Quick Answer: If your Medicaid coverage was terminated during the post-pandemic unwinding, there is a strong chance you were removed for paperwork reasons rather than because you no longer qualify. You can appeal within 90 days of your termination notice, request a fair hearing, and in many cases get your coverage reinstated retroactively. As of 2026, federal rules still require states to fix wrongful terminations from the unwinding period.
More than 25 million people lost Medicaid coverage between April 2023 and mid-2025 as states resumed eligibility checks that had been paused during the COVID-19 public health emergency. According to KFF, roughly 69% of those disenrollments were procedural, meaning people lost coverage not because they were found ineligible but because of paperwork issues: outdated mailing addresses, unreturned renewal forms, or administrative errors on the state's end.
That means millions of people who still qualify for Medicaid are uninsured right now. If you are one of them, this guide explains exactly what to do in 2026.
Check your eligibility now at CoveredUSA. It takes 2 minutes.
What "Medicaid Unwinding" Means
During the pandemic, the federal government required states to keep everyone enrolled in Medicaid through the public health emergency. States could not disenroll anyone from April 2020 through March 2023. When the emergency ended, states had to work through a backlog of millions of redeterminations all at once. That process is called the "unwinding."
The scale was enormous. States had three years of renewals to process, contact information had gone stale, and many people did not even know their coverage was at risk. The result was widespread disenrollment, much of it improper.
Per Medicaid.gov, states were required to follow federal safeguards throughout this process, including conducting ex parte renewals (automatic renewals using data already on file) before sending out renewal paperwork. Many states did not do this correctly. In response, CMS ordered states to reinstate coverage for hundreds of thousands of people who had been improperly removed.
Who Was Wrongfully Terminated
Not every disenrollment was a mistake, but many were. Common reasons people were wrongfully terminated during unwinding include:
- The state sent a renewal notice to an old address and you never received it
- The state failed to conduct an ex parte review using existing data (tax records, Social Security data, etc.) before disenrolling you
- You returned your renewal forms but they were lost or processed incorrectly
- A family member was removed from your household case even though they still qualify
- Your income, household size, or other information was entered incorrectly
- You moved states during the unwinding period and fell through administrative gaps
According to a GAO report, in 28 states that failed to properly conduct ex parte reviews, roughly 420,000 children and adults lost coverage due to this specific error. All of them were reinstated once the issue was identified.
Your Rights Under Federal Law
Federal law gives Medicaid enrollees specific rights when coverage is terminated. Under 42 CFR Part 431 Subpart E, every state Medicaid agency must:
- Send you a written notice before terminating coverage that explains the reason
- Tell you about your right to appeal and how to request a fair hearing
- Allow you to request that your coverage continue while the appeal is pending (if you request a hearing within 10 days of the notice)
- Make a decision on your fair hearing within 90 days of receiving your request
If the fair hearing finds in your favor, the state must correct the action retroactively to the date the wrongful termination occurred. That means your medical bills from the period you were uninsured could be covered.
Step-by-Step: What to Do Right Now
Step 1: Confirm your termination date
Find the letter or notice your state Medicaid agency sent. It should include the date your coverage ended and the stated reason. If you never received a notice, contact your state Medicaid office directly. You can find your state's contact information at Medicaid.gov.
Step 2: Determine if you are still within 90 days
Most states give you 90 days from the date on the termination notice to request a fair hearing. Some states have shorter windows, down to 30 days. Act as fast as possible. If you are approaching the deadline, submit a written appeal request today even if you do not have all your documents ready yet.
Step 3: Request a fair hearing in writing
Contact your state Medicaid agency and submit a written request for a fair hearing. Include:
- Your full name and Medicaid ID number
- The date your coverage was terminated
- A statement that you believe the termination was incorrect
- A request that your coverage continue during the appeal process (if within 10 days of the notice date)
Most states accept fair hearing requests by mail, phone, fax, or through their online portal. Confirm the method and get documentation that your request was received.
