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Modified Adjusted Gross Income (MAGI): Exchange and Medicaid Eligibility Flow Charts Updated per March 2012 Final Rules and June 2012 Supreme Court Decision October 3, 2012 1 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012 These charts illustrate MAGI eligibility processes for premium tax credits, cost-sharing reductions, and Medicaid eligibility. They also detail the new Medicaid eligibility groups, based on our interpretation of the regulations. The document highlights the areas where states have policy flexibility and where decisions need to be made by the State.
Transcript
Page 1: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Modified Adjusted Gross Income (MAGI): Exchange and Medicaid Eligibility Flow Charts

Updated per March 2012 Final Rules and June 2012 Supreme Court Decision

October 3, 2012

1 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

These charts illustrate MAGI eligibility processes for premium tax credits, cost-sharing reductions, and Medicaid eligibility. They also detail the new Medicaid eligibility groups, based on our interpretation of the regulations. The document highlights the areas where states have policy flexibility and where decisions need to be made by the State.

Page 2: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Topic Area Page (s)

Legend

4

Coverage Option Overview 6

MAGI Calculation 8 – MAGI Calculated Public Assistance Categories 10 – Non-MAGI Medicaid – Other Categories 11 – Non-MAGI Medicaid Referral 12 – MAGI Tax Subsidy Determination

8 - 12

Detailed Processes 14 – Check Citizenship/Verify SSN

15 – Check Incarceration 16 – Check State Residency

17 – Determine Household Size

18 – Calculate MAGI Household Size 19 – Determine Household Income 20 – Calculate FPL

13 - 20

State Decisions Needed 22 - 25

2 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Table of Contents

Page 3: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Legend

3 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 4: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

1

4

1

Household Size Info Found

Electronically?

Prior Enrollment

Flow Chart LEGEND

END

Yes No

Process Connector

Continued on to New Page

Process Decision Connector

Continued from Another Page

State Specific Comment

Process Description

Process End Indicator

Start Process Start Indicator

Determine Household Size Detailed Process Indicator

The Exchange must enter into agreements with Medicaid Agency to enable individual and dependents to be screened for Medicaid based on non-MAGI eligibility – example disability.

Regulation/Rule Brief

P#

P# Detailed Process Page #

State Decision Needed *#

138%* FPL 5% disregard included (For optional expansion, applies to Medicaid determinations only)

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Brief Coverage Area

Under PTC eligibility % of income indicates the % of income an individual is required to pay after which the PTC will cover remaining premium. For Cost-sharing this indicates the increased plan Actuarial Value (AV) an individual is eligible for based on a 70% AV silver plan. AV indicates the % of costs the plan covers vs. the individual. At 100% AV an individual has no cost sharing.

**

Page 5: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Coverage Option Overview

5 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 6: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

6

MAGI Calculation

Individual Mandate

Exemption

Coverage Option Overview

Medicaid Non-MAGI • No Medicaid Income

Determination Required • 65 & older • ABD & Medically Needy • Long-Term Services &

Supports • Medicare Cost Sharing • By Request

Non-MAGI Medicaid

Determination

Insured through Medicaid

Coverage Options

Not Insured

Employer Sponsored

Coverage /Other Acceptable

Insured with Minimal

Essential Coverage

Individual Coverage

Insured by non-Exchange

Commercial Plan

Public Assistance

Insured through Exchange

Commercial Plan w/ Subsidy

Medicaid Categories • Children’s Group • Pregnant Women • Parent/Caretaker • Adult (State Option) • SCHIP • Former Foster Children

Tax Subsidy/Cost-Sharing

Reduction

Insured through Medicaid

Not Eligible for Assistance

Insured through Individual

Exchange Commercial Plan

Exchange

Non-Subsidized Individual

Coverage

Individuals enrolled in affordable employer sponsored coverage or eligible for minimal essential coverage through an employer are not eligible to receive advanced payments

for premium tax credits or cost sharing reductions.

The regulation consolidates eligibility categories for parents and other caretaker

relatives, pregnant women, and infants and children under age 19.

The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation

methodology for all individuals applying for the new and consolidated Medicaid categories.

Individuals applying for coverage on the Exchange have the ability to decline to be

screened for eligibility for Medicaid, PTC and cost-sharing reductions.

