Some Dual-Eligible Patients Just Lost QMB Protection. Check Before You Bill.
Starting October 1, 2026, some patients who have both Medicare and Medicaid are losing their Medicaid coverage, and with it their Qualified Medicare Beneficiary (QMB) status. CMS flagged it in its October 22 MLN Connects newsletter. If your front desk still treats these patients as QMBs, or still bills Medicaid as their secondary payer, your claims and patient statements will be wrong.
What changed
A federal law passed in 2025 (P.L. 119-21, which CMS calls the Working Families Tax Cut legislation) generally limits federal Medicaid funding for noncitizens to three groups: lawful permanent residents, Cuban and Haitian entrants, and COFA migrants (with some exceptions). The same law limits Medicare entitlement to the same groups.
For a dual-eligible patient who loses Medicaid under this rule, two things change:
They're no longer a QMB, so the QMB cost-sharing protections no longer apply.
Medicaid is no longer their secondary payer.
What CMS tells providers to do
Before you bill or collect cost sharing, verify the patient's:
Current Medicaid eligibility
Current QMB status
Coverage that applies to the visit
If you bill Original Medicare, you can check Medicaid eligibility through HETS, CMS's eligibility check, using CMS's Checking Medicare Eligibility guide. If the patient is in a Medicare Advantage plan, the plan tells its providers about any billing protections that still apply.
What this means for your front desk
Re-verify every dual-eligible patient at each visit for now. Last month's eligibility check may already be out of date.
Get QMB status right before sending a statement. Billing a patient who still has QMB status for Medicare cost sharing is not allowed.
If Medicaid coverage ended, stop sending those claims to Medicaid as secondary.
Eligibility checks are one of the services Korps runs for practices every day.
Source: CMS, MLN Connects Newsletter, October 22, 2026. Checked October 24, 2026.
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