Virginia’s Insurance Marketplace will see key changes in the coming months and years. Many of these changes are required by new federal laws.
Non-Citizen Eligibility Changes- Part 1
(effective January 1st, 2026)
People ineligible for Medicaid because of their immigration status and who earn UNDER 100% of the Federal Poverty Level (FPL) cannot get an Advance Premium Tax Credit (APTC). These consumers were renewed for plan year 2026. They did not receive a tax credit but can still buy Marketplace coverage at full price.
Non-Citizen Eligibility Changes – Part 2 (Medicaid)
(effective October 1, 2026)
Federally required changes to noncitizen eligibility for Medicaid will start October 1, 2026. Once the changes are made, non-pregnant adults with certain immigration statuses will no longer be eligible for full-benefit Medicaid. Only adults who are a U.S. citizen, U.S. national, Legal Permanent Resident, Cuban-Haitian Entrant or Compact of Free Association Migrant will remain eligible for full-benefit Medicaid.
The new law does not change Virginia Medicaid or FAMIS eligibility rules for noncitizen children or pregnant individuals. Legally residing children, those with a current visa or status, can keep getting Medicaid and FAMIS. They just need to meet other eligibility rules, like income. Pregnant non-citizens can get coverage if they have qualifying incomes, no matter their immigration status.
For more information: Information for Noncitizens
Shorter Open Enrollment
(effective Nov 1, 2026)
Open Enrollment will begin November 1, 2026, and will end on January 29, 2027.
Non-Citizen Eligibility Changes – Part 3
(effective January 1, 2027)
Changes to noncitizen eligibility for federal Marketplace tax credits (APTC/PTC) and cost sharing reductions (CSRs) will start on January 1, 2027. Starting with Plan Year 2027 Open Enrollment, only U.S. citizens, U.S. nationals, and non-citizens with these status types can get APTC and CSR:
- Lawful Permanent Residents (LPRs/green card holders)
- Cuban/Haitian Entrants
- COFA Migrants
Other types of non-citizens won't qualify for the Advance Premium Tax Credit (APTC). These consumers will be renewed for plan year 2027, but without a tax credit. All current “lawfully present” statuses can still get Marketplace QHP coverage and may qualify for additional Virginia Premium Savings to reduce their monthly costs.
Work and Community Engagement Requirements - Medicaid
(effective January 1, 2027)
Beginning January 2027, a new federal law will require some adults to work or participate in activities. These activities can include volunteering or education for at least 80 hours each month. If they do not meet this requirement, they won’t qualify for Medicaid expansion coverage, unless they are exempt. These adults will have their coverage reviewed every 6 months, not 12 months. In addition, failing to report work will make you ineligible for an Advance Premium Tax Credit (APTC).
Federal Work Requirements apply only to adults in Medicaid Expansion. Medicaid Expansion covers adults who are between 19 and 64, have income under 138% of the federal poverty limit (FPL), and do not have Medicare. The new requirements DO NOT apply to other types of Medicaid, such as coverage for children, pregnant and postpartum individuals, or adults with a disability or over age 64.
For more information: Work & Community Engagement Requirement FAQs
Medicaid (General Changes)
(effective January 1, 2027)
Starting January 2027, a new federal law will require states to check Medicaid Expansion members' eligibility every 6 months. This replaces the previous review period of 12 months during the Medicaid renewal process.
Who does this change apply to? This change applies only to Medicaid Expansion members. Medicaid Expansion covers adults aged 19 to 64. They must have an income below 138% of the federal poverty level (FPL) and cannot qualify for Medicare. Most Medicaid-covered adults in this age range are in Medicaid Expansion.
For more information: Six-Month Eligibility Renewals for Certain Adults
Eligibility Verification
(effective January 1, 2028)
Beginning in plan year 2028, consumers must show they qualify for financial help to get an Advance Premium Tax Credit (APTC). Financial help will not be applied while information is being reviewed. If there's a data matching issue, consumers can enroll in a full-priced plan. The tax credit will be backdated once the verification is complete. The only exception is a Special Enrollment Period for a change in family size.
Consumers will need to confirm or update their information in order to be automatically re-enrolled with financial help for the 2028 plan year. Virginia’s Insurance Marketplace will provide more information and consumer guidance on the 2028 redetermination and renewal process in the near future.