This table depicts key elements of states’ proposed approach to verifying the factors of eligibility for coverage in Medicaid and Children's Health Insurance Program (CHIP). The Affordable Care Act and accompanying federal regulations have established a modernized, data driven approach to verification of financial and non-financial information needed to determine Medicaid and CHIP and Marketplace eligibility in 2014. Beginning in January 2014, states rely on available electronic data sources to confirm information included on the application, promote program integrity, while minimizing the amount of paper documentation that consumers need to provide. Every state submitted a “Verification Plan” to the Centers for Medicare & Medicaid Services (CMS) outlining their respective approach to verification.1 This table summarizes the states proposed processes for verification of income and other factors of eligibility and the steps the states will follow in requesting further information when appropriate. For a snapshot of states’ core functionality at the beginning of 2015, the Federally Facilitated Marketplace Year 2 Consult report provides an overview of state progress in implementing verification policies.
|Eligibility Factor||Electronic Data Source Used at Application2||Self-Attestation Accepted at Post-Eligibility Verification2||Self-Attestation Accepted at Application3|
|Age (Date of Birth)||27||7||17|
|Social Security Number||51||N/P||N/P|
|Eligibility Factor||Reasonable Explanation Requested from the Individual4||Paper Documentation Required from the Individual4|
|Age (Date of Birth)||23||34|
|Social Security Number||0||496|
- Regulations at 42 CFR 435.945(j) and 457.380(j), require states to develop, and update as modified, a Medicaid/CHIP verification plan describing the verification policies and procedures adopted by the agency in accordance with §435.940-435.965, and §457.380.
- As outlined in section 1137 of the Social Security Act and 42 CFR 435.952(a), electronic data shall be requested and utilized to the extent that such information may be useful in verifying eligibility. The agency must promptly evaluate information received through electronic data sources to determine whether such information may affect an individual's eligibility.
- According to 42 CFR 435.945(a), except where the law requires other procedures (such as for citizenship and immigration status information), states may accept attestation of information needed to determine Medicaid eligibility without requiring further information (including documentation) from the individual. If a state becomes aware of data that affects the individual's eligibility, the state is required to act on that information. The agency must require that all initial applications are signed and that the information is accurate under penalty of perjury.
- As described in 42 CFR 435.952(c)(2), if information provided by or on behalf of an individual is not reasonably compatible with information obtained through an electronic data source, the agency must seek additional information, which may include a reasonable explanation and/or paper documentation
- Four states indicated that self-attestation will be accepted for income (e.g. in-kind support, nominal cash support, etc.) in which data sources are not available for verification. One state indicated that self-attestation is used for the CHIP population only.
- Two states indicated they would not ask for paper documentation of social security numbers (SSNs), but will assist the individual in resolving discrepancies with the Social Security Administration.
- Three states indicated that if they have information that is not reasonably compatible with the individual's attestation of pregnancy, the state would pursue a reasonable explanation. Two of those states indicated that they may also request paper documentation in the case of a discrepancy.
Note: The state counts above are based solely on the Yes/No selections made by the states and do not take into account the textual explanations that are detailed in the comments section of the verification plan. Some states indicated "yes" for multiple cells to represent treatment of different populations. For example, some states indicated that they utilize their internal integrated data source to verify applicable eligibility factors for Supplemental Nutrition Assistance Program (SNAP)/Temporary Assistance for Needed Families (TANF) populations, but accept self-attestation for individuals that are not included in that population. These states are counted under the "Self-Attestation Accepted at Application without Additional Verification" column, as this is the process indicated for the majority of their population.