On July 4, 2025, President Trump signed into law a federal reconciliation bill that includes historic cuts to SNAP and Medicaid, two critical programs that provide access to food and healthcare. The bill also included significant changes to Affordable Care Act (ACA) coverage and allows the ACA’s enhanced premium tax credits to expire at the end of year.
Food Is Medicine Massachusetts co-conveners Community Servings and the Center for Health Law and Policy Innovation of Harvard Law School hosted a webinar on September 4 to recap the policy changes and explore what the impact might be in Massachusetts. Similarly, panelists discussed what stakeholders can do to mitigate harm, as accessing SNAP benefits and affordable healthcare coverage becomes more difficult.
Pat Baker, Senior Policy Advocate with the Massachusetts Law Reform Institute, spoke about SNAP.
Alex Sheff, Senior Director of Policy and Government Affairs at Health Care for All, spoke about the ACA and Medicaid.
The conversation was moderated by Katie Garfield, Director of Whole Person Care at the Center for Health Law and Policy Innovation of Harvard Law School.
The following is a summary of the discussion. (Click here to see the webinar slide deck.)
Changes to SNAP
The largest anti-hunger program in Massachusetts, SNAP currently serves one in six residents.
According to Baker, the new law is expected to take SNAP eligibility away from around 9,600 legally present immigrants residing in Massachusetts, including refugees, asylees, and victims of trafficking. The new law also expands the work requirements for SNAP beneficiaries. Previously, people over 54 and guardians of children were exempt from work requirements. However, with the new law, people aged 55 to 65, veterans, and guardians of children age 14 and older are subject to work requirements for the first time. About 40,000 Massachusetts residents are expected to be subject to the new requirements.
Historically, the federal government funded 50% of SNAP administrative costs and 100% of SNAP benefits. However, the new law is designed to change that:
- Effective October 1, 2026, the federal reimbursement of SNAP administrative costs will be reduced from 50% to 25%. The impact to Massachusetts, according to Baker, could be approximately $50 million to $60 million yearly.
- Effective October 1, 2027, SNAP benefit costs will shift to states based on each state’s error rate. States will be required to pay at least 5% and up to 15% of benefit costs if their error rate is 6% or higher. Based on its recent error rate of 14%, Massachusetts could be required to fund 15% of SNAP benefit costs – or a potential yearly cost of $400 million.
Baker has grave concerns about these changes.
SNAP beneficiaries who qualify still could lose benefits if they fail to comply with the new reporting requirements. “This is more about a paperwork requirement” that will make qualifying more cumbersome for beneficiaries, Baker says. “It’s death by a thousand papercuts.”
The United States Department of Agriculture, which administers the SNAP program, is beginning to issue implementation guidance. The direction of Massachusetts’ Department of Transitional Assistance under these changes is not yet known.
“We’re very worried about the future of this program,” Baker says.
Why It Matters
In 2024, 24% of Massachusetts residents experienced very low food security, meaning economic barriers disrupted their access to and intake of healthy food. This is true for many Community Servings’ clients, 90% of which have incomes under 200% of the federal poverty level. Cuts to SNAP are a major blow to the state’s most effective anti-hunger program at a time of rising food costs. Community Servings’ clients will be among the populations that will suffer from these cuts.
Resources
- MLRI Analysis of SNAP Cuts and Massachusetts Impact
- Boston Indicators Report: SNAP Cuts and the Local Fallout
Changes to the ACA and Medicaid
Similar to the changes to SNAP, changes to the ACA exclude certain legally present immigrants from accessing subsidized coverage. Effective January 1, 2027, the ACA’s premium tax credits are no longer available for lawfully present immigrants. The employer responsibility of coverage for lawfully present immigrants is also ending.
Separately, the changes to Medicaid create new and more frequent paperwork requirements for people who qualify.
As of April 2025, MassHealth covers about 1.9 million Massachusetts residents: low-income individuals and families, children, and people with disabilities. The program accounts for over 30% of the state budget, and it receives 86% of all of the federal revenue in Massachusetts.
Under the new law, Medicaid member eligibility and financing undergo sweeping changes. (In the interest of brevity, this summary does not cover Medicaid financing provisions. However, they are very significant. As Sheff explained, the new Medicaid financing provisions would introduce new challenges to state budgets that are already struggling. For a complete list of Medicaid provisions in the bill, see the Kaiser Family Foundation.)
