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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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Can states design a unique benefit package and cost-sharing structure for this population?

Yes. However, the benefit package and cost-sharing structure must be in compliance with separate CHIP rules.

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FAQ ID:93801

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Are states required to submit a CHIP State Plan Amendment to provide coverage for children covered under this option?

Yes, states will need to submit a CHIP SPA for approval to provide coverage to children under this group in accordance with section 457.60. CMS will make available a simplified SPA template on which the state may report how these protected children will be identified and enrolled and information on benefits and cost-sharing.

Because of the flexibility provided states in establishing eligibility for separate CHIP programs, states could establish a group within an existing separate CHIP or as a standalone separate CHIP with eligibility criteria specific to the chosen option. For example, a state could establish a CHIP group with eligibility limited to children losing Medicaid at their 2014 redetermination using MAGI methodology. Coverage provided under this group would sunset when the last child eligible for 2101(f) protection came up for their first annual renewal in CHIP.

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FAQ ID:93806

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Are states required to do a renewal at the end of the section 2101(f) coverage period?

Yes. States will need to conduct a renewal at the end of the 12-month separate CHIP coverage period in accordance with section 457.343 to determine if the child remains eligible for CHIP and, if not, to determine potential eligibility for other insurance affordability programs and transfer the child's account, as appropriate, to the Medicaid agency or the Exchange.

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FAQ ID:93811

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How long does section 2101(f) need to be applied?

As noted above, the protection afforded under section 2101(f) extends until the child comes up for his or her first regular renewal for coverage under the separate CHIP program, which would be 12 months from the child's transfer from Medicaid to the separate CHIP. When the last child eligible for protection under section 2101(f) comes up for renewal in the separate CHIP, the state may discontinue this part of its program.

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FAQ ID:93816

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Will states need to maintain 2013 eligibility determination systems in order to implement Section 2101(f)?

No. Systems programmed to determine eligibility based on 2013 rules would not properly determine eligibility based on MAGI methodologies and therefore could not be used to identify these children. Children protected by section 2101(f) are children who lose Medicaid eligibility after MAGI rules (including household composition and family income) are applied but would have remained eligible if the former disregards had also been applied.

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FAQ ID:93821

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Does the protection under section 2101(f) apply to children currently enrolled in a separate CHIP that lose coverage as a result of the conversion to MAGI?

No. Section 2101(f) does not apply to children made ineligible for a separate CHIP as a result of the elimination of income disregards. Children losing coverage under a separate CHIP must be screened for eligibility for other insurance affordability programs and their cases electronically transferred per section 457.348.

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FAQ ID:93826

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Will states receive the enhanced CHIP match for children protected under section 2101(f)?

Yes. States may claim the enhanced match available under title XXI for children enrolled in a separate CHIP in accordance with section 2101(f).

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FAQ ID:93831

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What methods can states use to execute conversion to modified adjusted gross income (MAGI) as required by the Affordable Care Act?

Effective January 1, 2014, MAGI eligibility rules will be used to determine eligibility for nonelderly, nondisabled eligibility groups. The transition to MAGI also involves converting current net income eligibility standards to MAGI standards. MAGI rules apply regardless of whether a state adopts the new adult eligibility group. The December 28, 2012 Modified Adjusted Gross Income (MAGI) conversion guidance (PDF, 177.59 KB) sets out options for a state to use a standardized MAGI conversion methodology (using Survey of Income and Program Participation (SIPP) data or with state data) or to propose an alternative methodology for converting to MAGI.

There are two potential ways of using the standardized MAGI conversion methodology:

  • States may choose to have CMS calculate the converted income levels for eligibility groups requiring conversion using state-adjusted data from the Census Bureau's SIPP; or
  • States may choose to use their own data as the source for applying the standardized conversion methodology.

For each eligibility group income level that needs to be converted, under the standardized MAGI conversion methodology, individuals whose net income is within 25 percentage points of the FPL below the current income standards will be selected (for example, if the current standard is 80 percent of the FPL, the analysis will include people with incomes between 55 and 80 percent FPL). The next step is to calculate disregards as a percent of FPL for each selected individual. The resulting average disregard amount as a percent of FPL is added to the current net income standard to get the converted standard.

For example, if the average disregard is 8 percent FPL, the converted standard would be 88 percent FPL. This basic process is the same regardless of whether SIPP data or state data is used.

Alternatively, states have the option to propose their own method, subject to approval by CMS. States are asked to provide a statement of intent by February 15, 2013 and must submit their MAGI conversion plans by April 30.

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FAQ ID:93931

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What issues should states consider in choosing which MAGI conversion method and data source to use?

Factors that states might want to consider in choosing an income conversion method and data source include whether the state currently maintains or can easily access the data that are needed to do the conversions, as well as the quality and completeness of the state's data. In addition, states will want to consider whether they have the analytical resources needed to do the conversions with their own data, how long it would take them to run the conversions and how much it would cost to pay a contractor to do the analysis. Finally, states should also consider preferences about using state-adjusted SIPP or state data.

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FAQ ID:93936

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If a state wants to use the Standardized MAGI Conversion Methodology with its own date, what data elements will it need to use?

Detailed information on how to use state data to apply the standardized conversion methodology is forthcoming, but in general states will need 1) information on net income of each person and the size of the Medicaid eligibility unit to establish which enrollees fall within the 25 percentage point band below the current net income standard; and 2) data on the total amount of disregards for each individual within the 25 percentage point band - if this is not stored as a data element in the state's system, this can be calculated by adding up individual disregards, or as the difference between gross income and net income.

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FAQ ID:93941

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