In States that elect Medicaid expansion, Medicaid eligibility

extends to all non-Medicare eligible individuals under 138%* FPL and tax

credit eligibility extends from 138%*FPL to 400% FPL based on

MAGI.

Individuals can still be eligible for Medicaid based on disability or

other current Medicaid categories; their income would not be calculated

based on MAGI.

Off Exchange – Public

Assistance – Non MAGI

Medicaid

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 7: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

MAGI Calculation

7 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 8: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Request for Public

Assistance/Insurance

Access Federal HUB

MAGI Calculation

Below 400% FPL?

1

Independent Enrollment

through Exchange Public Assistance Enrollment

END

Start

Yes No

Check Citizenship/SSN

Check Incarceration

Check State Residency

Determine Household Size

Determine Household Income

Citizen, Not Incarcerated,

and State Resident?

Yes No

Denied Exchange Coverage

END

P14

P15

P16

P17

P19

The Medicaid Agency must adopt MAGI calculation methodology for all individuals applying for the new

and consolidated Medicaid categories.

Eligibility must be redetermined every 12 months.

When possible the agency must complete the redetermination without requiring

information from the individual.

Individuals that are determined not eligible for Medicaid must

be screened for advanced payments of PTC and cost-

sharing reductions.

Individuals who are in the process of being determined

eligible for Medicaid on a basis other than MAGI must be screened for eligibility in

insurance affordability programs (MAGI Medicaid, Premium Tax

Credits, and Cost Sharing Reductions) for interim coverage.

For Eligibility determinations the Exchange will rely on the federal hub for income and citizenship information, when available.

All individuals have the right to appeal any eligibility determination for

Medicaid, PTC, cost sharing subsidies, or QHP eligibility.

*1

8

In Medicaid, all unborn children counted in determining family size of pregnant women .

Eligible for Employer

Sponsored Plan?

Yes

No

Denied Exchange Coverage

END

If household tax filer does not verify applicants attestation, applicant will not be eligible for advanced payments of the

PTC or cost-sharing reductions.

Individual Case Approved?

No Yes

If an applicant’s attestation cannot be verified, the Exchange must review on a case by case

basis and provide exceptions, as appropriate, and an explanation of circumstances.

The Exchange must accept attestation if the discrepancy or difference does not impact the eligibility of the applicant.

The Exchange must verify whether an applicant is eligible for or enrolled in an employer-sponsored plan.

Non MAGI application or

trigger or request for non-

MAGI review?

2

Calculate FPL P20

Yes

No

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

*2

*2, 3, 4, 5

*6

At any FPL an Indian enrolled in a QHP is eligible for services without cost sharing from Indian Health Services, Indian Tribes, Tribal

Organizations, or Urban Indian Organizations. This special cost-sharing must be provided without the individual having to go through

the determination for insurance eligibility programs.

Includes verification of Indian status. Indians are eligible for reduced and special cost-sharing reductions and may not have to

complete subsidy eligibility process.

Does Not Request Medicaid

Eligibility Review?

Yes

No An applicant can have employer coverage and be MAGI Medicaid eligible or have ESI and Medicaid as payor of last resort (with exception to SCHIP).

Page 9: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

No

MAGI Calculated Public Assistance Categories

1

Under 19 years old?

Children’s Group

Yes

No Pregnant?

Under State’s Income Threshold?

Minimum: Higher of 133% FPL or such higher income standard up to 185% FPL as of 12/19/89 or

7/1/89 had authorizing legislation Maximum: Higher of MAGI equivalent as of 3/23/10 or

3/23/13 income level if higher; or 185% FPL

Yes

Pregnant Women

Group

Parent/Caretaker? No

Yes

Under State’s Income

Threshold?

Minimum: AFDC income

standard as of 5/1/88

Maximum: MAGI equivalent

for 1931 families as of

3/23/10 or 12/31/13 or

7/16/96 AFDC income

standard increased by CPI

Parent/Caretaker

Relative Group

Yes

No

Between Parent/Caretaker

FPL & 138%* FPL?

Option: Adult Group

Have Child under 19 enrolled

in Medicaid or minimum

essentially covered?

Not eligible for Medicaid

Yes No

Option: Adult Group

END

Exchange Commercial Plan

250-400% FPL

No

Determine Tax

Subsidy

Yes

0-250% FPL? No

Yes

No

Between 0%-138%* FPL?

