Health Insurance for Undocumented Immigrants in 2026

Option 1: California Medi-Cal (Existing Enrollees Only as of 2026)

California Medi-Cal was the most expansive state health coverage program for undocumented immigrants in the U.S. before January 1, 2026. From 2016 through 2022, California extended Medi-Cal to undocumented children, then to adults under 26, then to adults over 50, and finally to all undocumented adults regardless of age beginning January 1, 2024. That full-scope enrollment froze on January 1, 2026, as part of the 2025-26 California state budget. Undocumented adults who were enrolled in full-scope Medi-Cal before the freeze may keep their coverage as long as they complete their annual renewal. New undocumented adult applicants can no longer enroll in full-scope Medi-Cal as of that date.

Additional 2026 changes for undocumented enrollees in Medi-Cal: routine dental benefits end for adult Medi-Cal members without satisfactory immigration status starting July 1, 2026 (emergency dental remains covered). Starting July 1, 2027, members ages 19 to 59 without satisfactory immigration status will owe a $30 per month premium to keep full-scope coverage; failure to pay drops coverage to emergency and pregnancy services only. Pregnant undocumented immigrants and undocumented children ages 0 to 18 remain eligible for full-scope Medi-Cal without the freeze applying to them. Apply or renew through BenefitsCal at benefits.ca.gov or call 1-800-541-5555. Income eligibility follows standard Medi-Cal at 138% FPL (income at or below $22,025 for a single person in 2026).

Option 2: Oregon Health Plan (OHP): Healthier Oregon, All Ages and Statuses

Oregon's Healthier Oregon program, which took full effect on July 1, 2023, is the most inclusive state health coverage program for undocumented immigrants in the United States as of 2026. Undocumented immigrants of any age who live in Oregon and whose household income is at or below 138% of the Federal Poverty Level ($22,025 for a single person, $45,540 for a household of four in 2026) can enroll in full Oregon Health Plan benefits through the Oregon Health Plan (OHP). Unlike California, Oregon did not impose a 2026 enrollment freeze, and no premium is required at or below the income threshold. Coverage includes primary care, specialist visits, behavioral health, dental, vision, prescription drugs, and long-term support services. OHP does not count as a public charge factor and does not affect immigration status.

Undocumented immigrants in Oregon apply through the Oregon ONE system at one.oregon.gov or by calling OHP Customer Service at 1-800-699-9075. Spanish-language enrollment assistance is available. Children in families earning above 138% FPL may qualify for OHP through the children's expanded threshold (up to 305% FPL for children). Enrollment in OHP is year-round; no special enrollment period is required because Medicaid has no open enrollment window. Oregon's program covers non-citizens regardless of whether they are DACA recipients, asylum seekers, Temporary Protected Status holders, or fully undocumented individuals.

Option 3: New York State-Funded Medicaid for Undocumented Seniors (65+)

New York State extended full-scope Medicaid to undocumented immigrants age 65 and older effective January 1, 2024, using state funds outside the federal Medicaid matching structure. In 2026 this program continues and is not subject to the federal H.R.1 Medicaid cuts because it is state-funded. Undocumented seniors in New York who meet standard Medicaid income thresholds (at or below 138% FPL, which is $22,025 for a single person and $45,540 for a household of four in 2026) can enroll in mainstream Medicaid managed care plans covering preventive care, primary care, specialist visits, prescriptions, and long-term care services including home care. Undocumented pregnant individuals in New York continue to be eligible for full Medicaid coverage under a separate pregnancy-coverage rule. For working-age undocumented adults in New York (ages 19 to 64 and not pregnant), the main fallback remains Emergency Medicaid plus community health centers.

Undocumented seniors in New York apply through their local Department of Social Services or, in New York City, through the NYC Human Resources Administration. NY State of Health (the state marketplace at nystateofhealth.ny.gov) provides application assistance for this population. For the working-age undocumented population in New York who are not pregnant and under 65, the New York City Health and Hospitals network (NYC Health + Hospitals) runs MetroPlus and NYC Care, which provide subsidized primary care to low-income uninsured residents regardless of immigration status and are not subject to federal immigration status rules.

