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Frequently Asked Questions

Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.

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Will any individuals lose coverage as a result of the new MAGI-based income methodology?

No one loses coverage as a result of converting to MAGI rules, but, in states that don't adopt the new adult eligibility group, it is possible that some individuals will lose coverage.

The Affordable Care Act ensured that no one would lose health coverage--if they were not eligible under the new MAGI standards either they would be covered under the new Medicaid adult coverage group or they would be able to purchase insurance through the Marketplace with the benefit of a premium tax credit and likely cost sharing reductions. Following the Supreme Court's decision, the Medicaid expansion is voluntary for states, and in states that do not adopt the new coverage group some individuals may lose coverage at the time of their renewal when the new rules are applied.

FAQ ID:92501

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It looks like in some states CHIP has gotten smaller; do the new MAGI rules result in smaller CHIP programs?

No, the change to MAGI does not affect the size of CHIP Programs.

The number of children in CHIP does not change as a result of MAGI because the new standards have the same value as the old standards; they simply translate the state's pre-MAGI two-step policies into a simpler one-step calculation. For example, if the state under old rules covers children in Medicaid with incomes up to 150% of the Federal Poverty Limit (FPL) and CHIP from 150% to 200% of the FPL, and under MAGI the new Medicaid income standard is 160% of the FPL, that doesn't mean that children between 150% and 160% are losing CHIP coverage--it means that many children between 150% and 160% of the FPL using net income standards were already eligible for Medicaid because of the use of disregards.

FAQ ID:92506

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Do the new MAGI standards mean that more children will move from CHIP to Medicaid?

No, the number of children moving from CHIP to Medicaid is not affected by the change to MAGI.

Under the law, those states that cover children ages 6-18 with incomes between 100% and 133% of the FPL in CHIP will be transitioning these children to Medicaid so that children under 133% of the FPL, regardless of their age, are eligible for the same coverage program (some states will continue to have different, higher income standards for younger children). The change to MAGI standards does not change the number of children who will move from CHIP to Medicaid.

FAQ ID:92511

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With regards to MAGI, can states that want to have one eligibility level for children, ages 1-18, do so?

Yes. The new converted standards are based on the state's current income eligibility standards and their pre-2014 disregards. So if children in different age groups have different effective eligibility levels under a state's pre-2014 rules, the children will have different converted standards. For example, if a state has been covering children aged 1-5 to 133% FPL and children aged 6-18 to 100% FPL, the state's MAGI eligibility standard in 2014 may be 139% FPL for children aged 1-5 and 133% FPL for older children.

FAQ ID:92516

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With regards to MAGI, can states that want to have a "rounded" number for their eligibility standards do so or must they stay with the converted standards?

Yes, states can adjust their standards within certain limits established by law.

States can adjust both their adult standards (e.g., for pregnant women) and their children standards, as long as they do not reduce eligibility levels below minimum standards established by the law. CMS can advise states of their options.

FAQ ID:92521

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With respect to MAGI conversion, how will the 5% disregard be applied?

The Affordable Care Act established an income disregard equal to five percentage points of the FPL disregard "for the purposes of determining income eligibility" for individuals whose eligibility is based on MAGI. In our final rule issued July 15, 2013, we provide that the disregard is applied to the income calculation of individuals only to the extent that the disregard matters for the purposes of determining eligibility for Medicaid or CHIP under MAGI-based rules-that is, those for whom the application of the disregard means the difference between being eligible for Medicaid or CHIP and being ineligible.

The disregard matters for purposes of determining Medicaid or CHIP eligibility only in cases where individuals have MAGI-based income that is above the highest applicable income standard under the program (Medicaid or CHIP), but would be within that income standard if the disregard were applied. This is the case only when the MAGI-based income is no higher than five percent of the FPL higher than that income standard. The disregard would not be applied for a determination of the particular eligibility group in which the individual qualifies, but only for overall eligibility for Medicaid or CHIP. We understand that this policy changes how disregards have been applied in the past, but believe this policy should be administratively simple to apply, for example, by applying the disregard at the point before a decision of ineligibility based on income would otherwise be made. This also ensures that the disregard does not reduce the "newly eligible" population for whom the increased federal matching rate is available.

For example, in a state that extends coverage to the new adult group, if a parent applied and has MAGI-based income within five percentage points of the FPL above the net income standard for the mandatory parent/caretaker relative group, the disregard would not apply because the disregard would not be needed for eligibility. The parent could be made eligible in the adult group instead. In that same state, if a parent applied with MAGI income within five percentage points of the FPL above the net income standard for the adult group (133% FPL), the five percent disregard would be applied to ensure that the parent could obtain eligibility in Medicaid and the parent would be made eligible in the adult group.

