By Stacey Pogue and Jalisa Clark
There is some misleading, and in some cases, flat-out false, information related to immigrant eligibility for health care coverage making the rounds as part of the debate related to the U.S. government shutdown that began on October 1, 2025. This blog post explains how immigration status affects access to Marketplace coverage and the recent federal changes that dismantle long-standing access to affordable Marketplace coverage for people who are lawfully present immigrants.
In short:
- People who are undocumented immigrants have never been eligible for federal subsidies to make Marketplace plans more affordable, and they are not even allowed to purchase plans on the federal Marketplace at full cost.
- People who are lawfully present immigrants, on the other hand, including “green card” holders and other people with permission to live and/or work in the U.S., were explicitly made eligible for Marketplace coverage and subsidies when the Affordable Care Act (ACA) passed in 2010 to help close long-standing gaps in access to coverage.
- Recent federal policy changes newly eliminate access to affordable Marketplace coverage for most categories of lawful immigrants, with changes phasing in between August 2025 and January 2027. An estimated 1.2 million people who are lawfully residing and/or working in the U.S. will lose Marketplace coverage due to these changes and become uninsured.
Background on immigrant eligibility for the ACA Marketplace
In 2023, there were approximately 47 million immigrants residing in the United States, 25 million of whom are naturalized U.S. citizens. Access to Marketplace coverage, or the lack of it, for the remaining 22 million people who are noncitizen immigrants is the focus of this blog post. Marketplace eligibility for noncitizen immigrants differs depending on whether a person is lawfully present—such as lawful permanent residents (also called LPRs or green card holders), immigrants granted humanitarian protections, and other noncitizen immigrants who have permission to live and/or work in the U.S.—or undocumented.
When passing the ACA, Congress purposely designed eligibility for Marketplace premium tax credits (PTCs, or financial assistance that reduces monthly premiums) to help rectify long-standing gaps in access to coverage for people who are lawfully present noncitizens. For decades, Medicaid has excluded many lawfully present immigrants entirely and made certain others eligible only after a five-year waiting period. The ACA helped fill these gaps by explicitly making immigrants who are lawfully present eligible to buy Marketplace coverage and providing PTCs for enrollees with lower incomes to make coverage more affordable. In general, the ACA does not allow PTCs for people with incomes below the poverty line ($15,650/year for an individual and $26,650/year for a family of three), but the ACA includes an explicit exception that makes lawful immigrants with incomes below the poverty line eligible for PTC if they are excluded from Medicaid because of their immigration status. Although Marketplace plans generally have higher out-of-pocket costs than Medicaid, which can create barriers for people at these very low income levels, premium tax credit enhancements available since 2021 have reduced premiums to few or even zero dollars for Marketplace enrollees with the lowest incomes, including for example, green card holders subject to Medicaid’s five-year waiting period.
In contrast, Congress did not provide coverage for undocumented immigrants in the ACA. Undocumented immigrants have never been eligible for federal PTCs, and they cannot even buy coverage in the federal Marketplace at full cost. (This exclusion is not unique to ACA coverage. Undocumented immigrants have also never been eligible for full Medicaid coverage and are excluded from other federal benefits their tax dollars help support.)
Recent and upcoming changes to Marketplace access for lawful immigrants
A series of federal ACA policy changes enacted in H.R. 1 in July 2025 and adopted in rule in June 2025 will dismantle access to affordable Marketplace coverage for many lawful immigrants. Changes include:
- Making recipients of Deferred Action for Childhood Arrivals (DACA) ineligible for Marketplace coverage and PTCs, effective August 25, 2025. This reverses an earlier rule that first extended eligibility for Marketplace coverage and PTCs to DACA recipients in November 2024;
- Eliminating PTC eligibility for lawfully present immigrants with incomes below the poverty line who are ineligible for Medicaid due to their immigration status, effective January 1, 2026; and
- Eliminating PTC eligibility for most categories of lawfully present immigrants, including refugees, people granted asylum, survivors of domestic violence and trafficking, and many others, effective January 1, 2027. The narrow categories of lawful immigrants who will remain eligible for Marketplace PTCs are: green card holders, certain Cuban and Haitian entrants, and people from Compact of Free Association (COFA) nations (Micronesia, the Marshall Islands, and Palau) living in the U.S.