Notably, the changes to Medicaid eligibility primarily concern the Medicaid Expansion population: adults under age 65 who do not have dependent children, have incomes up to 133% of the federal poverty level, and are not enrolled in or applying for Medicaid on the basis of disability or pregnancy. Key changes to Medicaid eligibility for this population include:
- Effective October 1, 2026, Medicaid federal funding is eliminated for many lawfully present immigrant adults, including refugees, asylees, and certain humanitarian visa holders. Lawfully present children, pregnant people, and green card holders are excluded.
- Effective January 1, 2027, Medicaid work requirements go into effect for Medicaid Expansion members (with some exceptions).
- Effective January 1, 2027, Medicaid Expansion members must renew their eligibility every 6 months instead of every 12 months.
- Effective October 1, 2028, Medicaid Expansion members must pay a new cost-share of up to $35.
The Center for Budget and Policy Priorities estimates that 46% of MassHealth members subject to work requirements would lose MassHealth, despite 86% already working or meeting the exemption criteria. The BCBS Foundation reports that work requirements and 6-month eligibility redeterminations will cause between 141,000 and 203,000 people to lose their MassHealth coverage. In the report’s words: “Many people will lose coverage because they aren’t able to verify their eligibility – not because they are no longer eligible.” As with changes to SNAP, Medicaid eligibility changes create additional reporting requirements that are likely to cause people to lose Medicaid benefits because of failure to report eligibility, or inaccurate or incomplete reporting.
The uninsured populated is expected to grow by 50% due to these provisions alone.
Why It Matters
MassHealth works. It effectively creates access to healthcare and improves health outcomes for people with low incomes.
From 2020 through 2024, Community Servings provided services to 6,339 MassHealth members through the Flexible Services Program. Over 2,000 MassHealth members have been referred to Community Servings in 2025 through the Health-Related Social Needs Program (HRSN). However, in the coming years, MassHealth funding for nutrition services may be threatened. There is the challenge of a strained state budget. There is also the question of federal approval of Massachusetts’s Section 1115 demonstration waiver under the current administration.
Subject to federal approval, HRSN is funded through an 1115 waiver that expires in 2027. MassHealth will likely seek renewal for its waiver so that HRSN and other key initiatives can continue. It remains to be seen how the Centers for Medicare and Medicaid Services (CMS) will conduct such negotiations under the current administration. In spring 2025, CMS rescinded the former administration’s HRSN framework; however, CMS left open the possibility of HRSN approval on a case-by-case basis.
“There is opportunity for potential alignment between the HRSN Program and the Make America Health Again movement,” Sheff said. “But I do think the expectation is that moving forward CMS is going to be more conservative about what they approve.”
MassHealth faces a daunting challenge: reduced funding overall and new administrative requirements (i.e., the implementation of work requirements). The path forward for non-required initiatives, such as HRSN, is uncertain.
Resources
- Health Care for All consumer helpline: 800-272-4232
- MA Health Connector: Enrollment Assisters
- Medicaid Cuts: The How and the Why
How to Mitigate the Harm of These Changes
Consumer Communication and Education
It’s critical that beneficiaries understand that even though SNAP and Medicaid have changed, many beneficiaries will still qualify. According to Baker and Sheff, a major risk of these changes is that reporting and other paperwork requirements will prevent people from staying enrolled, even when they qualify. Beneficiaries need support understanding their eligibility (including any exemptions they may have) as well as how to take action to stay enrolled.
“The importance of outreach and engagement cannot be overstated,” Sheff says. “Part of that falls to government. But I would say anybody who’s working with MassHealth should do their part.”
Advocacy to Policymakers
In this more constrained funding environment, CBOs and healthcare organizations are urged to speak up, make their case, and broadcast their value. “MassHealth will be under extraordinary pressure to reduce costs,” Sheff says. “So let’s make sure we don’t lose sight of the importance of programs like HRSN. Be more vocal than you have been in the past. Ask for the public support you need.”
Stay Informed
- Center on Budget and Policy Priorities
- Health Care in Motion newsletter, from the Center for Health Law and Policy Innovation of Harvard Law School
- Kaiser Family Foundation