Step 4: Gather your documents
Documents you will likely need:
- Government-issued photo ID (driver's license, passport, state ID)
- Proof of income (recent pay stubs, employer letter, tax return)
- Proof of household size (birth certificates, marriage certificate, utility bills)
- Proof of residency (lease, utility bill, bank statement with current address)
- Any prior Medicaid correspondence, renewal forms, or letters
- Documentation showing you meet current income limits
Step 5: Prepare your case
Review the specific reason your state gave for the termination. Common grounds for winning a fair hearing include:
- You never received the renewal notice (can be supported by evidence of address change or postal records)
- You submitted renewal documents but they were not processed
- Your income or household information was recorded incorrectly
- The state did not attempt an ex parte review before sending paperwork
Step 6: Attend the hearing
Fair hearings are typically conducted by phone or video. You can represent yourself. Legal aid organizations in your state may help you prepare for free. Find local legal aid at lawhelp.org.
Step 7: After the hearing
If you win, the state must reinstate your coverage and pay any claims from the period you were incorrectly uninsured. If you lose, you may be able to request judicial review.
What If the 90-Day Window Has Passed
Even if the appeal deadline has passed, you still have options:
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Reapply for Medicaid. You can apply for Medicaid at any time. If you still qualify, your new coverage can start as soon as the following month. Visit Healthcare.gov or your state Medicaid portal to reapply.
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Check the ACA Marketplace. If your income is above the Medicaid limit, you may qualify for subsidized coverage through the ACA Marketplace. A Special Enrollment Period may be available if you recently lost Medicaid. Income between 100% and 400% FPL (and beyond, depending on your state) may qualify for premium tax credits.
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Look for state-specific reinstatement programs. Some states created targeted reinstatement programs during the unwinding. Contact your state Medicaid agency to ask whether any of these still apply.
Use the CoveredUSA eligibility screener at /screener to check whether you qualify for Medicaid, ACA coverage, or other programs based on your current income and household situation.
2026 Medicaid Income Limits (National Medicaid Expansion)
The 40 states (plus DC) that expanded Medicaid under the ACA cover adults with incomes up to 138% of the Federal Poverty Level (FPL). The 2026 income thresholds are based on the federal poverty guidelines published by ASPE at HHS.
National Medicaid Expansion Income Limits, 2026
| Household Size | Annual Income Limit (138% FPL) | Monthly Income Limit |
|---|
| 1 | $22,025 | $1,835 |
| 2 | $29,863 | $2,489 |
| 3 | $37,702 | $3,142 |
| 4 | $45,540 | $3,795 |
| 5 | $53,378 | $4,448 |
| 6 | $61,217 | $5,101 |
| 7 | $69,055 | $5,755 |
| 8 | $76,894 | $6,408 |
| Each additional | +$7,838 | +$653 |
Income limits apply in Medicaid expansion states. Non-expansion states have significantly lower thresholds and cover primarily children, pregnant women, and individuals with disabilities.
If you live in a non-expansion state and your income falls between 100% and 138% FPL, you likely qualify for ACA Marketplace subsidies instead. See the full list of Medicaid income limits by state at CoveredUSA.
Common Reasons Fair Hearing Appeals Are Won
Based on federal guidance from CMS and documented patterns from the unwinding period, the following arguments have a strong track record at fair hearings:
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No notice received. If the termination notice was sent to a wrong address, many states consider this sufficient grounds to reinstate coverage from the termination date.
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Procedural error. If the state skipped the ex parte review step and went straight to paperwork-based disenrollment, federal rules require reinstatement.
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Income miscalculation. If income was counted incorrectly (for example, unemployment benefits counted after they ended, or a household member's income incorrectly attributed to you), correcting the record can reverse the termination.
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Returned forms not processed. If you have evidence you submitted your renewal (confirmation numbers, certified mail receipts, call logs), and the state claims no form was received, this is grounds to appeal.
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Children removed due to household case error. Children often have lower income thresholds than adults. If a child was removed from your case along with an ineligible adult, that removal may be incorrect.
Common Reasons Appeals Are Denied
- You did not request the hearing within the state's deadline
- You do not currently meet Medicaid income or eligibility requirements
- You failed to appear at the scheduled hearing
- You could not document that you submitted renewal paperwork
What Happens to Medical Bills from the Gap Period
If your termination is reversed through a fair hearing, the state must pay claims for covered services you received during the period you were incorrectly uninsured. Contact the providers directly, explain that your Medicaid was reinstated retroactively, and ask them to resubmit the claims.