Option 4: Emergency Medicaid and EMTALA Rights (Nationwide)

Emergency Medicaid is a federal program that reimburses hospitals for the cost of stabilizing patients who meet all standard Medicaid eligibility criteria except immigration status. In all 50 states, an income-eligible undocumented immigrant who presents with a life-threatening emergency condition will receive hospital stabilization covered under Emergency Medicaid. The Emergency Medical Treatment and Labor Act (EMTALA) separately requires every Medicare-participating hospital with an emergency department to screen and stabilize any patient with an emergency medical condition regardless of immigration status or ability to pay. EMTALA applies to all 6,100-plus emergency departments in the country and cannot be waived by hospital policy.

Emergency Medicaid covers only the acute stabilization episode, not ongoing care, specialist follow-up, or prescription drugs. Once stabilized and discharged, an undocumented immigrant has no federally guaranteed continued coverage. Starting October 1, 2026, H.R.1 (the 2025 reconciliation law) reduces the federal matching payment (FMAP) for Emergency Medicaid from 90% to 50% for expanded-Medicaid-eligible individuals, shifting more cost to states. This may lead some states to narrow Emergency Medicaid scope after October 2026, but all states must maintain at minimum the EMTALA-required stabilization mandate regardless of matching payment levels. Applying for Emergency Medicaid does not trigger a public charge consequence and does not expose any household member to immigration enforcement.

Option 5: Federally Qualified Health Centers (FQHCs): Sliding Scale Nationwide

Federally Qualified Health Centers (FQHCs) are community health organizations funded under Section 330 of the Public Health Service Act to serve medically underserved areas and populations. Approximately 1,400 FQHC organizations operate at nearly 15,000 locations across all 50 states and U.S. territories. FQHCs are required to offer a sliding fee scale based on income and cannot turn away patients due to inability to pay. Many FQHCs serve large immigrant populations and provide care regardless of immigration status. In 2026, undocumented immigrants who cannot access state Medicaid programs can use FQHCs for primary care, preventive screenings, prenatal care, behavioral health, and dental services at costs based on household income.

Note: Federal policy changes in 2025-2026 created ambiguity about whether Section 330 grant funds can be used for non-qualified alien patients in non-emergency, non-immunization contexts. The HRSA guidance from 2025 clarifies that emergency medical care, immunizations, and communicable disease testing and treatment remain covered for all patients under Section 330 funding, while routine primary care for undocumented individuals may be funded through non-federal sources at many FQHCs. Contact your local FQHC directly to confirm current service availability. Use the HRSA Find a Health Center tool at findahealthcenter.hrsa.gov to locate the nearest FQHC. FQHCs in California, New York, Illinois, and Oregon have historically served the largest undocumented immigrant populations and have alternative funding arrangements to fill gaps.

State programs for undocumented immigrants in 2026: CA, NY, IL, and OR compared

No two states took the same path in 2026 on coverage for undocumented immigrants and mixed-status households. California's Medi-Cal reached the widest coverage in 2024 but froze new enrollment for adults on January 1, 2026, under budget pressure estimated to save $3.3 billion annually by 2028-29. Oregon's OHP Healthier Oregon program, by contrast, added no new restrictions in 2026 and remains fully open to all ages and immigration statuses at or below 138% of the Federal Poverty Level. New York built a state-funded Medicaid program for undocumented seniors age 65 and older starting January 1, 2024, which continues in 2026. Illinois eliminated its Health Benefits for Immigrant Adults (HBIA) program for ages 42 to 64 effective July 1, 2025, due to state budget constraints, leaving Emergency Medicaid and FQHCs as the main options for working-age undocumented adults in Illinois.

Income eligibility lookup for Oregon OHP and state Medicaid programs in 2026

Oregon's OHP Healthier Oregon and the New York state-funded Medicaid for seniors both use 138% of the Federal Poverty Level (FPL) as the income threshold, the same as standard ACA Medicaid expansion. The 2026 FPL guidelines (published by HHS ASPE in January 2026) set the per-person increment at $5,680 for the 48 contiguous states and D.C. The table below shows the 138% FPL threshold by household size for 2026. Undocumented immigrants applying for OHP or the New York senior program must have household income at or below the applicable threshold. Income includes wages, self-employment earnings, rental income, and most government payments; it excludes child support received, foster care payments, and Supplemental Security Income.

