Medicaid & SNAP Changes in IllinoisWhat Providers, Clients & Families Need to Know
A federal law signed July 4, 2025 — often called H.R. 1 or the "One Big Beautiful Bill Act" — is changing eligibility, funding and administration across Medicaid and SNAP and affecting other programs connected to Illinois' community-based service system. IARF is organizing current IDHS and HFS guidance in one place so providers, staff, clients and families can find the right information and next steps quickly.
What deserves attention now
This page separates immediate action items from later implementation dates. Always use the linked IDHS/HFS source when determining an individual's eligibility.
ABAWD work requirements reach adults through age 64 unless they meet an exemption. A new 3-year time-limit period begins Jan. 1, 2027.
Automatic one-time cash payment per eligible person whose SNAP stopped under the work requirement.
Some noncitizens no longer qualify for federally funded Medicaid. Children, pregnant individuals and several other groups stay eligible — see below.
Work requirements and six-month redeterminations begin for ACA Adults, applied at each person's first redetermination on or after Jan. 1.
What's changed on this page
Most recent updates first. Each change is checked against the IDHS or HFS source it links to.
- Providers: added HFS's October 5 notice on off-cycle revalidation required by CMS for high-risk, non-NPI, laboratory, and ABA providers. Revalidation & Compliance card updated.
- Medicaid work requirement section updated to match HFS's September 2026 customer notice: full exemption list, the $580 income option, and 6-month renewals.
- October 1 noncitizen Medicaid change: added the groups HFS says stay eligible.
- SNAP: added the new 3-year period (Jan. 2027 – Dec. 2029), how to regain SNAP, and the February 2026 exemption form (English and Spanish).
- HFS webinars: Module 3 and Module 5 recordings added; Module 7 (Oct. 21) registration featured.
- New resources: HFS September customer notice, IDHS SNAP Support partners by county, IDHS Partner Information, IDHS SNAP Noncitizen FAQ and an LPR waiting-period table.
- Litigation card updated with the second "medically frail" lawsuit filed Sept. 18, 2026.
- New: Medicaid & SNAP Work Requirement Guide for case managers and support staff.
Key dates
Add any date to your calendar. Outlook/Apple downloads a calendar file; Google opens Google Calendar.
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1Oct 2026Medicaid noncitizen changes take effect
Some noncitizens no longer qualify for federally funded Medicaid.
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21Oct 2026HFS webinar Module 7: System Changes
1:30–2:30 PM CT. Registration required.
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31Dec 2026Medicaid applicants after 5 PM subject to work rules
Current SNAP 3-year period (2024–2026) also ends.
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1Jan 2027Medicaid work rules & 6-month renewals begin
Applied at each ACA Adult's first redetermination in 2027. New SNAP period starts.
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30Jun 2027FRESH funding period ends
Through June 2027, or sooner if funds run out.
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1Oct 2027Provider tax threshold begins phasing down
Tightens how much states can raise through provider taxes.

SNAP Work Requirements
Illinois' SNAP work-requirement waiver ended January 31, 2026. Since then, Able-Bodied Adults Without Dependents (ABAWDs) who don't meet or qualify for an exemption from the work requirement are limited to three months of benefits within a fixed three-year window. This is an ongoing, rolling limit — not a single cutoff date — so it's worth checking status regularly rather than assuming a one-time deadline has passed. People who lost SNAP can regain it by becoming exempt or meeting the requirement.
Current Status
Where Things Stand as of September 2026
Expanded ABAWD Definition
ABAWD now covers adults ages 18–64 (up from 18–54), and only children under age 14 count as dependents for exemption purposes.
Rolling 3-Month Limit
Non-exempt ABAWDs who aren't meeting the work requirement can receive SNAP for only 3 months within the fixed period Jan 1, 2024 – Dec 31, 2026. The first cohort lost benefits May 1, 2026; others may hit their own 3-month mark later in the window.
New 3-Year Period Starts Jan. 1, 2027
IDHS says the next fixed period runs Jan 1, 2027 – Dec 31, 2029. Someone who lost SNAP can get it back sooner by meeting the work requirement for a 30-day period or becoming exempt; otherwise they may become eligible again under the new period.
Not Everyone Is Affected
Many recipients already meet requirements or qualify for an exemption. Use the IDHS screener to check current status — don't assume benefits will be cut without verifying.
