Undocumented Access in Federal

The state immigrant-coverage rollback is now a national wave: Minnesota and Illinois ended programs, Washington froze, DC is phasing out, Colorado capped — and California's freeze fits the pattern

What looked like isolated state decisions is now a coherent national retreat from state-funded immigrant health coverage, driven by H.R. 1 fiscal pressure and the threat of FMAP penalties for states covering barred populations. The inventory: Minnesota ended MinnesotaCare for undocumented adults January 1, 2026 (~57,000 people); Illinois ended HBIA (ages 42-64, ~30,000) in July 2025 and capped its seniors program; Washington's Apple Health Expansion hit its 13,000 cap and froze in December 2025; DC blocks Healthcare Alliance re-enrollment for adults 26+ and eliminates eligibility for 21+ by FY2028 (~26,000 covered, ~$12.4M/yr FQHC revenue); Colorado capped Cover All Coloradans at 25,000 children and slashed OmniSalud from ~12,000 to ~6,700 subsidized adults; and California froze new Medi-Cal enrollment for undocumented adults in January 2026 with the dental benefit ending July 1. Oregon's Healthier Oregon (100,000+ covered) survives but faces a ~$400M/yr federal penalty risk. Only a handful of states — MA, CT, RI, NM — are holding. For health centers the pattern is the point: these patients don't disappear, they reappear as self-pay sliding-fee visits, and the centers with the largest immigrant panels take the revenue hit in proportion to their mission.

H.R. 1 Ends Federal Medicaid Match for Asylees, Refugees, and DACA Recipients — October 1, 2026

The House-passed reconciliation bill eliminates the federal financial participation (FFP) match for 'lawfully present' immigrants — including DACA recipients, asylees, and refugees — effective October 1, 2026. This is distinct from existing restrictions on undocumented immigrants: these populations currently receive full federal Medicaid matching funds. California FQHCs serving significant DACA and refugee populations (particularly in LA, San Diego, Central Valley) will face acute revenue loss when federal reimbursement disappears for this group — even if California chooses to continue state-only funding.

A Quieter H.R. 1 Cliff: ~100,000 Lawfully Present Immigrants — Including Seniors Who Paid In for Decades — Lose Medicare on January 4, 2027, and California Has the Most

Beneath the Medi-Cal cuts sits a separate, less-discussed H.R. 1 provision: the law bars Medicare eligibility for several lawfully present immigrant categories — refugees, asylees, people with Temporary Protected Status, survivors of domestic violence and trafficking, and certain work-visa holders. KFF estimates ~100,000 people lose Medicare specifically (and ~1.4M lawfully present immigrants lose health coverage overall), with current enrollees disenrolled January 4, 2027 — squarely in the December 2026–January 2027 cliff window. California, home to the largest population of immigrant seniors, is the most exposed, and the state has proposed NOT backfilling ~200,000 affected residents with state coverage, citing a ~$1.1B annual price tag. The bitter irony: undocumented and lawfully present immigrants paid an estimated $6.4B into Medicare and $25.7B into Social Security in 2022 alone. For FQHCs this is distinct from the Medi-Cal UIS freeze and the July 1 dental cut — it converts a population of insured, often-elderly patients into uninsured/self-pay starting in January, on top of the GWU Geiger Gibson finding that ~3.4M Medicare patients already rely on community health centers (2-in-5 of them dual-eligible). FQHC finance and enrollment teams should flag affected patients now and model the Medicare-side revenue loss alongside the Medicaid cliffs.

FQHCs Exempt from New $35 Medicaid Copays — Competitive Advantage

Under H.R. 1, states can impose up to $35 copays on Medicaid visits — but FQHCs are exempt by statute. This creates a significant competitive advantage: patients will face copays at hospitals and private clinics but not at FQHCs. Health centers should proactively market this exemption to attract and retain patients.