Home » Get Covered Illinois » H.R.1 Changes
Federal legislation H.R.1 (Public Law 119-21) is reshaping how Premium Tax Credits, Medicaid, and Marketplace enrollment work for Illinois residents between 2026 and 2028. Here is every change in plain English, based on the latest Get Covered Illinois guidance.
Elimination of APTC repayment caps (2026). Beginning in 2026, repayment caps for excess APTC are eliminated. Previously, some enrollees who received too much APTC during the year had limits on how much they were required to repay when filing federal taxes. Under H.R.1, you will be required to repay the full amount of excess APTC if your final annual income is higher than projected. It is more important than ever to promptly report changes in income, household size, or tax filing status to the Marketplace throughout the year.
PTC eligibility changes for lawfully present immigrants (2026). Beginning in 2026, lawfully present immigrants with household incomes below 100% of the FPL who are subject to Medicaid waiting periods (the 5-year bar) will no longer qualify for Premium Tax Credits. Beginning January 1, 2027, PTCs will only be available to lawful permanent residents, certain Cuban and Haitian immigrants, and individuals lawfully residing in the United States under a Compact of Free Association (CoFA), if their income is at or above 100% of the FPL. These changes come from Public Law 119-21 (H.R.1), which also eliminates APTC eligibility for most other lawfully present immigrants, including refugees, people granted asylum, certain survivors of domestic violence, trafficking, or other crimes, and special immigrant juveniles. If you are affected, community resources such as federally qualified health centers, local health departments, and free clinics may be able to help.
No PTC through the income-based Special Enrollment Period (2026). Beginning in 2026, you will no longer be eligible to receive Premium Tax Credits through the income-based SEP pathway (previously known as the “150% SEP”). You may still qualify for a Special Enrollment Period through another Qualifying Life Event or an Illinois-specific SEP, so the best way to keep access to financial assistance is to enroll during Open Enrollment.
More changes are coming in 2027 and 2028, including further narrowing of noncitizen PTC eligibility, Medicaid work requirements, the end of automatic renewal of financial assistance, the end of APTC while eligibility is pending verification, and a 1-year Failure to Reconcile (FTR) rule. We will keep this page updated as Get Covered Illinois releases guidance.
Four Key Medicaid Eligibility Changes – January 2027
| Eligibility Impact Category | Impact Result |
|---|---|
| Non-citizen eligibility | Eliminates federal matching funds for certain immigrant categories that were previously eligible. |
| Work requirements | Adults covered under the ACA Medicaid expansion must meet work requirements or qualify for an exemption to remain eligible. |
| Retroactive coverage limits | Reduces medical coverage pre-enrollment from 3 months to a) one month for ACA adults and b) two months for other groups. Illinois will continue providing up to two months of retroactive coverage using state funds. |
| 6-month redeterminations | Eligibility for ACA adult groups is redetermined every six months instead of every twelve months. |
H.R.1 changes are likely to drive disenrollment and coverage gaps. The ACA adult coverage group is the most heavily impacted by the H.R.1 eligibility changes.
Key Points Regarding Non-citizen Eligibility
H.R.1 removes federal Medicaid match funding for a select group of non-citizens effective October 1, 2026. Non-citizens no longer receiving match include:
- Refugees/asylum seekers
- Trafficking victims, domestic violence victims, or humanitarian refugees residing in the US for 1+ years
- American Indians born in Canada
- Amerasian immigrants (US citizen father, Vietnamese mother from the Vietnam war)
- Aliens whose deportation is withheld
The legislation narrows the definition of “qualified immigrants,” meaning the non-citizens who are eligible for federally funded Medicaid benefits. Under these changes, eligibility is limited to lawful permanent residents, certain Cuban and Haitian immigrants, and individuals lawfully residing in the United States through a Compact of Free Association (CoFA). Coverage eligibility for pregnant individuals and children under CHIPRA 214 is not affected by these changes.
