Two cost shocks, not one: what already changed in 2026, and what changes on January 1, 2027

The short answer

Coverage news is usually reported as one event. For immigrant households it is not one event — it is a sequence, and the parts landed on different dates for different reasons.

Wave one is already in force. Enhanced pandemic-era subsidies expired at the end of 2025, so monthly amounts rose for most enrollees. Separately, from the 2026 tax year, lawfully present people with income under 100% of the federal poverty level who cannot get Medicaid because of their status no longer receive subsidies. And the caps that limited how much excess advance credit had to be repaid were removed starting with the 2026 tax year — which shows up when 2026 returns are filed in early 2027.

Wave two arrives January 1, 2027. Federal Marketplace subsidies become limited by immigration status: U.S. citizens, green card holders, certain Cuban and Haitian entrants, and COFA residents keep them. Everyone else with a lawful status keeps the right to buy a plan, without the subsidy.

Between the two, on October 1, 2026, federal matching funds for full Medicaid and CHIP narrow to the same short list of statuses.

What is NOT happening

• The 2027 change is not the first change. Treating it as the first is how households end up surprised twice — once by a 2026 bill they did not expect, and again by a 2027 eligibility letter.
• Nothing here ends the right to buy Marketplace coverage for lawfully present people. The plan remains purchasable at the full price.
• The 2027 restriction is not the same rule as the 2026 income-floor change, even though both remove subsidies. One is about income, the other is about status, and one household can be caught by both.
• These are not administrative rules that a future agency can simply rewrite. The dates and the status list come from statute; agency rules fill in the implementation.

Wave one — already in force

• Enhanced subsidies expired at the end of 2025. The larger credit amounts in place since 2021 lapsed, so what enrollees pay each month went up. This was an expiration, not a new restriction, and it applies regardless of immigration status.
• The income-floor rule, from the 2026 tax year. Section 71302 removed the special rule that allowed lawfully present people below 100% of the poverty level to get subsidies when their immigration status blocked them from Medicaid. This reaches green card holders in the five-year Medicaid wait too; it is covered on its own page here.
• Repayment caps removed, from the 2026 tax year. Section 71305 removed the limits on how much excess advance credit has to be repaid at tax time. This one is invisible during 2026 and appears when the 2026 return is filed in early 2027 — which is why keeping income and household size current on the Marketplace application matters more than it used to.

Wave two — January 1, 2027

• Section 71301 limits the premium tax credit and cost-sharing reductions to U.S. citizens and a short list of non-citizen categories, effective for plan years beginning on or after January 1, 2027.
• The categories that keep subsidy eligibility: lawful permanent residents (green card holders), certain Cuban and Haitian entrants, and people living in the U.S. under a Compact of Free Association.
• Statuses that lose subsidy eligibility include refugees and people granted asylum who do not yet hold a green card, TPS holders, humanitarian parolees including U4U, work-visa holders, and survivors of trafficking or domestic violence on T and U visas.
• Section 71109, effective October 1, 2026, narrows federal matching funds for full Medicaid and CHIP to the same short list. Emergency Medicaid remains available regardless of status, and states may run their own programs with their own money.

KFF has estimated that roughly 1.4 million lawfully present immigrants are expected to lose health coverage as a result of the 2025 law; CBO's estimates of Marketplace enrollment and federal spending move in the same direction. Estimates are projections, not counts, and different analysts model them differently.

Which wave touches whom

Most households contain more than one row. The 2027 change is applied person by person, not to the household as a whole.

✓ Public Law 119-21, §§71301, 71302, 71305 (statute text) · 2025 — reviewed 2026-08-10

The dates that matter

• December 31, 2025 — enhanced subsidies expired. Already passed.
• January 1, 2026 — the income-floor rule took effect for the 2026 tax year. Already in force.
• October 1, 2026 — federal matching for full Medicaid and CHIP narrows by status.
• November 1, 2026 – January 15, 2027 — open enrollment for 2027 plans on HealthCare.gov; several state marketplaces run longer, and a federal appeal could still shorten the end of the window. Enrolling by December 15, 2026 is what starts coverage January 1, 2027.
• January 1, 2027 — the status-based subsidy restriction takes effect.
• Early 2027 — 2026 tax returns are filed, and the removed repayment caps become visible for anyone whose income or household size changed during 2026.

✓ Public Law 119-21, §§71301, 71302, 71305 (statute text) · 2025 — reviewed 2026-08-10

What people typically look at

• Which of the changes have already touched them, since a bill that rose in 2026 is a different problem from an eligibility letter arriving for 2027.
• What the full, unsubsidized price of a comparable plan looks like — prices vary by state, age, and plan, and typically run as ranges, not one number.
• Whether income and household size on the Marketplace application are current, because the repayment caps that used to limit the damage are gone.
• Whether other coverage paths exist: a job-based plan, a spouse's plan, or state programs where they exist.
• What remains available if no plan is affordable — community health centers, hospital financial assistance, and emergency Medicaid exist regardless of coverage status. (Note: under a July 2025 federal notice, community health centers in some states may apply immigration-status restrictions; the notice is being challenged in court and applies differently by state — check with the center directly.)

You can see how these options map to your own situation, without entering your name or immigration details: [Open the Health Coverage Map →]

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This page explains federal rules in plain language. It is education, not a recommendation, and not legal or immigration advice.