SNAP Noncitizen Eligibility Changes
The same federal law also narrows SNAP eligibility based on immigration status, effective April 1, 2026. For current recipients, the change is applied at their next redetermination on or after that date; existing certification periods are not cut off early.
FRESH Program — $400 Relief
Illinois' FRESH program provides a one-time $400 cash payment per eligible household member whose SNAP stopped or was reduced after using the three countable months under the federal work requirement and who has not regained or had SNAP reinstated. No application is required — IDHS issues eligible payments automatically.
FRESH Program: One-Time $400 Relief for Households Who Lost SNAP
Governor Pritzker and IDHS launched FRESH (Families Receiving Emergency Support for Hunger) to help households affected by the SNAP work requirement. It's a state-funded benefit, separate from SNAP itself — a $70 million program included in the FY27 state budget — not a replacement for ongoing monthly SNAP.
- One-time payment of $400 per eligible household member
- No application required — IDHS mails a notice to eligible households
- Issued automatically onto the household's Illinois Link/EBT card
- For eligible people whose SNAP stopped or was reduced after using their 3 countable months under the work requirement and who have not regained or had SNAP reinstated
- Does not affect eligibility for TANF, AABD Cash, or Medicaid
- Payments began August 1, 2026 for eligible households with losses after May 1 and before August 1; starting in August, newly eligible payments are issued after the 16th of the month in which SNAP access is lost
- Funding available through June 2027, or until exhausted
Each eligible person can receive FRESH only one time, even if SNAP stops again later. A person whose SNAP has already been regained or reinstated does not meet the current payment criteria. Anyone needing a replacement Link card can request one at EBTedge.com or by calling the LINK Hotline at 1-800-678-5465. IDHS posts FRESH flyers in English, Spanish, Arabic, Polish, Simplified and Traditional Chinese, and Ukrainian on its Partner Information page.
Check Your ABAWD Status
Use the IDHS online screener to find out if you're classified as an ABAWD, whether you already meet the work requirement, and whether you qualify for an exemption.
Take the Screener — English Cuestionario — EspañolFind Ways to Meet the Requirement
Work an average of 20 hours/week (paid or unpaid), volunteer through a SNAP Employment & Training activity, or do self-initiated community service. IDHS maintains a statewide resource directory.
SNAPWorkRequirements.illinois.govGet Local Help
IDHS-funded SNAP Outreach and SNAP Connect partners help people understand the new rules, file exemptions, find work or volunteer opportunities, and apply or reapply. Find the partner serving your county.
Find SNAP Support Near YouExamples of people who may be exempt from the SNAP work requirement include:
- Younger than 18 or 65 and older
- Living in a SNAP household with a child age 13 or younger
- Having a physical or mental condition that limits their ability to work or work the required hours
- Pregnant (any stage)
- Experiencing chronic homelessness
- Caring for an incapacitated household member
- A regular participant in a drug or alcohol treatment program
- Certain Native Americans under federal Indian health law
IDHS says a doctor's sign-off or medical records usually aren't needed to request a medical exemption, and proof generally isn't required unless the exemption is questionable. Receiving disability benefits is not required.
This is not an exhaustive list. Use the IDHS Screener to confirm exemption status and access the correct form to file.
SNAP Work Rules — Request for Exemption Form
The current IDHS form to document an exemption. Submit online through Manage My Case, by mail or fax to the Central Scanning Unit, or at a local Family Community Resource Center.
Download Form — English → Formulario — Español →Noncitizen Eligibility Changes
Which groups are affected by the April 1, 2026 SNAP immigration-status change, and what support is available.
Learn More →SNAP Noncitizen Eligibility Changes — FAQ
IDHS answers on the LPR 5-year waiting period, refugee and asylee children, redetermination timing, and VTTC state food benefits.
Read FAQ →Food Connections
Interactive maps and free food programs statewide — no prior application needed, useful for anyone affected while their status is being sorted out.
Find Food →FRESH Program Benefit Notice
Full eligibility details, payment timing, and what to do if you need a new Link card.
Learn More →IDHS SNAP Federal Impact Center
IDHS's own hub on the federal SNAP changes: exemption screener, resources to meet work requirements, noncitizen eligibility, and Medicaid crossover.
