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Page 8 – State Health Official Letter 1903(v)(5) of the Act permits FFP for full-benefit Medicaid coverage (i.e., LPRs, Cuban/Haitian entrants, and COFA migrants). Section 1899C of the Act applies 18 months after the date of enactment of the WFTC legislation. Section 1899C of the Act otherwise applies immediately to limit entitlement to, or enrollment for, Medicare after July 4, 2025. We expect to provide more information on section 1899C of the Act in forthcoming guidance. Implementation Requirements at Application and for Current Medicaid and CHIP Beneficiaries States will need to implement changes by October 1, 2026, to comply with the FFP limitations outlined in section 1903(v)(5) of the Act with respect to individuals who apply for coverage on and after October 1, 2026, and to beneficiaries who are enrolled in Medicaid or CHIP on October 1, 2026. Beginning October 1, 2026, states must ensure proper FFP claiming by limiting determinations of eligibility for full Medicaid and CHIP benefits to only those individuals for whom FFP is available for that coverage under sections 1903(v)(5) and 2107(e)(1)(R) of the Act. States will need to implement these new requirements when verifying citizenship or satisfactory immigration status, as required under sections 1137 and 2105(c)(9) of the Act, and implementing regulations at 42 C.F.R. §§ 435.406, 435.956, and 457.380(b). See the section of this letter entitled Verification of Immigration Status or Category for more information. Potential changes to states’ Medicaid and CHIP applications and to eligibility and enrollment and other systems necessitated by the implementation of sections 1903(v)(5) and 2107(e)(1)(R) of the Act are discussed in the sections of this letter entitled Updates to Applications, Renewal Forms, and Other Materials for Medicaid and CHIP and Medicaid and CHIP Information Technology (IT) Systems Costs and Upgrades. Because section 1903(v)(5) of the Act affects certain individuals’ eligibility for federally funded coverage and because CMS does not consider health coverage to be Medicaid or CHIP coverage unless federal matching funds are available, CMS interprets section 1903(v)(5) of the Act as a statutory change that potentially may affect an individual’s eligibility for Medicaid or CHIP coverage. Similarly, CMS interprets section 1903(v)(5) of the Act as affecting an individual’s “satisfactory immigration status” for full Medicaid or CHIP benefits for purposes of section 1137(d) of the Act. Thus, in accordance with 42 C.F.R. §§ 435.916(d) (2023) and 457.343,37 states must promptly act on this statutory change and assess whether certain beneficiaries continue to be in a satisfactory

37 Section 71102 of the WFTC legislation imposed a moratorium prohibiting CMS from implementing, administering, or enforcing certain amendments made by a CMS final rule entitled “Streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes” (89 Fed. Reg. 22780 (Apr. 2, 2024)) (the “2024 Eligibility and Enrollment (E&E) Final Rule”) available at: https://www.govinfo.gov/content/pkg/FR-2024-04-02/pdf/2024-06566.pdf. The moratorium applies to certain provisions of the 2024 E&E Final Rule that have a compliance date after July 4, 2025, the date the WFTC legislation was enacted, and ends on September 30, 2034. To comply with the moratorium, in this SHO letter, CMS refers to the renewal requirements and the requirements for acting on changes in circumstances at 42 C.F.R. § 435.916, including those cross- referenced at 42 C.F.R. § 457.343, in effect as of 2023, available at: https://www.ecfr.gov/on/2024-06-02/title-42/chapter- IV/subchapter-C/part-435 and https://www.ecfr.gov/on/2024-06-02/title-42/chapter-IV/subchapter-D/part-457. For more information on the moratorium, see the CIB “Working Families Tax Cut” Legislation, Public Law 119-21: Summary of Medicaid and Children’s Health Insurance Program (CHIP) Related Provisions,” (Nov. 18, 2025), available at: https://www.medicaid.gov/federal-policy-guidance/downloads/cib11182025.pdf.