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FAQ ID:92591

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Is Arkansas seeking a partial expansion of Medicaid, with individuals above the poverty threshold getting tax credits for private qualified health plans (QHPs) in Health Insurance Marketplaces (Exchanges) and those with income below the poverty threshold receiving Medicaid?

No. As stated in the past, the Affordable Care Act does not provide for a phased-in or partial expansion. States that wish to take advantage of the enhanced federal matching funds for newly eligible individuals must extend eligibility to 133% of the federal poverty level (FPL) by adopting the new adult group. Arkansas has initiated discussions about "premium assistance" options for Medicaid beneficiaries; partial expansion is not part of these discussions.

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FAQ ID:93836

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What is Premium Assistance in Medicaid?

The Medicaid statute provides several options for states to pay premiums for adults and children to purchase coverage through private group health plans, and in some case individual plans; in most cases, the statute conditions such arrangements on a determination that they are "cost effective." Cost effective generally means that Medicaid's premium payment to private plans plus the cost of additional services and cost sharing assistance that would be required would be comparable to what it would otherwise pay for the same services. Similar provisions also apply in the Children's Health Insurance Program (CHIP).

Under all these arrangements, beneficiaries remain Medicaid beneficiaries and continue to be entitled to all benefits and cost-sharing protections. States must have mechanisms in place to "wrap-around" private coverage to the extent that benefits are less and cost sharing requirements are greater than those in Medicaid. In addition under the statutory options in the individual market beneficiaries must be able to choose an alternative to private insurance to receive Medicaid benefits.

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FAQ ID:93841

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Would the Department of Health and Human Services (HHS) consider premium assistance demonstrations for the individual market?

Some states have expressed interest in section 1115 demonstrations to provide premium assistance for the purchase of QHPs in the Exchange. Under section 1115 of the Social Security Act, the Secretary may approve demonstration projects that she determines promote the objectives of the Medicaid program. HHS will consider approving a limited number of premium assistance demonstrations since their results would inform policy for the State Innovation Waivers that start in 2017. As with all such demonstrations, HHS will evaluate each proposal that is submitted and consider it on a case by case basis relative to this standard.

With regard to premium assistance demonstrations, HHS will consider states' ideas on cost effectiveness that include new factors introduced by the creation of Health Insurance Marketplaces and the expansion of Medicaid. For example, states may quantify savings from reduced churning (people moving between Medicaid and Exchanges as a result of fluctuating incomes) and increased competition in Marketplaces given the additional enrollees due to premium assistance. As with all demonstration proposals, the actuarial, economic, and budget justification (including budget neutrality) would need to be reviewed and, if approved, the program and budgetary impact would need to be carefully monitored and evaluated.

To ensure that the demonstrations further the objectives of the program and provide information in a timely way, HHS will only consider proposals that:

  • Provide beneficiaries with a choice of at least two qualified health plans (QHPs).
  • Make arrangements with the QHPs to provide any necessary wrap around benefits and cost sharing along with appropriate data; this would be done within the context of premium assistance, for example through a supplemental premium. This ensures that coverage is seamless, that cost sharing reductions are effectively delivered and that there is accountability for the payments made.
  • Are limited to individuals whose benefits are closely aligned with the benefits available on the Marketplace, that is, individuals in the new Medicaid adult group who must enroll in benchmark coverage and are not described in SSA 1937(a)(2)(B)(an example of a population that is described in SSA 1937(a)(2)(B) is the medically frail). Marketplace plans were not designed to offer broader benefits and could experience unexpected adverse selection due to enrollment of groups that are described in SSA 1937(a)(2)(B).
  • End no later than December 31, 2016. Starting in 2017, State Innovation Waiver authority begins which could allow a range of State-designed initiatives.

In addition, a state may increase the opportunity for a successful demonstration by choosing to target within the new adult group individuals with income between 100 and 133 percent of FPL. Medicaid allows for additional cost-sharing flexibility for populations with incomes above 100 percent of FPL; this population is more likely to be subject to churning and would be eligible for advance premium tax credits and Marketplace coverage if a state did not expand Medicaid to 133 percent of FPL.

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FAQ ID:93846

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Is Arkansas seeking a partial expansion of Medicaid, with individuals above the poverty threshold getting tax credits for private qualified health plans (QHPs) in Health Insurance Marketplaces (Exchanges) and those with income below the poverty threshold receiving Medicaid?

No. As stated in the past, the Affordable Care Act does not provide for a phased-in or partial expansion. States that wish to take advantage of the enhanced federal matching funds for newly eligible individuals must extend eligibility to 133% of the federal poverty level (FPL) by adopting the new adult group. Arkansas has initiated discussions about "premium assistance" options for Medicaid beneficiaries; partial expansion is not part of these discussions.

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FAQ ID:93851

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