Yes

No

No

Yes

Yes

A new optional category is created for adults between 19 and 65 who are at or below 138%* FPL regardless of

caretaker status.

Under State’s Income Threshold?

Minimum: 133% FPL - or - for

infants under age 1 such higher

income standard as of 12/19/89

or 7/1/89 had authorizing

legislation

Maximum: Higher of 133% FPL;

MAGI equivalent of 3/23/10 or

3/23/13 income level if higher; or

for infants under age 1 185% FPL

9

The regulation consolidates eligibility categories for parents and other caretaker relatives, pregnant women, infants and

children under age 19. Non-consolidated mandatory and optional eligibility groups are maintained.

Below State’s SCHIP income threshold -or- Medicaid enrolled

child on 12/31/13 determined ineligible for Medicaid due to

elimination of income disregards?

Yes

SCHIP

No

Info on App suggests non-MAGI eligible or requests non-MAGI determination

or No Medicaid income determination

required?

2 Yes

*7, 8, 19

Under 26, in foster

care on 18th

birthday, Medicaid

enrolled while in

foster care?

Former Foster

Child Group

No

Yes

No

3

3 3

3

3

3

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

3 4

*19 *19

Page 10: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Non-MAGI Medicaid – Other Categories

2

No income determination

required by Medicaid (e.g., Title

IV-E, SSI, Express Lane)

10

Review for eligibility on basis

of blindness, disability,

medically needy coverage or

need for long-term services &

supports

Non MAGI application,

request for non-MAGI review

or application identifies

potential non-MAGI eligibility

Determined Eligible based on

disability/need for long term

services & supports?

Enrolled in applicable category Eligibility maintained in Adult

Group or Tax Subsidy

Application for Medicare

Savings Program?

Electronic case transferred

to Medicaid &enrolled in

Medicare Savings Program

Yes No

The regulation exempts from MAGI methodology individuals for whom Medicaid does not make an income

determination, Medicare Savings Program individuals, and individuals being determined eligible on basis of blindness,

disability or need for long-term services & supports.

END

END

Electronic Case Transferred

to Medicaid & enrolled in

applicable category

Electronic Case transferred to

Medicaid

Exchange notified of

Medicaid determination

Exchange notified of

Medicaid determination

Exchange notified of

Medicaid determination

END

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Can enroll in Adult Group or PTC and/or

cost sharing reductions while non-MAGI

review is pending.

Page 11: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Non-MAGI Medicaid Referral

3

Individual Request Non-MAGI Medicaid Determination?

OR Exchange have reason to believe eligible for Non-

MAGI Medicaid?

Referral to Non-MAGI

Medicaid

No Yes

END

11 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 12: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Between 100-133% FPL?

Yes No

12

END

MAGI Tax Subsidy Determination

If individual is an Indian below 300% FPL then individual is eligible for Cost Sharing Reduction to

100% of Plan AV.

DRAFT - Eligibility Process Flows -Based on our Interpretation of IRS NPRM 26 CFR PART 1 and February 2012 CCIIO Actuarial Value and Cost Sharing Bulletin

4

PTC** Cost Sharing **

2% of Income 94% Plan AV

Between 133-150% FPL?

Yes No

PTC** Cost Sharing **

3% of Income 94% Plan AV

Between 150-200% FPL?

Yes No

PTC** Cost Sharing **

4% of Income 87% Plan AV

Between 200-250% FPL?

Yes No

PTC** Cost Sharing **

6.3% of Income 73% Plan AV

Between 250-300% FPL?

Yes No

PTC** Cost Sharing **

8.05% of Income 70% Plan AV

Between 300-400% FPL

PTC** Cost Sharing**

9.5% of Income 70% Plan AV

At any FPL an Indian enrolled in a QHP is eligible for services without cost-sharing from Indian Health Services, Indian Tribes, Tribal

Organizations, or Urban Indian Organizations. This special cost-sharing must be provided without the individual having to go through

the determination for insurance eligibility programs.

Page 13: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Detailed Processes

13 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 14: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Citizenship found in federal hub to match attestation?

