2025

• Expiration of ACA Marketplace Enhanced Tax Premium Credits/Subsidies: The enhanced subsidies for ACA Marketplace plans are set to expire at the end of 2025. This is expected to cause a significant increase in premiums for many Floridians enrolled in these plans starting in 2026. It is expected they will go up 75% on average, with some estimates as high as 400% for some people. 
• Increased Medicaid Application & Renewal Complexity: Effective July 2025, changes to Medicaid application and renewal processes will make it more difficult to enroll/keep coverage, especially for older adults and those with disabilities. This includes a delay in the implementation of streamlined eligibility and enrollment procedures until 2035. 

2026

• Eligibility Restrictions for Immigrants: Effective October 2026, only U.S. citizens, nationals, lawful permanent residents, certain Cuban and Haitian entrants, and individuals residing under a Compact of Free Association will qualify, excluding asylees, refugees, and those with DACA and TPS. 
• Requirement for Notifying Medicaid Enrollees of Work Requirements: States that implement Medicaid work requirements by December 31, 2026, must notify enrollees that they will soon be subject to these requirements. (Even though FL is not an expansion state, the legislature can still implement work requirements for those already eligible for Medicaid.)

2027

• Implementation of Medicaid Work Requirements: Effective January 2027, most Medicaid recipients between 19 and 64 years old, without qualifying exemptions, will need to meet work or community engagement requirements to maintain coverage. (Note states have the option to implement these requirements sooner.)
• Reduced Retroactive Coverage: The period of retroactive coverage for medical bills will be shortened to one month prior to applying for Medicaid for expansion enrollees and two months prior for traditional enrollees, starting January 1, 2027.

2028

• Reductions in State Directed Payment Rates for Hospitals: The "safe harbor" limit, which impacts how much provider tax revenue states can use to finance their share of Medicaid, will be phased down starting in fiscal year 2028. The limit will be reduced by 0.5% each year until it reaches 3.5% in fiscal year 2032.
• Imposition of New Medicaid Cost-Sharing: Beginning October 1, 2028, some states can begin imposing deductions, cost-sharing, or similar charges for certain care, items, and services provided to Medicaid beneficiaries with incomes above the federal poverty level.