COFA Citizens: Your Medicaid Eligibility Is Preserved

Your eligibility survives the 2026 change

COFA citizens have had a turbulent coverage history: eligible for Medicaid at first, excluded in 1996, and restored by Congress in 2020. Section 71109 could plausibly have swept COFA migrants out again — but it did not. The post-October 2026 federal definition covers U.S. citizens and nationals, lawful permanent residents (generally after five years), Cuban/Haitian entrants, and COFA migrants. You are named in the statute.

You also remain exempt from the five-year waiting period that applies to most green card holders. Income-eligible COFA migrants can enroll in federally-funded Medicaid and CHIP immediately, and that remains true after October 1, 2026 — while refugees, asylees, parolees, TPS holders and other groups lose access.

The risk is paperwork, not the law

For COFA migrants, the biggest danger through 2026-2027 is administrative. States will redetermine millions of cases as this provision and the new work requirement phase in, and category errors are common in mass reviews — a COFA citizen mis-coded as 'other lawfully present' could receive an incorrect termination notice. If that happens, appeal within the deadline and state your COFA citizenship clearly; eligibility workers may apply the new exclusions too broadly.

Keep your documents ready: a valid COFA nation passport, your I-94 showing admission under the Compact, and any state correspondence. Note that if your state adopts the 2027 Medicaid work requirement for expansion adults, COFA migrants are subject to its 80-hour rule and exemptions like other adults — protected status covers eligibility, not the new activity requirement. Use this site's exemption self-check to see where you stand.

Mixed-status families: screen everyone separately

Your protection is individual. A spouse or relative in the household under a different status — humanitarian parole, TPS, or another category — faces different rules after October 1, 2026 and may lose federal eligibility even though you keep yours. Children have a separate buffer: in states using the CHIPRA 214 option, lawfully residing children and pregnant people keep federally-funded coverage regardless of the adult rules.

State agencies determine eligibility person by person, so a notice for one family member says nothing about the others. Screen each person's status individually, and respond to each person's notices separately.

Marketplace access you keep

COFA migrants also keep marketplace premium tax credit access after the January 1, 2027 tightening, which limits subsidies to LPRs, Cuban/Haitian entrants, and COFA migrants. If your income rises above your state's Medicaid line, a subsidized marketplace plan remains a realistic option for you — a bridge that refugees, asylees, parolees, TPS holders and DACA recipients lose after 2026.

Practical to-dos: renew coverage on time; report income and address changes promptly; appeal any notice that misapplies the new exclusions; prepare for the work requirement's 80-hour reporting if you are an expansion adult in an affected state; and have each family member check their own category.

If your federal Medicaid has ended — your options, in order

Your children's coverage is separate. Children who are U.S. citizens or qualified immigrants can keep Medicaid or CHIP even when a parent's federal eligibility has ended — renew their coverage on time and do not drop their applications.

Lawfully present immigrants can buy marketplace coverage at any income, and households at or above 100% FPL generally qualify for premium tax credits. Losing Medicaid opens a 60-day Special Enrollment Period — our coverage alternatives page ranks the realistic options by cost.

Several states use their own funds to cover residents regardless of immigration status — California and New York are the largest examples, and a few others run narrower programs. Eligibility and enrollment windows change, so confirm with your state Medicaid agency before counting on it.

Emergency Medicaid remains available in every state for acute conditions regardless of status. It pays for the emergency itself, not for ongoing care — treat it as a backstop, not a plan.

Frequently asked questions