• Citizen • National • Lawfully Present • Native American

Yes No

14

Yes No

Exchange finds an

inconsistency

END

SSN verified by info in federal

hub?

Eligibility process continues

END

Information verified against information from electronic

sources (DHS) for lawful presence in US, individual

with no SSN and where SSN doesn’t match

Yes No

END

Check Citizenship/Verify SSN Check Citizenship

Eligibility process continues Exchange makes reasonable effort to identify

the inconsistency and notifies individual and

gives 90 days for application filer to provide

satisfactory documentation. Eligibility process

continues and if meets other eligibility criteria,

HIX provide non-Medicaid coverage during

this time.

END

Inconsistency resolved after

90 days?

If enrolled, Individual is

disenrolled

Yes No

Reasonably Compatible?

Start

Agency must verify Indian status and cannot accept self-attestation.

Self-Attestation

*9

Individual remains enrolled

Period can be extended if applicant is making good

faith effort to obtain additional documentation.

*10

The 90 day reasonable opportunity period does not apply to Medicaid. Individual is not enrolled in

Medicaid until the discrepancy is resolved.

Continued Medicaid requirement to provide emergency services to

individuals not eligible for full Medicaid due to their immigration status.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

*11

Page 15: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

15

Approved Electronic Data

source available for

verification of incarceration?

Yes No

END

Check Incarceration Check Incarceration

Reasonably compatible?

END

Inconsistency resolved?

Exchange makes reasonable

effort to identify the

inconsistency

Eligibility process continues

Yes No

Eligibility process continues

Yes

Start

Self Attestation

*9

END END

Exchange makes reasonable effort to identify

the inconsistency and notifies individual and

gives 90 days for application filer to provide

satisfactory documentation. Eligibility process

continues and if meets other eligibility criteria,

HIX provide non-Medicaid coverage during

this time.

Inconsistency resolved after

90 days?

Individual is disenrolled, if

enrolled

Yes No

Individual remains enrolled

Resolution period can be extended if applicant is making good faith effort

to obtain additional documentation.

*12

The 90 day reasonable opportunity period does not

apply to Medicaid.

*10

Incarceration is not a factor of eligibility which needs to be verified for purposes of

determining Medicaid eligibility. It is generally prohibited for Medicaid to cover services while

individuals are incarcerated.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

No

*11

Page 16: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

State Residency found in

federal hub?

Yes No

16

Yes No

Exchange finds an

inconsistency END

Residency verified?

Eligibility process continues

END

Adult: Where living &

intends to reside or is

seeking employment or

employed

Child <21: living in, or state

of residency of

parent/caretaker with whom

child resides

State can accept self-

attestation without further

review

Yes No

END

Check State Residency Check State Residency

Eligibility process continues.

Exchange makes reasonable effort to identify

the inconsistency and notifies individual and

gives 90 days for application filer to provide

satisfactory documentation. Eligibility process

continues and if meets other eligibility criteria,

HIX provide non-Medicaid coverage during

this time.

END

Inconsistency resolved after

90 days?

Eligibility Process Continues Eligibility process stops

Yes No

Data in another Electronic Source &

Compatible?

Start

Document that provides evidence of immigration status

may not be used alone to determine that individual is not

state resident.

Self Attestation

*9, 12

Resolution period can be extended if applicant is making

good faith effort to obtain additional documentation.

If attestation of residency is not reasonably compatible with other

information provided, the Exchange must examine information in data sources that are available to the Exchange and approved by HHS.

*10

The 90 day reasonable opportunity period does not apply to Medicaid. An individual is not enrolled in Medicaid

until the discrepancy is resolved.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

*11

Page 17: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

17

Household Size Info via Fed

Data Hub - Filer?

Yes No

Verified by Requestor?

Yes No

Self-Attestation from

Requestor

Reasonably Compatible?

Yes No

Yes No

Use Self-Attested Household

Size

Requestor Provide

Paperwork

Received and Approved w/in

90 Days?

Not eligible for Continued

Determination Due to

Insufficient Data

END

Use Other Electronically

Found Household Size Use Manually Calculated

Size as Household Size

Start

Use data from Hub as

household size

Data Found via Other

Sources?

Yes

No

Sufficient Electronic Secured

Data Available?