No access to ACA plans or Premium Tax Credits: what that means for undocumented immigrants in 2026

Federal law (ACA Section 1312(f)(3)) bars undocumented immigrants from purchasing health coverage through ACA Marketplace plans and from receiving the Premium Tax Credit (PTC). This bar applies even if the person's income would otherwise qualify for a subsidy. The 2026 return of the subsidy cliff (enhanced PTCs from ARPA and the Inflation Reduction Act expired January 1, 2026) makes ACA Marketplace plans more expensive for citizens and lawfully present immigrants, but that pricing shift is irrelevant for undocumented immigrants because they cannot access the marketplace at all, regardless of income level. Form 7206 (the self-employed health insurance deduction) is also not applicable to undocumented immigrants because they are not permitted to deduct premiums against income reported on federal tax returns in the context of marketplace plans, and they cannot purchase the qualifying plans that Form 7206 supports. Health Savings Accounts (HSA) paired with High-Deductible Health Plans (HDHP) are similarly inaccessible because HSA-eligible HDHP plans are purchased on the ACA Marketplace or through employer sponsors, neither of which is available to undocumented immigrants. Flexible Spending Accounts (FSA) are employer-only and not available to undocumented immigrants who are typically not on formal W-2 payroll.

Mixed-status families where some members ARE lawfully present (U.S.-born children, DACA recipients with valid status, TPS holders, lawful permanent residents) face a split situation. Lawfully present members of the household can purchase ACA Marketplace plans and may qualify for Premium Tax Credits based on household MAGI. The undocumented members of the same household cannot. For 2026 PTC calculation purposes, the household income of all members is counted, but only lawfully present members' coverage needs are included in the tax credit computation. Section 1095-A, the IRS form that marketplace enrollees receive and use to reconcile premium tax credits on Form 8962, applies only to lawfully present family members who enrolled through the marketplace.

HSA and FSA access for undocumented immigrants in 2026

Health Savings Accounts (HSA) are not available to undocumented immigrants as a practical matter in 2026. HSA eligibility requires enrollment in an HSA-qualified High-Deductible Health Plan (HDHP), defined by the IRS as a plan with a minimum deductible of $1,700 for self-only coverage or $3,400 for family coverage in 2026 (per IRS Rev. Proc. 2025-19). HSA-qualified HDHPs are purchased through the ACA Marketplace or through employer-sponsored group plans. Because undocumented immigrants cannot access either the ACA Marketplace or most formal employer-sponsored plans, the HSA pathway is inaccessible for most undocumented immigrants in practice. The 2026 HSA contribution limits ($4,400 self-only / $8,750 family / $1,000 catch-up for ages 55 and older) and the triple tax advantage (tax-deductible contribution, tax-free growth, tax-free qualified medical withdrawals) that make HSAs valuable for other populations are therefore not available to undocumented immigrants.

Flexible Spending Accounts (FSA) are employer-only benefits available through formal W-2 employment. Undocumented immigrants who work in the informal economy or in cash-wage arrangements outside formal payroll typically have no access to FSA accounts. Even undocumented immigrants in formal W-2 employment may have restricted access depending on employer plan offerings. The distinction between HSA and FSA is important: FSA is employer-administered and use-it-or-lose-it; HSA is individually owned and portable. Neither is accessible through the state programs (Medi-Cal, OHP, New York state Medicaid) that serve undocumented immigrants, as those are state Medicaid programs that do not offer HSA or FSA pairing options.

Marketplace Special Enrollment Period (SEP) triggers for undocumented immigrants in 2026

The ACA Marketplace Special Enrollment Period (SEP) rules under 45 CFR 155.420 do not apply to undocumented immigrants because undocumented individuals cannot enroll in ACA Marketplace plans at any time. For state Medicaid programs that cover undocumented immigrants (Medi-Cal, OHP, New York state Medicaid for seniors), enrollment is year-round with no SEP or open enrollment window required. This is one meaningful advantage of state Medicaid coverage over marketplace coverage: there is no enrollment period. An undocumented immigrant who becomes income-eligible for Oregon OHP can apply any day of the year. An undocumented immigrant in California who was enrolled before the 2026 freeze and then lost coverage due to a missed renewal can potentially seek assistance through the county social services office.

For mixed-status families with lawfully present members who CAN use the ACA Marketplace, standard SEP triggers apply to those family members: loss of other coverage (60-day window), marriage or divorce, having or adopting a child, moving to a new state or coverage area, income change crossing the Medicaid threshold, DACA or other immigration status change granting lawful presence (which itself triggers a 60-day SEP), and aging off a parent's plan at 26. A DACA recipient whose status is renewed mid-year has a 60-day SEP from the renewal date to enroll in a marketplace plan. If a mixed-status family member gains lawful presence through a visa or status change, they trigger a 60-day SEP on the ACA Marketplace. Undocumented members of the same household do not gain marketplace eligibility from the status change of a relative.

