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.
Frequently Asked Questions
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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Yes. The CHIP enhanced FMAP will continue to be available for the expenditures for children shifted from CHIP to Medicaid, as long as their income is greater than the state's March 31, 1997 Medicaid income standard for children. In other words, if CHIP funding was available for this group of children when they were covered in a separate CHIP, it will continue to be available when the children are covered under Medicaid. The CHIP enhanced FMAP is available for uninsured children whose income exceeds that income standard, whether the children previously qualified for or were enrolled in a separate CHIP program or not.
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Yes, consistent with Medicaid coverage rules. States must cover children ages 6-18 in the new mandatory Medicaid group and Medicaid is the secondary payer to other insurance. All children must be covered without regard to their insurance status but title XIX funds must be used to cover such children who have creditable health insurance.
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Yes. As with children who move from a separate CHIP to Medicaid because of the change in Medicaid eligibility to 133 percent FPL, children moving from CHIP to Medicaid because of the application of the 5 percent disregard may also be funded through title XXI.
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Yes. As stated in the Frequently Asked Questions pertaining to this provision posted on April 25, 2013, states may claim the enhanced match available under title XXI for children who lose Medicaid eligibility due to the elimination of income disregards as a result of the conversion to MAGI. These children now meet the definition of a targeted low-income child and will be enrolled in a separate CHIP in accordance with section 2101(f) of the ACA. If states choose the option to maintain Medicaid eligibility for such children title XIX funds and regular FMAP must be used to provide coverage.
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Generally, no. Section 2105(c) (8) of the Social Security Act limits enhanced FMAP to the expenditures associated with children whose effective family income is at or below 300 percent FPL. Expenditures for children whose effective family income exceeds 300 percent of the FPL are matched at the regular Medicaid FMAP rate rather than the enhanced FMAP. However, the enhanced matching rate continues to be available for expenditures on populations whose income exceeds 300% FPL in states in which the income standard exceeds 300 percent as a result of MAGI conversion, as well as for states with approved income limits for CHIP above 300% of the FPL prior to the passage of the Children's Health Insurance Program Reauthorization Act (CHIPRA).
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States are no longer allowed to cover parents in CHIP after Sept. 30, 2013 and therefore, are no longer eligible to receive the enhanced CHIP FMAP for expenditures for parents.
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We are working with states to help them complete all of the steps needed to implement the new adult group on January 1, 2014. States need to make changes and updates to their Medicaid state plan (and sometimes waiver programs) as expeditiously as possible, so they can accurately determine who is eligible, assist individuals with enrollment, contract with health care plans, provide access to quality care health care for their beneficiaries, and receive federal financial assistance for these costs. They will also need to submit state plan amendments (SPAs) describing how they will claim the appropriate federal medical assistance percentage (FMAP) for expenditures for the new adult group. In addition, states will need to submit their budget estimates related to the new adult group, so CMS can provide funding at the appropriate levels.
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As states compile their budget estimates for the first calendar quarter of 2014, or for future quarters, states that will adopt the new adult group should include in those estimates the impact of the increased newly eligible FMAP rates available for the new adult group. CMS typically issues quarterly grant awards prior to the beginning of the quarter, so that states can make payments to Medicaid providers during the quarter. We will issue grant awards associated with expenditures related to the new adult group once eligibility SPAs reflecting the new adult group have been approved and the associated FMAP SPAs have been submitted.
For states that have not yet reached these milestones, CMS can quickly issue supplemental grant awards once the new adult group SPA is approved and the FMAP SPA is submitted. States expanding coverage are likely to achieve these milestones early in the quarter but, as always, SPAs do not need to be submitted until the end of the quarter to be made effective retroactively to the beginning of the quarter. CMS is working with states to secure approval of new adult group eligibility SPAs on an expedited basis, and will provide technical assistance as needed so that states can submit their FMAP SPAs in a timely manner.
After the grant award reflecting estimated new adult expenditures is issued, states will be able to draw down federal funds during the quarter, in advance of submitting claims for such expenditures. Finally, as is our regular process, states can begin claiming for expenditures made during the quarter following the close of the quarter, subject to approval of all required eligibility, benefit, and FMAP SPAs. States that do not have approved SPAs can claim retroactively after approval is granted, as long as timely filing requirements are met.
States with waivers should note that, as always, waivers are prospective only - so any waiver changes need to be submitted and approved by January 1, 2014 if a state if trying to make coverage effective on that date.