No

END

END

END

END

Agency must accept self-attestation of pregnancy unless the State has information that is not

reasonably compatible with the attestation. States can require verification of pregnancy with

multiples for purposes of determining household size for Medicaid. *9

Basic rule for tax filers is that the household size consists of the

taxpayer and all tax dependents.

In Medicaid, a pregnant woman is considered a household of two (or more if carrying

multiples). States have the option to count the unborn children in determining the family size

of other members of a pregnant woman’s household for Medicaid eligibility purposes.

Calculate MAGI Household Size

P18

Determine Household Size Determine

Household Size

Yes

*14

*12

The Exchange must compute annual household income for the

family based on the number of dependents on the tax return.

Attestation must be verified with the tax filer.

*10

The 90 day reasonable opportunity period does not

apply to Medicaid. Individual is not enrolled in Medicaid until the discrepancy is resolved.

*13

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Calculate MAGI Household Size P18

Page 18: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Is the individual a tax filer?

Yes No

18

No

END

The individual is a non filer

Yes

No

END

Yes

Start

Is the individual claimed as

a dependent?

The individual’s Household size is the tax filing household size

Household size consists of if living with the individual: (1) the individual’s spouse; (2) the individual’s qualifying children ; (3) if the individual is under 19 or 21 and a full time student the individual’s qualifying parents and siblings.

Is the individual: •Other than a spouse, biological, adopted or step child •Under 19 or under 21 & full time student & claimed by non-custodial parent • Living with both parents who will not file joint tax return

Calculate MAGI Household Size Calculate MAGI Household Size

No

*15

Married couples living together are included in the household of the

spouse regardless tax filing status.

If individual cannot substantiate that another individual is a tax

dependent for the year in which Medicaid coverage is sought,

non-filer rules apply.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

In Medicaid, unborn children are included in household size for pregnant

women. State has option to count unborn children in household size for

other household members. *14

Page 19: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

19

Household Income Info via

Fed Data Hub - Filer?

Yes No

Verified by Requestor?

Yes No

Self-Attestation from

Requestor

Reasonably Compatible?

Yes No

Gather sum of income for household: Pay Stubs, Letters of employment

Medicaid count Lump Sum in month received. Grants/ Scholarships not counted (<138%* Only), AI/AN Income not counted

Attest that to an accurate projection of next benefit year income for non-Medicaid.

Yes No

Accept Self-Attested

Household Income without

further verification

Requestor Provide

Paperwork

Received and Approved w/in

90 Days?

Not eligible for Continued

Determination Due to

Insufficient Data or no

longer filer

END

Use Other Electronically

Found Household Income

Use Manually Calculated Income as Household

Income

Determine Household Income Start

Use Fed Hub Electronically

Found Household Income

Data Found via Other

Sources? Yes

No

Sufficient Electronic Secured

Data Available?

Yes No

END

END

END

END

Determine Household Income

Tax subsidy requires filing for continued receipt of benefits.

*9

*12

Must search to see if applicant has filed for unemployment benefits.

Attestation must be verified with the tax filer.

Higher Self-Attestation and

No eligibility impact? < 10% Lower and PTC?

If applicant’s income attestation is higher than reported and does not

impact eligibility OR is no more than 10% below, Exchange must accept

attestation without further verification.

*10

The 90 day reasonable opportunity period does not

apply to Medicaid. Individual is not enrolled in Medicaid until the discrepancy is resolved.

If Medicaid and No eligibility

impact?

*17

*18

Medicaid eligibility is based on current monthly income. Annual income must

be converted to monthly number . State option to use projected annual income for ongoing eligibility. Medicaid MAGI exceptions must be applied including :

• Deduct sources counted as income by IRS but not Medicaid (taxable scholarships, grants; AI/AN exceptions; Lump Sum Payments counted only in month received) •Exclude income of child or other tax dependent who files taxes but isn’t required to •Count Social Security Income that is tax exempt

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

*16

*18

Page 20: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

Calculate FPL

Yes No

20

END

Start Option A

Perform Medicaid

Determination and Re-

Calculate FPL

Calculate FPL

Calculate FPL

States have the option of performing an Assessment via an Exchange and then a Determination through Medicaid (option

A) or a Determination through the Exchange (option B)

Assessed Above 100% FPL or 138%* FPL at State Option

Assessment = Determination for Exchange

*6

Assessed Above 138%* Assessed Above 100% FPL or

138%* FPL at State Option PL Yes No

Replace Assessed FPL with Medicaid Process Calculated

FPL

Medicaid Process FPL Determined

The State-Operated Federal PTC Partnership model may allow contracting with the Federal

Exchange to perform the Determination Assessment as shown

in Option A. Calculate FPL

END

Start Option B

Gather Additional State Medicaid Specific

Information from Applicant

In the event that the State has another entity perform an eligibility assessment,

the State can then collect additional, non-duplicative, information to determine Medicaid eligibility.

