Effective December 27, 2020, migrants under the Compact of Free Association (COFA) may be newly eligible for Medicaid if they meet all of the eligibility criteria in their state. COFA migrants are generally citizens of the Marshall Islands, Federated States of Micronesia, and Republic of Palau who are lawfully residing in one of the U.S. states or territories. Under the new eligibility criteria, COFA migrants are now considered qualified non-citizens (QNC) for the purposes of Medicaid eligibility and do not have to wait for five years after receiving their status before qualifying for Medicaid coverage, if otherwise eligible. This policy change does not apply to coverage through separate Children’s Health Insurance Program (CHIP) programs, except for states that have elected to cover children and/or pregnant women in CHIP under the CHIPRA 214 option.

Currently, COFA migrants who apply at the Federally-Facilitated Exchange (FFE) will not be found eligible for Medicaid, as the system does not consider COFA migrants to be QNCs for purposes of Medicaid eligibility. Instead, COFA migrants may be found eligible for Marketplace coverage with advance payments of the premium tax credit (APTC) or cost-sharing reductions (CSRs), if otherwise eligible. CMS is actively working on system changes to determine correct eligibility for these consumers at the Marketplace, and anticipates a release in early summer 2021.

Until the system changes at the FFE are finalized, CMS recommends that consumers apply directly with their state Medicaid agencies to determine their eligibility for Medicaid. Once consumers receive a determination of eligibility for Medicaid, they should return to the Marketplace to end their QHP coverage with financial assistance if they are found eligible for Medicaid and do not want to pay full cost for their share of the Marketplace coverage. This is because consumers who are enrolled in Medicaid or CHIP that counts as qualifying coverage (also known as minimum essential coverage, or MEC), are not eligible for APTC or CSRs to help pay for the cost of a Marketplace plan premium and covered services. The FFE will not take action on a consumer’s behalf to end their Marketplace coverage if they are found to be Medicaid eligible by their state due to this policy update.