Federal health officials have ordered states to step up checks on the immigration and citizenship status of Medicaid and CHIP enrollees, adding a new layer of monthly scrutiny that could lead to disenrollment for people who cannot confirm eligibility.
On August 20, 2025, the Centers for Medicare & Medicaid Services (CMS) said it will send states monthly enrollment reports listing individuals whose status could not be confirmed through federal databases, including the Department of Homeland Security’s SAVE system. States must verify those cases, request documents when needed, and take “appropriate actions,” including ending coverage if eligibility cannot be confirmed. CMS said all states should receive the first round of reports by mid-September 2025. Official details are expected to post on the CMS website at https://www.cms.gov.
CMS Administrator Dr. Mehmet Oz said in a statement, “Every dollar misspent is a dollar taken away from an eligible, vulnerable individual in need of Medicaid and CHIP.” While the agency framed the move as program integrity work, immigrant advocates warn it will sweep in many people who are eligible but face paperwork hurdles or database errors.
Background on eligibility and prior checks
– Traditional Medicaid and CHIP rules exclude undocumented immigrants from federally funded full coverage.
– Some lawfully present immigrants qualify, but many face a five-year waiting period after obtaining qualified status; some states waive that wait for children and pregnant people.
– States have long checked immigration and citizenship status at application and renewal, often using the Social Security Administration and DHS’s SAVE system.
– What is new is the pace and scope: instead of checking at set times, states will now act on federal lists every month, creating ongoing, repeated reviews tied to immigration and citizenship status.
Implementation and timelines
CMS outlined a multi-step process that applies once people appear on the monthly enrollment reports sent to states:
- Monthly flagging
- CMS uses federal data sources, including the DHS SAVE program, to flag enrollees whose immigration or citizenship information is not confirmed.
- States receive lists and must start case reviews promptly.
- State review and document requests
- States must recheck data, contact enrollees, and request proof as needed.
- Typical documents may include proof of citizenship or lawful presence, as allowed under existing Medicaid rules.
- Reasonable opportunity period
- If status cannot be confirmed right away, states must provide a 90‑day “reasonable opportunity period” for the person to submit documents or correct information.
- Disenrollment window
- If eligibility is still not confirmed after that period, states must terminate coverage within 30 days of the ineligibility decision.
- Appeals
- People who lose coverage can request a fair hearing.
- Benefits do not continue during the appeal unless eligibility is restored.
- Annual redetermination
- States may also recheck status during yearly renewals, especially for immigrant children and pregnant people with less than five years of lawful residence.
Oversight and schedule
– The Department of Health and Human Services is overseeing the rollout.
– CMS says the first lists will reach all state Medicaid agencies by mid‑September 2025, with ongoing reports each month after that.
Key process takeaway: expect a state notice, then a 90‑day window to submit proof, and a possible 30‑day disenrollment timeline if eligibility remains unconfirmed.
Impacts and disputes
Political and policy context
– The policy shift arrives as President Trump pursues tighter benefit eligibility rules for immigrants.
– A July 2025 Department of Justice order narrowed exemptions for some humanitarian programs, a move advocates say could ripple into health coverage access.
Supporters’ arguments
– Regular status checks will trim improper payments and guard funds for people who meet the rules.
– Supporters note these are long‑standing federal verification rules made more frequent to improve program accuracy.
Critics’ concerns
– Critics say the move targets a problem that data does not support.
– The administration has claimed up to 1.4 million “illegal immigrants” could be dropped from Medicaid; Georgetown University researchers call that figure “unequivocally false.”
– From 2017 to 2023, Emergency Medicaid for undocumented patients made up less than 1% of total Medicaid spending, according to analyses cited by health policy experts.
Administrative burden and chilling effects
– Advocates warn monthly checks will create heavy administrative work for states and churn for families.
– Issues that can cause coverage loss:
– Complex paperwork that does not match database fields.
– Mixed‑status families’ fear of immigration checks, even when the enrollee is a U.S. citizen child.
– Notices sent to an old address, wrong language, or mismatches in names/dates.
– VisaVerge.com reports these pitfalls disproportionately affect people with limited English or those working multiple jobs, who may struggle to reply within short timeframes.
State budget and program impacts
– States must review cases every month, make repeated outreach attempts, and track thousands of 90‑day clocks.
– Some states are already narrowing safety‑net programs. Example:
– Illinois scaled back state‑funded coverage for some noncitizen adults because of costs, reducing options for people who do not qualify for federal Medicaid.
What does not change
– Emergency Medicaid remains in place for undocumented patients facing life‑threatening conditions or childbirth; it does not cover ongoing care, medicines, or routine visits.
– The new checks do not expand access to full Medicaid for undocumented immigrants, nor create new pathways to coverage.
– Core eligibility rules—such as the five‑year bar for many lawfully present adults and the exclusion of undocumented immigrants from full‑scope Medicaid—remain the same.
– The major change is the new, ongoing, monthly enrollment reports that keep cases under constant review.
What to watch through the fall
Rollout timing
– The rollout starts in late August and September 2025.
– States will receive the first CMS lists by mid‑September 2025 and then each month.
Expected variation by state
– Implementation will be uneven:
– States decide how to sequence reviews, which notices to send, and how to staff extra work.
– Some may prioritize children or people with pending documents; others may triage by data‑match rates.
Legal and administrative developments
– Legal challenges are likely. Advocates may argue that aggressive timelines or error‑prone data matching push eligible people off coverage without adequate chance to fix mistakes.
– Federal agencies could issue more guidance on:
– Notice language and translation requirements.
– Handling data mismatches and identity verification problems.
– The Justice Department’s July 2025 order tightening humanitarian exceptions could trigger additional rulemaking affecting edge cases.
Practical reminders for families
– If you get a notice from your state:
1. Read it carefully and note deadlines.
2. Gather proof of citizenship or lawful presence as requested.
3. Use the 90‑day window to submit documents or correct information.
4. If coverage ends, you can request a fair hearing—understand that coverage typically does not continue during the appeal unless eligibility is restored.
Final note
– The rule change increases the frequency of checks (monthly reports) rather than altering who is eligible under existing law. The new process aims to improve program integrity, but advocates warn it could produce coverage losses for eligible people because of database errors, notice issues, and administrative burdens.
This Article in a Nutshell
CMS ordered monthly checks of Medicaid and CHIP enrollees starting August 20, 2025, flagging unconfirmed immigration status. States must review, request proof, offer a 90-day opportunity, and can terminate coverage within 30 days thereafter. Advocates warn database errors and paperwork barriers could wrongly disenroll eligible people nationwide.