In addition, the federal matching rate (FMAP) for Emergency Medicaid services provided to non-citizens is capped at 50%. Beginning January 1, 2026, certain immigrant populations with incomes below 100% of the Federal Poverty Level (FPL) also became ineligible for Premium Tax Credits (PTCs) through the Marketplace.
Immigration Status and Medicaid
The qualifying immigration status for federally funded Medicaid is Lawful Permanent Resident (LPR, aka green card holder) for 5 years or longer.
Illinois also offers state-funded medical assistance programs that do NOT require an immigration status:
- All Kids (children)
- Moms & Babies (pregnant people and up to 12 months post-partum)
- Family Planning Program (Presumptive Eligibility only)
- Health Benefits for Immigrant Seniors (age 65+)
- Asylum Applicants and Torture Victims (AATV)
Immigration rules are complex and policies change. It is best to seek the advice of an immigration attorney or DOJ accredited representative for questions related to status.
Immigration Status and Marketplace (QHP) Coverage
To be eligible for Qualified Health Plan (QHP) coverage through Get Covered Illinois, non-citizens must have a lawfully present immigration status. Qualifying statuses include (non-exhaustive): lawful permanent residents (green card holders), lawful temporary residents, refugees, asylees, Cuban/Haitian entrants, individuals paroled into the U.S., Temporary Protected Status (TPS), withholding of deportation or removal, victims of trafficking (and their spouse, child, sibling, or parent), battered spouses, children, and parents, individuals with non-immigrant status (including worker and student visas, and citizens of Micronesia, the Marshall Islands, and Palau), members of a federally recognized Indian tribe or American Indians born in Canada, and residents of American Samoa.
DACA note: Under a federal rule finalized in June 2025, DACA recipients are no longer considered lawfully present and are not eligible to enroll in Qualified Health Plans starting Plan Year 2026 (they were eligible from November 1, 2024 through October 31, 2025).
Acceptable proof of lawful presence includes documents such as a Permanent Resident Card (I-551), Employment Authorization Card (EAD/I-766), Arrival/Departure Record (I-94/I-94A), an immigrant visa, foreign passport, refugee travel document (I-571), Notice of Action (I-797), certificates of eligibility for student (I-20) or exchange visitor (DS2019) status, an Alien Registration Number or I-94 number, or documentation of refugee, Cuban/Haitian entrant, or withholding-of-removal status. Documents must be valid and unexpired, match the name and date of birth on your application, and be clear and readable – otherwise you will receive a Data Matching Issue (DMI) notice with a 90-day Reasonable Opportunity Period to submit acceptable documentation.
Gained citizenship or lawful presence? You may qualify for a Special Enrollment Period if you newly became a U.S. citizen or U.S. national or gained lawfully present status. You pre-verify by uploading documentation showing the new status and the date it was gained, and coverage starts the first of the month following plan selection. You must be newly QHP-eligible – a change between eligible statuses (such as going from lawfully present to U.S. citizen) does not qualify.
Key Points Regarding H.R.1 Work Requirements
Individuals 19 and older in the ACA adult eligibility category are “applicable individuals” and are subject to work requirements and six-month redeterminations starting January 1, 2027.
- Some ACA adult groups must meet work or community engagement requirements to remain eligible for Medicaid.
- Compliance and exemptions are reviewed at both application and six-month redetermination.
- Illinois will verify compliance at application using the month before application, and at redetermination using one month during the review period.
- Individuals may meet requirements through one or multiple qualifying activities totaling at least 80 hours.
- You can work with your case worker to determine if you qualify for an exemption from work requirements.
Important notes: Individuals exempt from work requirements are still subject to six-month redeterminations. Individuals denied Medicaid for non-compliance are not eligible for Marketplace premium tax credits (PTCs) while otherwise Medicaid eligible. If an individual later becomes ineligible for Medicaid due to increased income, they may qualify for Marketplace PTCs.
Questions About How H.R.1 Affects Your Coverage?
These rules are complex and the details matter. Call us at 312.726.6565 and we will walk through your specific situation, or get a free quote online in minutes.