Visit Hub →IDHS Partner Information
Latest partner flyers (including multilingual FRESH flyers), news releases, and June 2026 SNAP counts by county, House, Senate and Congressional district.
Open Partner Page →SNAP Outreach & SNAP Connect Partners
County-by-county list of IDHS-funded partners (Greater Chicago Food Depository, IPHA, U of I Extension, Feeding Illinois, ICIRR and others) who help clients with the new rules.
Find a Partner →SNAP Work Requirements & Exemptions
Detailed breakdown of who's covered and who's exempt, for staff advising clients.
Read More →SNAP Work Requirement & FRESH — Frequently Asked Questions
IDHS's FAQ on exemptions, meeting the requirement, regaining eligibility, the 2027–2029 period, and FRESH.
Browse FAQ →MR #26.18 — The New FRESH Program
IDHS policy manual release explaining FRESH eligibility rules and FCRC staff responsibilities.
Read Policy Memo →Federal Impact to SNAP & Medicaid — Stakeholder Briefing
The August 2025 HHS stakeholder briefing recording and slide deck.
Watch Briefing →SNAP for Lawful Permanent Residents: Who Waits 5 Years?
Per IDHS, LPRs under 18, blind or disabled, veterans/active duty and dependents, or credited with 40 quarters of work are exempt from the 5-year wait. Status held before becoming an LPR also matters:
| Status before adjusting to LPR | Subject to 5-year wait? |
|---|---|
| Refugees; individuals granted asylum; deportation withheld | No |
| Cuban and Haitian entrants; Amerasians; COFA citizens | No |
| Iraqi and Afghan Special Immigrants (SIV); certain Afghan parolees (7/31/2021–9/30/2023); certain Ukrainian parolees (2/24/2022–9/30/2024) | No |
| Victims of severe trafficking; certain American Indians born in Canada; Hmong or Highland Laotian tribal members | No |
| Conditional entrants; battered immigrants (VAWA); parolees for at least one year | Yes |
Someone who has applied to adjust status but not yet received approval is not considered an LPR. Source: IDHS SNAP Noncitizen FAQ.
Most clients do not need to submit proof of an exemption — IDHS may ask for verification only if an exemption is questionable. When it does, case managers and support staff can help clients gather documentation of a work-limiting condition. Staff should also be ready to answer questions about the FRESH program — it's automatic and requires no application, so clients may see an unexpected Link card deposit and should be reassured it's legitimate.
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Medicaid Changes
The federal law makes significant cuts to Medicaid. HFS estimates coverage loss for roughly 500,000 Illinois Medicaid customers, with the state facing a reduction in federal Medicaid funding of $26–51 billion over the next decade. Changes roll out on a phased timeline through 2029, with the first major provisions taking effect October 1, 2026 and January 1, 2027.
Effective-Date Timeline
Key Provisions & When They Start
Provider tax freeze (no new or higher provider taxes); new State Directed Payments (SDPs) capped at 100% of Medicare rates; one-year prohibition on Medicaid funding to Planned Parenthood.
Some noncitizens no longer qualify for federally funded Medicaid. Eligibility continues for Lawful Permanent Residents who have met the 5-year bar or are not subject to it (including refugees, asylees and trafficking survivors who adjusted to LPR from that status), Cuban/Haitian entrants, COFA citizens, lawfully residing children under 19 and pregnant individuals, and people already enrolled in HBIS, AATV, and Illinois' medical programs for domestic violence survivors and kidney/renal disease. Refugees, asylees and trafficking survivors who have not adjusted to LPR status are among those affected.
Medicaid work requirements begin for ACA Adults (generally ages 19–64, no child under 18 at home, not on Medicare). New applicants are subject if they apply after 5:00 PM on December 31, 2026; current enrollees are subject starting at their first redetermination on or after January 1, 2027. ACA Adults also move to 6-month redeterminations, and the retroactive coverage window shrinks.
Provider "hold harmless" threshold begins phasing down, tightening how much states can raise through provider taxes.
Existing State Directed Payments begin stepping down 10 percentage points per year until they reach 100% of Medicare rates.
Expanded cost-sharing begins for ACA expansion adults above 100% FPL (out-of-pocket cap: 5% of annual income). Primary care, mental health, and substance use disorder services are explicitly exempt, as are all services delivered by CCBHCs, FQHCs, and RHCs.
