Short answer: Starting October 1, 2026, federal funding for full Medicaid and CHIP is generally limited to U.S. citizens and nationals, lawful permanent residents, Cuban/Haitian entrants and COFA migrants, so many refugees, asylees and people with other humanitarian statuses may lose eligibility for full coverage.
Section 71109 of the 2025 federal law (P.L. 119-21) limits federal matching money for full Medicaid and CHIP to those four groups, and CMS treats that as an eligibility change. States must identify affected members and redetermine them, first by checking electronic data before contacting the family.
Other rules did not change: lawful permanent residents generally still face the five-year waiting period, with exceptions such as veterans, active-duty service members and certain of their family members. Emergency Medicaid, which pays only to treat an emergency medical condition, is not affected.
For an employer, the practical effect is that some employees’ family members may lose Medicaid or CHIP. Losing it for loss of eligibility opens the 60-day special enrollment right into the group plan.