If a state selects the option that the Exchange will perform the eligibility

determination, no additional information can be collected at this

time from the applicant.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 21: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

State Decisions Needed

21 DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

Page 22: Modified Adjusted Gross Income (MAGI)...The Medicaid Agency must adopt the Modified Adjusted Gross Income (MAGI) calculation methodology for all individuals applying for the new and

22

1. Will the State use the CMS application or develop a state specific application? For the Non-MAGI application, will the State use the single streamlined application & supplemental forms or an alternative application?

2. A redetermination of eligibility must be made without requiring additional information from the individual when reliable information is available to the State to complete the renewal. What will be considered reliable information?

3. For Medicaid renewals, the State can extend the reconsideration period during which a new application is not required. Will the State offer a longer reconsideration period? The State may also implement a 90 day reconsideration period for reasons other than non-timely submission of renewal materials.

4. The State may replicate the MAGI redetermination process for non-MAGI Medicaid populations. Will the State implement these renewal procedures for non-MAGI?

5. The Exchange may automatically enroll qualified individuals at open enrollment in QHPs. Will this option be implemented?

6. The State may delegate Medicaid determinations to the Exchange or Medicaid may make an eligibility determination in addition to the Exchange’s initial assessment.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

State Decisions Needed (1 of 4)

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23

7. The State can expand the definition of caretaker relative to include another relative based on blood, adoption or marriage, domestic partner or adult with whom the child is living and assumes primary responsibility.

8. In defining who is considered a dependent child for purposes of eligibility for the Medicaid Parent/Caretaker Relative Group, the State may eliminate the deprivation requirement. Dependent children can also be defined as either under 18 or 18 and full time student in secondary school or training if before age 19 child is expected to complete training.

9. Within the rules guidelines for upper and lower limits, State to define rules for what is considered reasonably compatible when self-attestation does not match electronic data. State to determine when self-attestation will be allowed without further verification through electronic data sources.

10. State to determine the reasonable time period for allowing individuals to provide verification documents for Medicaid eligibility determinations.

11. The 90 day grace period for providing documentation to resolve discrepancies may be extended when the applicant demonstrates a good faith effort has been made to obtain the required documentation. Will this option be utilized and under what circumstances?

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

State Decisions Needed (2 of 4)

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12. State to define other electronic data sources (approved by HHS) that will be utilized in addition to those accessed through the Federal Data Hub.

13. For Medicaid eligibility, State may require verification of pregnancy with multiples for purposes of determining household size.

14. States have the option to count the unborn child(ren) in determining the family size of other members of a pregnant woman’s household for Medicaid eligibility purposes.

15. For purposes of determining household composition for Medicaid, State has option to count children as either under Age 19 or under Age 19 or in the case of full-time students, under 21.

16. If individual is found Medicaid ineligible due to lump sum payment, State may opt to reconsider eligibility in a subsequent month without requiring a new application.

17. For a tax dependent claimed by an individual other than a spouse or parent, the State has the option to count as income available cash support provided by the tax filer.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

State Decisions Needed (3 of 4)

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18. For individuals determined Medicaid eligible under MAGI, states may elect to base ongoing financial eligibility on current monthly household income or projected annual income for the remainder of the calendar year. Thus, State needs to decide whether to use a point in time income or projected annual income in the Exchange. State can also opt to continue to account for reasonably predictable fluctuations in income for Medicaid determinations.

19. States to determine income standard for Medicaid consolidated groups within minimum and maximum parameters defined in federal regulation.

DRAFT - Eligibility Process Flows -Based on our Interpretation of 42 CFR Part 435 Subsection B & C and 45 CFR Part 155 Subsection D Published March 2012

State Decisions Needed (4 of 4)


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