Restructuring DC Health Care Alliance With New Eligibility Rules and Timelines for 2025

The Department of Health Care Finance (DHCF), which administers the Alliance, is preparing for a phased overhaul that will affect eligibility, benefits, and enrollment procedures over the next two years.

The DC Health Care Alliance has long served as a safety net for District residents who fall outside the scope of federal health programs. According to DHCF, the program is designed to ensure that all residents, regardless of immigration status, have access to essential health services. However, due to budget constraints and policy shifts, Mayor Muriel Bowser’s FY26 budget proposal includes amendments to the program with the inclusion of the “DC Health Care Alliance Reform Amendment Act of 2025.” The Council’s Committee on Health has reviewed this amendment to the program and recommended changes to it for the full Council to review.

The Committee made several key changes to the Mayor’s proposal to minimize harm to current and future participants, including removing the requirement for face-to-face recertification, allowing public school enrollment as proof of residency, restoring coverage of durable medical equipment for adults and youth, and increasing the moratorium age for new adult enrollees from 21 to 26 for FY 2026. These changes will begin on August 1, and culminate in the phase-out of adult coverage by October 1, 2027.

Under the new rules, an enrollment moratorium will take effect on August 1, barring new applications from adults aged 26 and older, as modified by the Committee on Health (the original proposal would have set the moratorium at age 21). Adults aged 25 and under will still be able to enroll but only until further notice. Over the following two years, the income eligibility threshold for adults will be reduced in stages. Starting from 210% of the federal poverty level (FPL) to 133% FPL beginning October 1, and then to just 19% FPL by October 1, 2026. On October 1, 2027, coverage for all Alliance participants aged 21 and older will end, leaving the program available only to children and young adults under 21.

Eligibility requirements are also tightening. Adults aged 21 and older will see their income eligibility reduced in phases, while young adults aged 19 to 20 will remain eligible if their income is at or below 216% FPL, and children up to age 18 will continue to qualify with family incomes up to 319% FPL. Notably, benefits for children will remain largely unchanged, preserving access to comprehensive care for the youngest District residents. The Committee on Health also ensured that public school enrollment can be used as proof of residency, and that exceptions to documentation requirements will be made for individuals experiencing homelessness, domestic violence, or similar hardships. While a Social Security number (SSN) is required if one has been issued, the absence of an SSN will not automatically disqualify applicants who lack lawful status.

In a positive development for participants, the previously proposed six-month, in-person recertification requirement has been eliminated by the Committee on Health. Instead, Alliance members will be able to recertify their eligibility annually through remote options such as online, phone, or mail, removing the need for face-to-face interviews for both adults and youth. The Committee also removed the in-person recertification requirement and the six-month recertification requirement for youth under 19.

The benefit package for Alliance participants is also changing. Adults will continue to receive coverage for primary care, inpatient and outpatient hospital services, emergency transportation, prescription drugs, and, as restored by the Committee on Health, durable medical equipment. However, dental care, most behavioral health services, and long term care will no longer be covered for adults. Behavioral health coverage for adults will be limited mainly to outpatient services, with intensive treatments such as residential care excluded. In contrast, youth and children will retain broader coverage, including dental and behavioral health services as designated by the Mayor, and will also retain coverage for durable medical equipment.

To manage costs, DHCF recommended a cap on total adult enrollment in the Alliance at 28,000 or the current number of adult participants, whichever is lower. There will be no cap on the number of children who can enroll in the program. These caps and phased eligibility reductions were part of the Mayor’s proposal, but the Committee on Health worked to mitigate their impact by adjusting the moratorium age and restoring certain benefits.

These changes carry significant implications for current and prospective Alliance participants, as well as for employers and health care providers across the District. Adults who will turn 26 after August 1 should begin exploring alternative coverage options — such as the forthcoming Basic Health Program, employer-sponsored insurance, or plans available through the Affordable Care Act marketplace — well in advance of their birthdays. Existing enrollees aged 26 and older will be able to retain coverage only until September 30, 2027, provided they continue to meet the increasingly strict income requirements. The Committee on Health has urged the District to ensure a smooth transition for those aging out of the Alliance, particularly as the Basic Health Program is implemented.

The loss of dental, behavioral health, and long term care services for adults is expected to increase pressure on emergency departments, community health centers and other safety-net providers, potentially resulting in more uncompensated care. Community navigators and individuals aged 25 and under are encouraged to submit applications before the August 1 moratorium to secure eligibility. Employers with large numbers of undocumented or mixed-status workers should update their human resources materials and consider partnering with navigators or exploring group coverage options to help employees maintain access to care. Stakeholders will have the opportunity to comment on the implementing regulations that the Mayor is required to publish, and they should prepare documentation of residency early to avoid delays. The Committee on Health has indicated it will continue to monitor the impact of these changes and seek further adjustments if necessary.

In the coming months, DHCF will issue new rules and update application platforms to reflect these changes. Organizations and individuals are encouraged to conduct eligibility audits, launch outreach campaigns to inform young adults about the upcoming enrollment moratorium, and map out alternative coverage pathways for those who may lose Alliance eligibility. It will be important to monitor regulatory updates and Council hearings for any further amendments to the program.

Our team will continue to monitor Council deliberations on supplemental funding or other changes. Please contact us with specific questions regarding these significant changes to the Alliance program.