• Loss of other coverage (state Medicaid termination, job loss): 60-day SEP for lawfully present family members
• Marriage or divorce: 60-day SEP
• Birth, adoption, or foster placement of a child: 60-day SEP (child is U.S. born and eligible for Medicaid/CHIP immediately)
• DACA status renewal or new grant of lawful presence: 60-day SEP for that individual
• Permanent move to a state with different Medicaid rules (e.g., moving to Oregon, which covers undocumented immigrants): apply for OHP year-round without an SEP
• Income change that crosses the OHP or state Medicaid income threshold: apply year-round for state programs

How to apply for state programs in 2026: step-by-step

Enrollment for state Medicaid programs covering undocumented immigrants is year-round, but the application process varies by state. Oregon OHP: apply at one.oregon.gov or call 1-800-699-9075. California Medi-Cal (existing enrollees renewing): renew at benefits.ca.gov or call 1-800-541-5555; county social services offices also accept in-person renewals. New York state-funded senior Medicaid: apply at the local Department of Social Services or NYC Human Resources Administration; assistance available at nystateofhealth.ny.gov. FQHCs: locate the nearest center at findahealthcenter.hrsa.gov and contact directly for intake.

• Step 1: Determine state eligibility. Check whether your state has a program for undocumented immigrants (Oregon: all ages; California: existing enrollees 19+ and all children 0-18; New York: seniors 65+ and pregnant individuals; Illinois: Emergency Medicaid and FQHCs only).
• Step 2: Gather documents. You do not need a Social Security number or immigration document to apply for state-funded Medicaid in Oregon, California, or New York. You will need proof of state residency (utility bill, lease, bank statement), proof of identity (foreign passport, consular ID such as the Matricula Consular, or birth certificate), and proof of household income (pay stubs, employer letter, or self-employment records).
• Step 3: Submit the application. Oregon: online at one.oregon.gov. California renewals: online at benefits.ca.gov or at the county social services office. New York: at the local Department of Social Services. FQHCs: contact the health center directly; most have patient navigators who assist with enrollment.
• Step 4: Await eligibility determination. Oregon determines eligibility within 45 days for non-disability applications. California Medi-Cal renewals are processed within 90 days. New York county agencies typically decide within 45 days.
• Step 5: Common reasons applications are denied. Income above 138% FPL (verify with the household-size table above). Residency not established in the state (must prove current state residence). Missing identity documentation (bring a consular ID, foreign passport, or equivalent). For California Medi-Cal: enrollment after January 1, 2026, as a new adult applicant. For New York senior Medicaid: age below 65.

What is the cheapest health insurance option for undocumented immigrants in 2026?

The cheapest option depends on the state. In Oregon, income-eligible undocumented immigrants of any age can enroll in the Oregon Health Plan (OHP) at no cost (premium-free at 138% FPL and below, which is $22,025 annually for a single person in 2026). In California, undocumented adults who were enrolled in Medi-Cal before January 1, 2026, can continue coverage free of charge through annual renewals. In New York, undocumented seniors age 65 and older who are income-eligible can enroll in state-funded Medicaid at no premium cost. In states without dedicated programs, Federally Qualified Health Centers (FQHCs) provide sliding-scale primary care often for $20 to $40 per visit based on income, and Emergency Medicaid covers life-threatening emergencies at no direct patient cost. ACA Marketplace plans and Premium Tax Credits are not available to undocumented immigrants.

Do undocumented immigrants qualify for the Premium Tax Credit or ACA subsidies?

No. Federal law (ACA Section 1312(f)(3)) categorically bars undocumented immigrants from purchasing ACA Marketplace plans or receiving the Premium Tax Credit (PTC). This applies regardless of income level. The 2026 return of the subsidy cliff (enhanced PTCs from ARPA and the Inflation Reduction Act expired January 1, 2026) affects citizens and lawfully present immigrants, not undocumented individuals who were never eligible for those credits. Mixed-status families with lawfully present members (U.S.-born children, DACA recipients, TPS holders, lawful permanent residents) can access marketplace plans and PTCs for those eligible members; the undocumented members of the household cannot.

Can undocumented immigrants deduct health insurance premiums on taxes?

