APA WF 26-03 HR1 Alien Eligibility
The proposed policy revisions align with eligibility changes included in H.R. 1, also referred to as the Working Families Tax Cut legislation. Beginning October 1, 2026, federal financial participation (FFP) will only be available for Medicaid benefits furnished to United States citizens, lawful permanent residents (LPRs), certain Cuban/Haitian entrants, and citizens of the Freely Associated States covered under the Compact of Free Association (COFA). Most other non-citizens will no longer qualify for full-scope coverage and will be limited to Emergency Medical Assistance.
Please view the draft regulatory text here and submit feedback via the comment box.
Circulation Date: 5/29/26
Comment Due Date: 6/13/26
Requested Effective Date: October 1, 2026 or upon gubernatorial approval.
Submit a Comment
After you submit your comment, you should be re-directed to a confirmation page. If you are not, please submit your comment through e-mail to federal.authorities@okhca.org.
Please note that all comments must be reviewed and approved prior to posting. Approved comments will be posted Monday through Friday between the hours of 7:30 a.m. – 4 p.m. Any comments received after 4 p.m. will be posted on the following business day.
Comments
Caley:
I submit these comments regarding the proposed revisions implementing federal eligibility changes contained in H.R. 1 affecting Medicaid coverage for non-citizens.
I recognize that OHCA is implementing federal requirements and that the agency's discretion may be limited. I also understand the importance of ensuring the long-term sustainability and responsible stewardship of public resources.
At the same time, these policies must acknowledge the contributions of noncitizens who are employed, paying taxes, pursuing education, and/or actively participating in their communities. As eligibility changes are implemented, I encourage policymakers to continue evaluating whether the criteria appropriately balance fiscal responsibility with the realities of those who contribute to and depend upon these systems.
I also believe that no person should be denied access to necessary healthcare services solely because of immigration status. Delays in treatment often lead to worsening health conditions, greater reliance on emergency services, and increased costs to the healthcare system over time.
Many individuals affected by these changes represent particularly vulnerable populations, including those with histories of trauma, displacement, instability, or significant healthcare needs. From a trauma-informed perspective, abrupt disruptions in access to healthcare may exacerbate distress, increase barriers to seeking help, and contribute to further psychological harm. Thoughtful implementation strategies that emphasize clear communication, continuity of care, and connection to available resources can help mitigate these risks.
As a licensed psychologist, I encourage OHCA to prioritize transparency, effective referral pathways, and compassionate implementation practices that preserve dignity while carrying out federal requirements.