With no federal assistance, Marketplace coverage will be largely unaffordable
For many lawfully residing immigrants, recent federal changes effectively eliminate any affordable pathway to comprehensive health coverage, reducing their access to health care and financial security.
Starting January 1, 2026, approximately 500,000 enrollees who are lawful immigrants with incomes below the poverty line will see their health insurance premiums increase astronomically when they lose eligibility for PTCs. This change will happen at the same time that premium tax credit enhancements are scheduled to expire. To understand how these two impending policy changes affect affordability on vastly different scales, consider how much more a current enrollee with income near the poverty line would have to pay to keep their coverage in January:
- If Congress allows PTC enhancements to expire, a Marketplace enrollee with income just above the poverty line ($15,650 for an individual) would see their out-of-pocket premiums rise from $0 to $332 per year starting in January.1
- But a lawful immigrant with income just below the poverty line who is losing all federal financial help will see their premiums skyrocket from $0 to $5,958 per year due to changes adopted in H.R.1.
As of January 1, 2027, many more lawful immigrants will see their premiums skyrocket when they lose PTC eligibility. This time, it will be lawful immigrants with incomes above the poverty line who are refugees, people granted asylum, survivors of domestic violence and trafficking, and other lawful immigrants who lose access PTCs that keep Marketplace coverage affordable.
Other than DACA recipients, lawfully residing immigrants discussed in this post will still be able buy Marketplace coverage at full cost as a technical matter, but insurance at full price is unlikely to be affordable to many people enrolled in the Marketplace. Affordability of health care and coverage is a significant challenge in the U.S., regardless of citizenship or immigration status. Nearly half of U.S. adults say it is difficult to afford health care costs, and 70 percent of Marketplace enrollees say that if their premiums doubled, they’d no longer be able to afford them without a significant disruption to their household finances. It would be particularly disingenuous to suggest that full-cost coverage is a viable option for the lawful immigrants with poverty-level wages who will lose PTC eligibility in January. Rather, many lawful immigrants will have no affordable options. The Congressional Budget Office estimates that 1.2 million people who are noncitizens lawfully residing or working in the U.S. will lose Marketplace coverage due to changes in H.R. 1 and become uninsured.
Immigrants will experience significant direct harm, though harms will be widespread
The anti-immigrant federal policies that eliminate PTCs for certain lawful immigrant groups create real and immediate harms. People who lose health insurance will be at risk of reduced access to care, poorer health care outcomes, and amassing medical debt. Individuals in the midst of receiving life-saving health care services and medications—mothers battling cancer, fathers managing diabetes—will soon lose the ability to afford the coverage that makes their care possible.
While these policies target immigrants, the interconnected nature of the U.S. health care system ensures that many Americans will feel the impacts. One likely outcome is higher premiums for all Marketplace enrollees. Lawful immigrants enrolled in the Marketplace tend to be younger and healthier than other enrollees, and their exit from the Marketplace is expected to increase premiums as the pool of people who remain covered becomes older and less healthy on average. A spike in the uninsured population will also strain hospitals and safety net health care providers, as well as states and communities that scramble to fill in the gaps. The loss of Marketplace coverage by lawful immigrants and other changes in H.R. 1 that will cause millions of others to lose health insurance are estimated to create $200 billion in uncompensated care costs over the next decade.
Looking ahead
Some states have implemented programs that try to fill in existing federal coverage gaps in Medicaid and the Marketplace by using state dollars to extend coverage to residents regardless of their immigration status, though a few have recently scaled back this coverage. As recently adopted federal policies phase in and more than one million lawful immigrants are newly excluded from affordable federal coverage programs that their tax dollars support, states can step in to help cover their residents, as New Mexico has and Connecticut may. But states that want to mitigate damage from H.R. 1 will be hard-pressed to do so. The staggering cuts to federal health care funding passed in H.R. 1—a $1 trillion cut that will cause 10 million people to lose health care coverage—extend well beyond lawful immigrant coverage, and no state is well-positioned to backfill the loss of federal funding at this scale.
