Frequently Asked Questions

States have broad flexibility under the final regulations at section 435.956 regarding verification of non-financial eligibility requirements, other than citizenship and immigration status. States may, for example, accept self-attestation of the former foster care status and enrollment in Medicaid required for eligibility under this group.

In addition, section 435.952(c)(2)(ii) provides that the state may not require paper documentation unless electronic data to verify the individual's status as a former foster care individual is not available and establishing such a data match would not be effective. States that do not currently have an electronic data base that could be used for verifying an applicant's former status as a foster care child receiving Medicaid should consider the effectiveness of developing such capability in accordance with the regulations. The 90/10 federal match for systems development would be available for this purpose through Dec. 2015, as outlined in 42 CFR Part 433, available at http://www.gpo.gov/fdsys/pkg/FR-2011-04-19/pdf/2011-9340.pdf.

We note that, over time, verification of former foster care status may become less important at the point of application because, in accordance with sections 471(a)(16) and 475(1)(D) and (5)(H) of the Act, Title IV-E/B agencies are required to assist and support a foster youth in developing a transition plan during the 90-day period before the youth attains age 18, or, if applicable, before the later age elected by the state or tribe, that addresses specific options for the youth, including health insurance coverage. We encourage child welfare agencies and state Medicaid agencies to begin incorporating coverage under this group in the transition planning for foster care youth as soon as practicable. More information about transition planning requirements for youth in foster care can be found in Section C of ACYF-CB-PI-10-11, available at https://www.acf.hhs.gov/cb/policy-guidance/pi-10-11.

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No. In accordance with section 1902(a)(10)(G) of the Social Security Act, eligibility under the group for former foster care children takes precedence over eligibility under the new adult group. Thus, individuals who meet the requirements for both of these groups must be enrolled under the group for former foster care children.

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No. Under the law, the state's regular federal matching rate applies for individuals eligible under the former foster care group.

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Section 2101(a) of the Affordable Care Act amended section 2104(a) of the Social Security Act to extend title XXI funding for states' CHIP fiscal year allotments through September 30, 2015, the end of federal fiscal year (FY) 2015. The new law also amended section 2105(b) of the Social Security Act to increase the enhanced Federal Medical Assistance Percentage (Enhanced FMAP) rate by 23 percent applicable for certain expenditures for the period FY 2016 through FY 2019, but in no case will the enhanced FMAP exceed 100 percent. In the absence of additional legislation, the FY 2015 allotments would continue to be available through September 30, 2016. The Secretary also has the authority to redistribute prior unexpended allotments to states experiencing shortfalls.

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Yes. States have a limited opportunity to expand CHIP eligibility without a section 1115 demonstration (through the use of a block of income disregard) that will then get incorporated into a MAGI converted eligibility level. Any state interested in expanding CHIP eligibility above 200 percent of the FPL must submit a state plan amendment (SPA) before Dec. 31, 2013. After such time, states could expand eligibility through a demonstration. (Of course, if a state has not already expanded eligibility to 50 percent points above the MAGI-converted Medicaid income level that was in effect in 1997, that option for expansion without demonstration authority will remain available after Dec. 31, 2013.)

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We believe these files have information that states can rely on. As with any transmission of data or logic process, discrepancies may arise. However, we have done quality reviews and continue to act on reports of issues as quickly as possible by investigating them and introducing systems fixes as needed. We are continuing our testing and quality assurance efforts as well. We expect that states will be doing the same on accounts transferred from states to the FFM. We will continue to rely on our daily desk officer calls and our SOTA process to follow up with states on any questions that may arise.

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As applicant information is entered into state systems, there will be some applicants that will be known to the system, such as people who previously applied to or enrolled in Medicaid, family members of current beneficiaries, and possibly beneficiaries of other human services programs. If, based on this information known to the system, the state finds information that indicates the individual is unlikely to be eligible for Medicaid under MAGI rules, then the state may treat such information as an inconsistency. Just as states are not enrolling applicants on the flat file who have an inconsistency in their income or residency information based on FFM verification without further evaluation, states may also not enroll applicants based on the flat-file data for whom there are discrepancies based on state system information. We will work with states that would like to pursue other options for dealing with information found in state systems when entering individuals from the flat file.

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If the state would like to exclude individuals from enrollment based on the flat file, please reach out to CMCS to discuss the state's options. Our goal in offering this flat file option is to provide an additional avenue for enrollment and we will work with states on how they might best maximize the use of these files.

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In a letter dated November 29, 2013, (see http://www.medicaid.gov/Federal-PolicyGuidance/downloads/SHO-13-008.pdf) CMS offered states the opportunity to apply for a waiver under section 1902(e)(14)(A) of the Social Security Act to allow them to make temporary enrollment decisions based on the information included in the flat file. So, as long as states follow the procedures outlined in the guidance and other applicable rules with respect to eligibility and claiming, federal funding is available for this temporary enrollment. Individual's circumstances might change and other factors might arise that could change the outcome of the eligibility determination once the state evaluates eligibility based on the full account transfer. Federal funding is not at risk for states that follow appropriate procedures to enroll beneficiaries based on the FFM's determination or assessment of eligibility.

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Since the waiver is a temporary grant of authority, if changes in circumstance are reported then states have the flexibility to choose to act on reported changes immediately or wait until the full determination occurs. If a state has the capability to review and process the changes reported they can do so, and if a state does not wish to act upon reported changes during this temporary waiver period that is also permissible. States should discuss with CMS how to document the state's policy regarding changes in circumstance in the waiver request.

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