Cost-sharing exemption detail: National Council for Mental Wellbeing H.R.1 Hub.
Important for Medicaid customers
HFS says many customers will be exempt and no one will be required to act until they receive direct notice from the State. In September 2026, HFS mailed a notice to ACA Adults who may be affected by work requirements and six-month redeterminations in 2027 — view the notice (English) or en español. Keep your address current, open mail from the State right away, and set up a Manage My Case account at abe.illinois.gov.
Who is exempt from the Medicaid work requirement?
- Pregnant, or receiving postpartum coverage (Moms & Babies)
- A former foster youth under age 26
- American Indian/Alaska Native, or eligible for care through the Indian Health Service
- A parent, guardian, caretaker relative or family caregiver (paid or unpaid) of a child under 14 or a person with a disability
- A veteran with a 100% VA disability rating
- "Medically frail" — health issues that prevent meeting the requirement, such as being blind or disabled under Social Security standards, a substance use condition, a serious mental health condition, a physical, intellectual or developmental disability that makes daily activities hard, or a serious or complex medical condition needing regular treatment
- Receiving TANF and meeting TANF work requirements
- Meeting SNAP work requirements, or in a month of the 3-month SNAP grace period
- Participating in a drug or alcohol treatment program
- In jail or prison, or released within the last 3 months
Short-term hardship exemptions also exist: living in a county with a federal emergency declaration or high unemployment (HFS determines this), and — on request — being an inpatient in a hospital, rehab facility, ICF/IID or psychiatric hospital, or traveling outside the community for extended medical treatment.
Work requirements do not apply to people under 19 or over 64, people enrolled in or entitled to Medicare, or people in another Medicaid category such as AABD, Moms & Babies or Family Care. Illinois will accept self-attestation of exemptions in 2027 when state data can't verify them. Source: HFS September 2026 customer notice and Medicaid Customer Guide.
How ACA Adults can meet the requirement: in at least one month of each eligibility period, have income of $580 or more, or be enrolled in school at least half-time, or complete 80 hours of work (including unpaid, self-employment or seasonal work), volunteering, a work program, or less-than-half-time school — in any combination. After the first 2027 redetermination, eligibility is reviewed every 6 months, and exemptions must be confirmed at each review. If HFS can't verify compliance or an exemption, the customer gets 30 days to provide information. HFS says customers will be able to request exemptions and upload work documents through Manage My Case by January 2027.
Noncitizen Medicaid changes — effective October 1, 2026
Only these noncitizens continue to be eligible for Medicaid:
- Lawful permanent residents who have met the 5-year bar, or are not subject to it (for example, refugees, asylees and trafficking survivors who adjusted to LPR from that status)
- Cuban-Haitian entrants
- Citizens of the Compact of Free Association (COFA) states
- Children under 19 who reside here lawfully
- Pregnant individuals who reside here lawfully
- People already enrolled in Health Benefits for Immigrant Seniors (HBIS), AATV medical coverage, or Illinois' medical programs for domestic violence survivors or kidney/renal disease
HFS fact sheets: English · Español · Noncitizen Medicaid & Marketplace rules
HFS Stakeholder Webinar Series
Medicaid Changes Under H.R. 1
Common Questions & Answers Regarding Medicaid Changes
Held September 15, 2026. Recording not yet posted by HFS.
Check HFS for Recording →Redeterminations & Retroactive Coverage
Recording from the August 20 session.
Watch Recording →Exemptions from Work Requirements
Recording plus English & Spanish slide decks from the July 22 session.
Watch Recording → English Slides → Diapositivas en Español →Work Requirements & Community Engagement
Recording plus English & Spanish slide decks from the July 14 session.
Watch Recording → English Slides → Diapositivas en Español →Noncitizen Eligibility Changes & Alternative Resources
Recording plus English & Spanish slide decks from the June 23 session.
Watch Recording → English Slides → Diapositivas en Español →Medicaid Overview and H.R. 1 Changes, Impact, and Timeline
Recording from the May 21 session.
Watch Recording →Customer Notices & Toolkits
Multilingual Client Resources
Illinois Medicaid Customer Guide to HR 1 Changes
HFS's own plain-language guide: who's affected, how to meet or get exempted from work requirements, and a step-by-step "what to do now" checklist.
