Frequently Asked Questions

In order to ensure a smooth transition of children from a separate CHIP to Medicaid state plan coverage, we encourage states to consider the following points as they prepare for this transition. CMS will work with states on these issues as part of the CHIP SPA review process:

• Proper and timely notification to families, including detailed information on changes related to managed care plans, providers, benefits and cost sharing and what families can expect and need to do in preparation for the transition.
• Education and notification to key stakeholders, including providers, managed care plans, and carve outs, such as mental health or dental services.
• Establishment of a help line to address questions from families during the transition.
• Continuity of care for children in treatment, such as the transfer of prior authorization requests from CHIP to Medicaid providers.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 295.71 KB)

FAQ ID:92636

Yes. While coverage of children protected by 2101(f) is mandated through a separate CHIP, states may instead continue to provide coverage of these children in the state's Medicaid program, thereby eliminating the need to provide coverage in a separate CHIP in accordance with section 2101(f).

If a state chooses this option, children in the state would not lose Medicaid eligibility due to the elimination of disregards under the new "modified adjusted gross income" (MAGI) based methodologies. A Medicaid SPA could cover such children as an optional reasonable classification of children under 42 CFR section 435.222, with a disregard of all income (so that there would be no required determination of income).

The state will need to accurately identify the population of children who otherwise would lose Medicaid eligibility effective January 1, 2014 due to the elimination of income disregards as the new optional reasonable classification of children covered under this group. Children covered under this classification would remain categorically eligible based on their enrollment in Medicaid on December 31, 2013.

In order to limit the protection afforded under this strategy to the same timeframe as the protection which otherwise would be afforded to each affected child under a separate CHIP, the state may define this group as "children who would lose Medicaid eligibility on the initial redetermination of income using MAGI-based income determination due to the elimination of income disregards." The classification would thus not include individuals whose income is being redetermined after that time. This would be parallel to the treatment of this population in a separate CHIP, as automatically eligible in CHIP only when initially losing Medicaid eligibility.

For SPA page S52 for optional reasonable classifications of children that will be submitted for Medicaid state plan eligibility in 2014, the state should enter information for this new reasonable classification of children, just like it will enter information for any other reasonable classification covered by the state. The state would define this reasonable classification using the approved state plan language and would enter that no income test is used for this classification because there was no income test (i.e., all income was disregarded) in 2013.

In addition, once the Medicaid SPA has been approved, interested states should also submit a CHIP SPA (CS14) and check the first option indicating that: "The state has received approval from CMS to maintain Medicaid eligibility for children who would otherwise be subject to Section 2101(f) such that no child in the state will be subject to this provision."

A state interested in covering children protected by section 2101(f) of the ACA should indicate its interest to CMS on its next State Operations and Technical Assistance (SOTA) call.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 295.71 KB)

FAQ ID:92641

In an assessment model, the Federally-Facilitated Marketplace will not make a final Medicaid determination. Instead, the Federally-Facilitated Marketplace will transmit the account to the Medicaid or CHIP agency when they have evaluated the individual and identified him or her as Medicaid or CHIP eligible, and the Medicaid or CHIP agency will make the formal determination. In a determination model, the Medicaid or CHIP agency delegate the authority to make determinations to the Federally-Facilitated Marketplace. In both an assessment and determination model, as described in more detail in 42 CFR section 435.1200, the Federally-Facilitated Marketplace will utilize the same set of eligibility criteria, including selected state-specific options and standard verification procedures. If the state agency chooses the determination model, it must accept the Federally-Facilitated Marketplace determination as final. If the state chooses the assessment model, it must accept findings made by the Federally-Facilitated Marketplace relating to a criterion of eligibility, as long as the Federally-Facilitated Marketplace applies the same policies and verification procedures as those the state agency employs. In a state with a separate CHIP agency, the state Medicaid and CHIP agencies can make different choices allowing the Federally-Facilitated Marketplace to make an assessment or determination. States must choose either the assessment or determination model for all applications; they may not choose between models on a case-by-case basis. States will need to indicate their assessment or determination decision to CMS in a State Plan Amendment, as well as in the Memorandum of Agreement it signs with the Federally-Facilitated Marketplace.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93731

Yes. In an assessment model, where an applicant is assessed eligible by the Federally-Facilitated Marketplace and later found to be ineligible by the state Medicaid agency, the state must transfer the account to the Federally-Facilitated Marketplace. Once received, the state Medicaid determination will be accepted and the account will be assessed by the Federally-Facilitated Marketplace for enrollment in a qualified health plan (QHP) and eligibility for Advanced Premium Tax Credits/Cost Sharing Reductions.

For the determination model, as discussed in section 435.1200(c), as governed by the agreement signed between the Medicaid agency and the Federally-Facilitated Marketplace, the Federally-Facilitated Marketplace determines eligibility for individuals applying to the Federally-Facilitated Marketplace for Medicaid/CHIP based on MAGI, and the state Medicaid or CHIP agency agrees to accept eligibility findings made by the Federally-Facilitated Marketplace.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93736

For individuals assessed eligible for Medicaid/CHIP by the Federally-Facilitated Marketplace, their account will be transferred to the state Medicaid/CHIP agency for a final determination. Once enrolled in Medicaid/CHIP, regardless of where the initial application was submitted, all updates, redeterminations and renewals are handled by the enrolling entity (e.g., the state Medicaid/CHIP agency). No further coordination would be needed with the Federally-Facilitated Marketplace except when an individual is found ineligible for Medicaid or CHIP during the redetermination process. In this case, the state agency would transfer the individual's account to the Federally-Facilitated Marketplace to be assessed for enrollment in a qualified health plan (QHP) and eligibility for Advanced Premium Tax Credits /Cost Sharing Reductions. The Federally-Facilitated Marketplace will not handle redeterminations or renewals for Medicaid/CHIP and will refer individuals to the appropriate site in the state as appropriate.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93741

No. There will not be integration of the Federally-Facilitated Marketplace and states' client registries. Instead, the Federally-Facilitated Marketplace will both verify current Medicaid/CHIP enrollment as part of the Federally-Facilitated Marketplace "applicant" application, and will also conduct quarterly checks of the Medicaid/CHIP enrollment files to determine any overlap with Federally-Facilitated Marketplace enrollment logs.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93746

Section 2101(f) of the Affordable Care Act (implemented through regulations for the CHIP program at 42 CFR section 457.310) provides that states maintain coverage under a separate CHIP for children who lose Medicaid eligibility (including eligibility under a Medicaid expansion or M-CHIP program) due to the elimination of disregards under the new "modified adjusted gross income" (MAGI) based methodologies, which will be effective on January 1, 2014. This provision was intended to create a mechanism to ensure a smooth transition and continuity of coverage for children as the new income counting rules take effect.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93761

Income and expense disregards, including block disregards, that were used to calculate children's income eligibility under the state's Medicaid program prior to January 1, 2014 must be considered in implementing this provision.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93766

Yes, children protected by section 2101(f) must be enrolled in a separate CHIP. A state could design its CHIP program to operate in the same manner with respect to this population as the state's existing title XXI Medicaid expansion program (as a Medicaid look-alike program) so as to reduce administrative burden for states and confusion for families.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93771

The provision should be applied only to children who were enrolled in Medicaid on December 31, 2013 and who lose Medicaid eligibility at their first Medicaid renewal in which MAGI-based methodologies are applied.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 105.59 KB)

FAQ ID:93776