account, ensure that your MMC account has your most up-to-date address, email, and phone number, as well as your immigration status. Request help from community organizations, health navigators, or legal service providers.
• Visit https://abe.illinois.gov for application and case information.

You can contact IDHS, HFS, your local FCRC, and noncitizen servicing organizations.

IDHS Customer Help Line: 1-800-843-6154 (TTY: 1-877-734-7429)

HFS Health Benefits Hotline: 1-877-805-5312 (TTY: 1-877-204-1012)

ABE (Apply for Benefits): https://abe.illinois.gov

Get Covered Illinois (Illinois Marketplace): https://getcovered.illinois.gov/ or call 1-866-311-1119 

Noncitizens may access Federally Qualified Health Centers (FQHC), community health centers, and free and charitable clinics. These providers serve uninsured and underinsured people regardless of immigration status and ability to pay.

More information and clinic locations are available online at www.illinoisfreeclinics.org and www.iphca.org/health-center-locator

Beginning January 2027, Medicaid will only provide two months of retroactive coverage to eligible people at application instead of three months.

H.R.1 made more drastic cuts, but HFS has secured state funding to allow all Medicaid groups to be assessed for up to two months of retroactive coverage. 

Retroactive coverage allows medical care to be paid for up to a certain amount of time prior to your Medicaid application submission date.

Medical events can’t always be predicted, and retroactive coverage is one way to protect uninsured individuals and families against accruing medical debt. It also helps reimburse providers for services they have already furnished.