Read the Guide →September 2026 ACA Adult Notice
The notice HFS mailed to ACA Adults who may be affected by work requirements and 6-month redeterminations in 2027, including the full exemption list.
View HR 1 Customer Notices →Slide Deck, Flyer, Palm Card & Flow Chart
Explains which noncitizens are affected by the October 2026 eligibility change and what to do now. Available in English, Spanish, Chinese, Korean, Polish, Russian and Ukrainian.
English PDF →Medicaid Rules Will Be Changing
HFS's Phase 2 communications package: toolkit, flyer, palm card, social media graphics and a customer fact sheet, in English and Spanish.
English Toolkit → All Phase 2 Files →Update Your Address / Stay Reachable
Helps customers keep their contact info current so they don't miss redetermination notices.
English PDF →Language availability varies by toolkit. HFS posts the Phase One address/update materials in the languages shown above. The NonCitizen toolkit is available in English, Spanish, Chinese, Korean, Polish, Russian and Ukrainian. The Phase 2 toolkit is in English and Spanish. Use the HFS Federal Resource Center for the latest language-specific files.
Provider Tax & SDP Changes
Provider tax limits and State Directed Payment caps are projected to cost Illinois nearly $5 billion in federal dollars over 5 years from provider tax changes, and reduce hospital SDPs by $3.4 billion over 5 years — reductions that flow through to provider reimbursement statewide. For expansion states like Illinois, the provider tax "safe harbor" threshold steps down on a set schedule under CMS’s proposed rule (CMS-2452-P, comment period closed Sept. 21, 2026 — not yet finalized): 6% today → 5.5% (Oct 2027) → 5% (Oct 2028) → 4.5% (Oct 2029) → 4% (Oct 2030) → 3.5% (Oct 2031).
What Providers Should Know Now
HFS mailed September 2026 notices to ACA Adults. Many people served in I/DD settings are in other Medicaid categories (such as AABD) or on Medicare and are not subject to work requirements. For ACA Adults who are, the exemption for inpatient stays in an ICF/IID or psychiatric hospital must be requested. HFS says a combined SNAP & Medicaid work requirement screener and a "Manage My Work Requirement" form are coming in late 2026.
Revalidation & Compliance
Illinois Medicaid providers revalidate at least every five years on rolling cycles. Under new CMS guidance, HFS announced on Oct. 5, 2026 that high-risk providers, providers without an NPI, laboratory providers, and ABA providers must revalidate within an upcoming two-year cycle. Providers that revalidated or newly enrolled between April 30, 2025 and April 30, 2026 are not affected.
HFS emails notices 90 and 30 days before each due date to the address listed in IMPACT. Wait for that email before starting. Missing the deadline means disenrollment, and reinstatement is not retroactive.
Off-Cycle Provider Revalidation
HFS notice (Oct. 5, 2026) on CMS-required two-year revalidation for high-risk, non-NPI, laboratory, and ABA providers, with steps to prepare in IMPACT and NPPES.
Read Notice →Legal Challenges to the "Medically Frail" Definition
Illinois is one of 25 states plus D.C. suing CMS over the narrow "medically frail" definition in its June 2026 work-requirement rule. The court declined to pause the rule this summer, so the Jan. 1, 2027 timeline stands while the case continues. On Sept. 18, 2026, a second suit (Taylor v. Kennedy, D. Md.) was filed by medical groups and five enrollees, including one from Illinois.
Learn More →HR 1 Customer Notices
The text of the September 2026 notice to ACA Adults — useful for staff helping clients understand what they received.
View Notices →Medicaid Technical Assistance Center
HFS help desk for provider billing, enrollment, and revalidation questions.
Visit MTAC →Save Medicaid Toolkit
HFS-produced messaging and materials for provider organizations responding to the Medicaid cuts.
Access Toolkit →Medicaid Federal Policy Changes — Full FAQ
HFS's detailed FAQ covering eligibility, funding, and SNAP crossover questions. May lag behind newer HFS materials — check the Customer Guide for the latest.
Read FAQ →
Other Impacts to Watch
The federal changes reach beyond SNAP and Medicaid eligibility rules. These related items are worth tracking because they affect funding and costs across the community-based service system IARF members operate in. We'll expand this section as more provisions relevant to our field come into focus.