If the retroactive period cannot be established (for example, because you are outside the appeal window), you may still be able to negotiate with providers directly. Many hospitals have charity care programs that can reduce or eliminate bills. See Medicaid.gov for additional guidance on billing disputes.
How to Apply or Reapply for Medicaid in 2026
If you are reapplying rather than appealing:
- Go to your state's Medicaid portal or Healthcare.gov to start a new application
- Gather your income documents, proof of identity, and proof of residency
- List all household members and their income accurately
- Submit the application online, by phone, by mail, or in person at a local DHS or social services office
- You should receive a decision within 45 days (90 days for disability-based cases)
- If approved, coverage can start as soon as the first day of the month following your application in most states
If you are unsure whether you qualify before applying, check your eligibility at CoveredUSA. The screener takes about 2 minutes and covers Medicaid, ACA plans, CHIP, Medicare, and other programs.
Frequently Asked Questions
What is Medicaid unwinding?
Medicaid unwinding refers to the process that began in April 2023 when states resumed checking whether current enrollees still qualified for coverage. During the COVID-19 pandemic, a federal rule prevented states from disenrolling anyone from Medicaid. When that rule ended, states had to review the eligibility of all enrollees, leading to mass disenrollments nationwide. As of 2026, more than 25 million people lost coverage through this process.
How do I know if I was wrongfully terminated from Medicaid?
If you lost coverage during the unwinding period (April 2023 through 2025) and your income and household situation did not change significantly, there is a good chance your disenrollment was procedural rather than based on an actual eligibility review. The clearest signs include: you never received a renewal notice, you submitted renewal paperwork but were still disenrolled, or your termination notice cited failure to respond to a notice you never received.
How long do I have to appeal a Medicaid termination?
Most states allow 90 days from the date on your termination notice. Some states have shorter windows of 30 to 60 days. Check your notice for the specific deadline and contact your state Medicaid agency if you are unsure. Acting quickly is important because once the appeal window closes, your options become more limited.
Can I keep my Medicaid while the appeal is pending?
Yes, if you request a fair hearing within 10 days of the date on your termination notice, federal rules require the state to continue your coverage while the appeal is pending. If you request the hearing between 11 and 90 days after the notice, your coverage may already be terminated before the hearing takes place. In that case, if you win, the state must pay claims retroactively.
What happens if I win my fair hearing?
If the hearing decision is in your favor, the state Medicaid agency must reinstate your coverage and implement the decision retroactively to the date of the wrongful termination. This means the state should pay for covered medical services you received during the gap period. Providers may need to resubmit claims after your coverage is reinstated.
What if I no longer qualify for Medicaid?
If you have been determined ineligible for Medicaid, you may still be able to get coverage through the ACA Marketplace. Losing Medicaid triggers a Special Enrollment Period that typically lasts 60 days. During that window you can enroll in a Marketplace plan regardless of the annual open enrollment schedule. Depending on your income, you may qualify for premium tax credits that significantly reduce your monthly cost.
Does the Medicaid unwinding affect children differently than adults?
Yes. Children often qualify at higher income thresholds than adults (up to 200% to 300% FPL in many states through CHIP), and federal rules give extra protections for children's coverage. If a child in your household lost coverage during the unwinding, especially due to an error on the household adult's case, that removal is worth appealing separately. Contact your state Medicaid agency and ask specifically about CHIP reinstatement for children.
Who can help me appeal my Medicaid termination for free?
Several free resources can help. Legal aid organizations in your state often assist with Medicaid appeals at no cost. Search lawhelp.org by state. Your state's Medicaid agency must also provide information about the fair hearing process. Community health centers and patient advocacy organizations sometimes have enrollment assistors who can help prepare your case.
Are more Medicaid disenrollments expected in 2026?
Yes. Federal legislation under consideration in 2026 includes work requirements and more frequent eligibility checks for certain adults. The Congressional Budget Office and KFF have projected that millions more could lose coverage if these policies take effect. Staying current on your state's Medicaid renewal requirements and keeping your contact information up to date with your state agency are the most important steps you can take now.
