Medi-Cal Eligibility

• Federal Policy Impacts
• Medi-Cal Eligibility
• Medi-Cal Benefits
• Behavioral Health
• Reproductive Health
• Medi-Cal Financing
• Section 1115 Waivers

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.

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 will no longer qualify for federally funded full-scope Medi-Cal. Members who are affected will get state-funded full-scope Medi-Cal until June 30, 2027.
• Work and Community Engagement Requirements
  • Starting January 1, 2027, adults ages 19–64 without children under 13 must meet work, volunteer, school, or training requirements to keep Medi-Cal. Exemptions apply for pregnancy, disability, serious health conditions, and other circumstances. Read more about work rules on the Medi-Cal Changes page.
  • 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.
  • In June 2026, CMS released an interim final rule with additional work requirements implementation details.
• Six-Month Eligibility Checks
  • Effective March 1, 2027, some adults ages 19–64 will need to renew Medi-Cal every six months instead of annually. Missing deadlines could result in loss of coverage. Read more about six-month eligibility checks on the Medi-Cal Updates page.
  • In March 2026, CMS released guidance regarding implementation of six-month renewals in alignment with H.R. 1.
• 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.
• Public Charge Rule
  • In July 2026, DHS issued a final rule rescinding 2022 public charge regulations and expanding immigration officer discretion to consider a wider range of income-based programs (including Medi-Cal, CalFresh, and federal housing assistance) when determining whether an applicant is likely to become a “public charge,” meaning they may become primarily dependent on government-funded support. This determination can affect visa and green card approvals. The final rule took effect on September 18, 2026, and benefits received before that date will not be considered under the new framework.

• Transition of Members with Unsatisfactory Immigration Status to Fee-for-Service
  • In 2025, federal guidance directed all states to transition Medicaid members with unsatisfactory immigration status (UIS) from managed care to Medicaid Fee-for-Service (FFS) by January 1, 2027. Members with UIS will no longer receive services through managed care plans and will instead obtain care through Medi-Cal FFS providers. States must make operational and system changes to support the transition and help maintain access to care for affected members.

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
  • The California Health and Human Services Agency (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
  • 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.
• Litigation
  • California is a lead plaintiff in New York et al. v. U.S. Department of Homeland Security et al., a multistate lawsuit to block the new federal public charge rule, arguing that the expanded definition unlawfully broadens who may be considered a “public charge” and would create significant harm for immigrant families across the state.
    • California previously submitted formal comments opposing the proposed federal rule and raised concerns that the final rule would create confusion, reduce access to essential services, and disproportionately harm mixed-status households. CalHHS also issued a joint public statement in July 2026 reaffirming California’s opposition and warning that the rule could discourage eligible families from seeking vital services and increase fear in immigrant communities.
    • California continues to provide trusted information and legal service referrals to help families navigate federal public charge policies. A list of qualified nonprofit organizations is available on the California Department of Social Services website, and additional guidance is available on the CalHHS public charge webpage.
  • California is a lead plaintiff in State of California et al. v. U.S. Department of Homeland Security et al., the multistate lawsuit challenging the CMS–DHS data sharing agreement, and a plaintiff in State of New York et al. v. U.S. Department of Justice et al. challenging expanded PRWORA restrictions.
  • California is a lead plaintiff in Commonwealth of Massachusetts et al. v. Mehmet Oz, M.D. et al., a multi-state lawsuit filed in June 2026 challenging several provisions of the interim final rule to implement work requirements.
• UIS/FFS Transition Planning and Implementation
  • DHCS has released the Policy Guide for transitioning Medi-Cal members with UIS from managed care to Medi-Cal FFS. The guide outlines member notifications, continuity-of-care expectations, provider enrollment needs, and required data-sharing activities. DHCS is coordinating with managed care plans, counties, and providers to reduce disruptions, maintain access to medically necessary services, and ensure clear communication.

Resources

• Medi-Cal Changes: What Members Need to Know
• Medi-Cal Immigrant Eligibility FAQs
• Public Charge Information
• Immigration Status and Changes to Medi-Cal Eligibility Chart
• Program Integrity: How DHCS Protects Medi-Cal

Page last updated September 21, 2026