In August 2025, in an effort to drum up evidence of fraud in the Medicaid program, CMS announced a burdensome new policy, requiring states to re-verify the immigration status of Medicaid enrollees—people whose status had already been verified.
Reporting has revealed that states are finding extremely small numbers of people erroneously on the program. For example, Oklahoma identified just 10 people, while Pennsylvania found no one incorrectly enrolled after checking 79,000 people.
This makes sense. Immigration status verification is already rigorous in the Medicaid program. Individuals must indicate that they have a status that makes them eligible for Medicaid and states are required to verify that assertion with the Department of Homeland Security via the SAVE database.
Yet CMS is demanding states do this whole process again, every month, for tens to hundreds of thousands of people at a time. This excessive verification is the real waste.
Arizona’s Data Revealed Minimal Evidence of Ineligible Enrollees
With the help of our Health Law Partner, the William E. Morris Institute for Justice, NHeLP obtained hundreds of documents from Arizona’s Medicaid agency related to this request from CMS. The data confirms minimal evidence of incorrectly enrolled individuals, demonstrates the costly administrative and financial burdens extra verification places on states, and raises concerns about CMS’s own data practices.
First, Arizona’s data mirrors other states in finding minimal evidence of ineligible enrollees. In the first month, CMS demanded Arizona review over 44,000 enrollees. Four months later, it disenrolled just 14 for lacking satisfactory status. Of those 14, it appears 10 may have been Cuban/Haitian entrants who SAVE could not verify – but this likely reflects longstanding difficulties with SAVE verification of this population, rather than erroneous enrollment.
Another 134 individuals were asked to supply additional information and did not respond, causing them to be procedurally disenrolled without a determination that they are in fact ineligible. This is not surprising, given that paperwork burdens often lead eligible individuals to lose coverage, and immigrants are currently living in an environment of fear surrounding Medicaid use.
Second, this re-verification work is diverting state resources. Arizona spent $253,000 to update its eligibility system to try to automate its response to these monthly reports, a cost one state employee characterized as “very expensive.” Meeting notes indicate that the work “is considered an emergency priority, bypassing normal governance, with immediate action required.” And documents showed this project diverted staff time from other projects.
Third, the documents show sloppy data practices from CMS. Though purportedly aimed at immigrants, in the first month, 43% of the names on the list CMS sent were citizens. The same names appeared in multiple months, in part due to slow response times from SAVE itself. And CMS is sending the files via spreadsheets over email rather than through a more secure managed file transfer.
In the end, CMS’s fishing expedition is the true waste of Medicaid funds. It isn’t turning up any evidence of fraud and is diverting state resources that could be spent on people’s health care. NHeLP’s team will continue to monitor implementation of these additional CMS-imposed immigrant verification requirements.
