How recent federal changes may impact noncitizen access to public benefits in Michigan

Supplemental Nutrition Assistance Program (SNAP)
(Formerly known as food stamps)

OBBBA shortens the list of eligible populations for Michigan’s Food Assistance Program (FAP) or SNAP to only the following: U.S. citizens, certain U.S. lawful permanent residents, Cuban and Haitian entrants, and people present in accordance with the Compact of Free Association (COFA), i.e. citizens from the Marshall Islands, Micronesia, and Palau. To be clear, SNAP “is not and has never been available to undocumented non-citizens,” according to the U.S. Department of Agriculture’s Food and Nutrition Service, which administers SNAP at the federal level.

Lawful permanent residents (LPRs) or green card holders remain a SNAP-eligible population — and refugees and asylees may apply to adjust their status to LPR or green card status after one year. LPRs who meet other SNAP requirements have traditionally been eligible after a five-year waiting period, although that period can be waived if they meet another requirement like being a child under 18, being blind or disabled, or having a U.S. military connection.

OBBBA takes away SNAP eligibility from the following non-citizen statuses: refugees, asylees, victims of trafficking, people granted a withholding of removal, survivors of domestic violence who have filed a self-petition under the Violence Against Women Act, and persons granted humanitarian parole for a period of at least one year. As of 2023, there were 43,759 non-citizens who relied on SNAP with another 330,179 likely eligible. The law did not have any delay in implementing these changes, so they will go into effect in Michigan as soon as Michigan receives and processes the specific requirements from the U.S. Department of Agriculture (USDA).

In addition to OBBBA, the USDA issued a notice on July 10, 2025 that purported to restrict eligibility based on the definition of a federal public benefit. However, because immigrant and refugee eligibility for SNAP was already limited, and because OBBBA will further restrict access, the USDA notice does not have any further implications for access to SNAP. Food banks and nonprofit organizations may continue to provide assistance to those who are in need, regardless of immigration status.

Access to SNAP is also limited by new work requirements for adults up to age 64 and those who are caring for anyone over age 14. Finally, many SNAP users were frightened when the federal government threatened to share data for purposes of immigration enforcement — a move that has been paused for Michiganders by a lawsuit. This fact sheet can help users navigate threats to data privacy.

Women, Infants, and Children Program (WIC)

OBBBA did not make changes to eligibility requirements for the Women, Infants, and Children program (WIC).

This may provide a critical safety net for some people who are newly ineligible for SNAP. Advocates are also encouraged to explore programs that are outside of SNAP, such as Rx Kids, Food Club Network programs, and food pantries. Notably, the USDA notice regarding the term federal public benefit confirmed that states such as Michigan may provide WIC to immigrants who are not considered “qualified.”

Medicaid and Healthy Michigan Eligibility

Effective October 1, 2026, the OBBBA restricts Medicaid eligibility to lawful permanent residents, Cuban and Haitian entrants, people residing in the U.S. under the Compacts of Free Association (COFA), and lawfully residing children and pregnant immigrants in states that cover them under the Medicaid and/or Children’s Health Insurance Program (CHIP) option. These restrictions also apply to the Healthy Michigan program, or Medicaid expansion. The OBBBA removes eligibility for refugees, those granted parole for at least one year, those granted asylum or related relief, certain abused spouses and their children or parents, and certain victims of trafficking. Michigan was home to approximately 90,000 refugees in 2019, many of whom would not have access to health care apart from Medicaid. An estimated 66,400 non-citizens in Michigan had their health coverage through Medicaid in 2023. Based on data from 2016-2020, over 70% of Michigan’s uninsured population were non-citizens.

Additionally, the OBBBA lowers the federal Medicaid matching rate for “emergency only” services. States like Michigan that expanded Medicaid under the ACA will receive a lower federal Medicaid matching rate (FMAP) for emergency services provided to adults with low incomes who are ineligible for full-scope Medicaid because of their immigration status. We have not yet heard from the Michigan Department of Health and Human Services on if this is expected to affect delivery of emergency services only Medicaid. It is possible that funding could become more strained, limiting the reach of the program.

Access to Medicaid will also be limited by upcoming work requirements starting in 2027. Finally, many Medicaid users were frightened when the federal government threatened to share data for purposes of immigration enforcement — a move that has been paused for Michiganders by a lawsuit. This fact sheet can help users navigate threats to data privacy.

Children's Health Insurance Program (CHIP)

CHIP eligibility changes reflect the same changes made to Medicaid eligibility. This also goes into effect on October 1, 2026. This change will impact thousands of Michigan children who will become ineligible for health insurance.

Medicare Eligibility

OBBBA eliminates Medicare eligibility for groups like refugees and asylees who do not have a green card and people with Temporary Protected Status. The only remaining eligible groups include U.S. citizens, certain lawful permanent residents, Cuban and Haitian entrants and COFA citizens. Current participants at the time of enactment will remain eligible for 18 months, thus going into effect no later than January 04, 2027.

Affordable Care Act/Marketplace Access

Those who are lawfully present and either admitted for permanent residence, granted status as a Cuban or Haitian entrant, or are here via a Compact of Free Association are eligible for premium tax credits to purchase marketplace plans. Refugees, asylees, and Temporary Protected Status recipients who were previously eligible for the premium tax credits are no longer eligible. These status holders are some of the 12,192 non-citizens whose health insurance was purchased directly by the subscriber just two years ago. This takes effect on January 1, 2027.

In related regulatory activity, the federal administration removed access to Affordable Care Act (ACA) Marketplace health care for recipients of Deferred Action for Childhood Arrivals (DACA) as of August 25, 2025. This access had only briefly been in place and had been impacted by litigation, but the regulatory change ended eligibility.

Lawfully present immigrants with income that falls below 100% of the federal poverty level and are ineligible for Medicaid due to their immigration status (and those ineligible because they have not met the requirement of five years in the U.S.) are ineligible for Premium Tax Credits under the ACA. This is effective for tax years after December 31, 2025.

Immigrant Children’s Health Improvement Act Policy (ICHIA)

OBBBA left intact access to Medicaid for children and pregnant people who are lawfully present, regardless of how long they have been present. Michigan adopted the ICHIA expansion option through its budget and eligibility manuals, and those under 19 and pregnant people during one year postpartum remain eligible after OBBBA. This may allow many people newly ineligible for Medicaid to gain access for critical child and prenatal care. Prior to implementation, it was estimated that 3,000-4,000 children would be impacted by the ICHIA expansion. By 2023, there were 16,104 foreign-born children in Michigan who met the age, citizenship and income requirements and could benefit from the ICHIA option, having resided here for less than five years.

Child Tax Credit (CTC)

For families with low incomes and children who qualify, the CTC provides a tax break; previously, dependent children who were citizens were available to qualify for the CTC, regardless of their parent’s citizenship status. After the OBBBA, taxpayers and their spouses, if filing jointly, require them to have a SSN. This applies to taxable years after December 31, 2024. There are an estimated 22,300 children in Michigan under mixed status households that could be affected.