Rural Health Transformation Program
The federal law created a $50 billion federal fund for rural healthcare. Illinois was awarded $193.4 million for calendar year 2026. The state applied for $1 billion across five years, but subsequent annual awards are determined by federal CMS. Planned uses include primary care/behavioral health integration, telehealth, and rural workforce expansion — directly relevant to members providing behavioral health and rehabilitation services in rural Illinois.
Provider Tax & Reimbursement Pressure
The same provider tax and State Directed Payment caps described in the Medicaid section reduce the state dollars available to support providers generally — a funding pressure worth factoring into budget planning even for organizations not directly billing Medicaid for these services.
ACA Marketplace Premiums (related, not H.R. 1)
Separately, the enhanced ACA premium tax credits expired December 31, 2025 under a different law (not H.R. 1 itself). Get Covered Illinois confirms those enhanced credits expired at the end of 2025. Financial help still exists for many Marketplace customers, but the amount may be lower in 2026. HFS also notes that people who lose Medicaid for not meeting work requirements may enroll through Get Covered Illinois but will not be eligible for advance premium subsidies.
Rural Health Transformation Program — Illinois
HFS's application details, funding uses, and timeline.
Read More →HFS Federal Resource Center
The source page for all HFS Medicaid materials on this page.
Visit HFS →
National Partner Resources
Beyond Illinois state agencies, two national associations IARF members already have access to maintain their own resource hubs on the federal changes, each written for a specific part of our field: ANCOR for I/DD community-based service providers (IARF members receive full ANCOR membership), and the National Council for Mental Wellbeing for behavioral health and substance use organizations.
Summary of Medicaid Provisions in H.R. 1
ANCOR's overview of key Medicaid provisions, written for I/DD community providers.
Read Summary →Access Rule & Budget Reconciliation Implementation Timeline
Cross-references the federal law's changes against the separate HCBS Access Rule — useful for members running HCBS programs.
View Timeline →State Financing Mechanisms: Provider Taxes & SDPs
The provider tax / State Directed Payment changes, explained specifically for I/DD providers.
Read Fact Sheet →Medicaid Work Requirements & People with Disabilities
The administrative burden case against work requirements for I/DD beneficiaries and providers.
Read Fact Sheet →Medicaid Cuts & Community Services
Frequently asked questions on how the cuts affect community-based disability services.
Browse FAQs →ANCOR Medicaid Resource Center
The full hub — advocacy toolkits, fact sheets, workforce data, and ongoing updates.
Visit ANCOR →H.R. 1 Direct Service Provider Talking Points
Written for frontline staff, not policy teams — useful for training direct support and case management staff.
Get Talking Points →H.R. 1 Implementation Journey Map
Visual walkthrough of how the changes unfold for organizations and the clients they serve.
View Journey Map →H.R. 1 Implementation Timeline
Federal/CMS-level effective-date timeline, a useful cross-check against the Illinois-specific dates above.
View Timeline →Medicaid Work Requirements: Impact & Recommendations
Analysis of how community engagement requirements affect behavioral health and SUD service organizations.
Read White Paper →National Council H.R. 1 Hub
The full hub — RHTP resources, work requirement guidance, redetermination fact sheets, and CMS resources.
Visit National Council →
Stay Informed
Ongoing Updates
IARF NewsNotes
Weekly hot-sheet on Capitol and state agency updates relevant to members.
Read NewsNotes →HFS Stakeholder Newsletter
Quarterly updates on major HFS initiatives, policy, and program changes.
Subscribe →IDHS Partner Information
IDHS's page for the latest partner flyers, toolkits, news releases and SNAP data.
Visit IDHS →IARF Policy Context
Working with the State of Illinois to disseminate information on H.R. 1's changes to Medicaid, SNAP, and related federal programs is a pillar of IARF's 2026 Strategic Framework. Member organizations are encouraged to share these resources with clients, families, and community partners. For policy updates, visit the IARF Policy Action Center or review the 2026 Strategic Framework.
Last content verification: October 5, 2026. This hub is an educational resource and does not replace an individual eligibility determination or direct notice from IDHS/HFS. Agency guidance can change as federal implementation continues.