Form 7206, the self-employed health insurance deduction, does not apply to undocumented immigrants in the standard sense, because it requires purchasing a qualifying plan (ACA Marketplace or employer-sponsored HDHP), which are not available to undocumented immigrants. Undocumented immigrants who file U.S. tax returns using an Individual Taxpayer Identification Number (ITIN) can potentially deduct unreimbursed medical expenses above 7.5% of AGI on Schedule A, the itemized deduction, the same medical expense deduction available to any taxpayer. This deduction does not reduce self-employment tax on Schedule SE; it reduces income tax only. The Form 7206 deduction specifically and the associated HSA tax benefits do not apply to undocumented immigrants because the qualifying plans that enable those deductions are not accessible to them.

Can undocumented immigrants use an HSA in 2026?

Not as a practical matter. Health Savings Accounts (HSA) require enrollment in an HSA-qualified High-Deductible Health Plan (HDHP) with a minimum deductible of $1,700 self-only or $3,400 family in 2026, per IRS Rev. Proc. 2025-19. HSA-qualified HDHPs are purchased through the ACA Marketplace or through formal employer-sponsored plans. Since undocumented immigrants cannot access either, the HSA pathway and its 2026 contribution limits ($4,400 self-only / $8,750 family) and triple tax advantage are unavailable. State Medicaid programs like Oregon OHP and California Medi-Cal that serve undocumented immigrants are not HSA-paired HDHP plans. Flexible Spending Accounts (FSA) are employer-only and similarly unavailable to most undocumented immigrants.

Does applying for Medicaid or a state program create a public charge problem?

As of May 2026, using Emergency Medicaid, Oregon OHP, California Medi-Cal, or New York state-funded Medicaid generally does not count against a public charge determination under the DHS 2022 framework that remains in effect. DHS published a proposed rule in November 2025 that could broaden public charge consideration, but that proposal is still in rulemaking and the 2022 framework governs currently. Medicaid received by children under 21 and pregnant individuals explicitly does not count under any current rule. Consult a qualified immigration attorney before making coverage decisions if you have an active immigration case or pending visa petition. Immigrants without papers who need emergency care should not forgo treatment due to unfounded public charge fears. Do not forgo needed care.

When can an undocumented immigrant enroll in a state Medicaid program outside a set enrollment period?

State Medicaid programs (Oregon OHP, California Medi-Cal, New York state senior Medicaid) have year-round enrollment. Unlike ACA Marketplace plans, which require a Special Enrollment Period (SEP) outside open enrollment, Medicaid has no enrollment window. An income-eligible undocumented immigrant can apply for Oregon OHP or New York senior Medicaid on any day of the year. In California, existing Medi-Cal enrollees can renew year-round; new adult applicants cannot enroll as of January 1, 2026. For FQHCs, walk-in and scheduled appointments are available year-round regardless of any enrollment period. Emergency Medicaid is triggered automatically by an emergency event and does not require advance enrollment.

What coverage is available to undocumented immigrants in Illinois after the HBIA program ended?

Illinois eliminated the Health Benefits for Immigrant Adults (HBIA) program for ages 42 to 64 effective July 1, 2025. As of 2026, undocumented adults in Illinois have access to: (1) Emergency Medicaid for life-threatening emergency stabilization, covered statewide under federal mandate; (2) FQHCs (Federally Qualified Health Centers) that provide sliding-scale primary care regardless of immigration status; (3) free and charitable clinics serving uninsured and underinsured populations; and (4) the Health Benefits for Immigrant Seniors (HBIS) program, which remains for existing enrollees age 65 and older. No new HBIS enrollment is being accepted. Undocumented children age 0 to 18 in Illinois may still qualify through All Kids or CHIP on their own merits. Undocumented pregnant individuals qualify for emergency pregnancy-related Medicaid.

Are U.S.-born children of undocumented parents eligible for Medicaid and CHIP?

Yes. U.S.-born children of undocumented parents are U.S. citizens and are fully eligible for Medicaid and CHIP based on the household's income, regardless of the parents' immigration status. In 2026, children in families at or below 138% FPL typically qualify for Medicaid; those between 138% and 200-300% FPL (varies by state) qualify for CHIP. Applying for a child's Medicaid or CHIP coverage does not trigger public charge consequences for the parent and does not expose the parent to immigration enforcement. Every income-eligible U.S.-born child in an undocumented or mixed-status household should be enrolled in Medicaid or CHIP. Apply through your state's Medicaid agency or at healthcare.gov for CHIP in states using the federal marketplace.