Federal and state changes will affect how some Californians qualify for Medi-Cal and what steps they must take to keep coverage. These changes include new eligibility rules, immigration-related provisions, work requirements, and more frequent renewals. In November 2025, teh federal Centers for Medicare and Medicaid Services (CMS) released an
informational bulletin outlining changes without operational details; further guidance is expected.
Notable Federal Actions
Key Medi-Cal Eligibility Changes Under H.R. 1
- Moratorium on Streamlining Eligibility Rules
- Effective July 4, 2025, states must pause the adoption of simplified eligibility and renewal processes across Medicaid, the Children's Health Insurance Program (CHIP), and the Basic Health Program, such as shorter applications or automated renewals. Previously, there had been federal rules in place in which states were required to adopt these simplified processes.
- Amended Definition of Qualified Non-Citizen
- Starting October 1, 2026, federal law narrowed eligibility for full-scope Medicaid to certain immigration statuses, meaning some individuals who previously qualified for federally funded full-scope Medi-Cal will move to state-funded coverage with limited benefits.
- Work and Community Engagement Requirements
- Starting January 1, 2027, adults ages 19–64 without children under 19 must meet work, volunteer, school, or training requirements to keep Medi-Cal. Exemptions apply for pregnancy, disability, serious health conditions, and other circumstances.
- In December 2025, CMS released initial guidance on implementing work and community engagement requirements.
- In January 2026, CMS announced agreements with 10 Medicaid eligibility and enrollment technology vendors to provide more than $600 million in no-cost and discounted products and services. These voluntary commitments aim to help states implement work and community engagement requirements efficiently while modernizing Medicaid systems. DHCS is assessing opportunities with relevant technology vendors to determine how these voluntary offerings may support California’s implementation and modernization efforts.
- Six-Month Eligibility Checks
- Effective January 1, 2027, adults ages 19–64 without children under 19 will need to renew Medi-Cal every six months instead of annually. Missing deadlines could result in loss of coverage.
- Reducing Duplicate Enrollment
- Effective January 1, 2027, H.R. 1 requires states to update Medicaid address information using data sources such as the National Change of Address database and returned mail. Beginning in 2029, the federal government will establish a national database to identify individuals who may be enrolled in Medicaid in more than one state.
- In November 2025, CMS issued an informational bulletin reminding states to prevent concurrent Medicaid or CHIP enrollment in more than one state.
- Retroactive Coverage Limits
- Starting January 1, 2027, Medi-Cal will cover fewer past medical bills: adults ages 19–64 without children get one month of retroactive coverage, while all other members get two months.
- Cost Sharing
- Beginning October 1, 2028, some adults on Medi-Cal will pay small copayments for certain services, capped at 5 percent of household income, with no copays for emergency care, checkups, pregnancy, pediatric, mental health, or community clinic services.
Other Federal Actions
- Federal Data-Sharing
- In July 2025, breaking longstanding precedent, reports revealed that CMS shared Medicaid member data with the U.S. Department of Homeland Security (DHS), giving Immigration and Customs Enforcement (ICE) access to personal information.
- A federal court issued an order, effective January 5, 2026, allowing CMS to share data with ICE (a) only for individuals not lawfully residing in the U.S; and (b) only information describing an individual’s citizenship and immigration status, address, phone number, date of birth, and Medicaid ID number.
- CMS may not disclose information regarding any other individuals and CMS may not share other types of information, such as utilization of health care services.
- Expanded Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) Restrictions
- In July 2025, several federal agencies, including the federal Department of Health and Human Services (HHS), extended immigration-based eligibility restrictions under PRWORA to additional health care and other programs. This policy has been paused under a court order.
- Proposed Public Charge Rule
- In November 2025, DHS issued a proposed rule that would expand immigration officers’ discretion to consider an individual’s past or current use of Medicaid, CHIP, and other benefits when making public charge determinations.
- Existing public charge rules remain in effect. DHS is currently reviewing public comments on the proposed policy changes.
Actions California Is Taking
H.R. 1 Implementation Planning
- Implementation Plan
- DHCS is assessing the eligibility and operational changes required under H.R. 1, including verification processes, eligibility categories, and systems changes needed to align with federal requirements. Read DHCS' H.R. 1 Implementation Plan.
- Stakeholder Engagement
- CalHHS hosts regular webinars to explain federal changes and California's response, including impacts on Medi-Cal and CalFresh.
Responses to Other Federal Actions
- Data Privacy
- In July 2025, California and 21 other states filed a legal challenge following reports that CMS shared Medicaid member data with DHS, giving ICE access to personal information.
- DHCS issued a statement explaining CMS may share data with ICE only about individuals not lawfully residing in the U.S. while the multistate lawsuit continues.
- Formal Opposition to Harmful Rules
- In December 2025, the California Health and Human Services Agency (CalHHS), with DHCS and other departments, submitted formal comments opposing the proposed federal rule on public charge determinations. The letter emphasized that the rule would create uncertainty, harm access to health care and social services, and negatively impact millions of Californians, including U.S. citizens in mixed-status households. California urged DHS to withdraw the rule, citing its detrimental effects on public health, economic stability, and immigrant communities.
Resources
Page last updated February 6, 2026
