Frequently Asked Questions

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.

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The Affordable Care Act provides significant federal support to ensure the availability of coverage to low-income adults. Enrollment caps limit enrollment in coverage on a first come, first serve basis. Periods of ineligibility delay or deny coverage for otherwise eligible individuals. These policies do not further the objectives of the Medicaid program, which is the statutory requirement for allowing section 1115 demonstrations. As such, we do not anticipate that we would authorize enrollment caps or similar policies through section 1115 demonstrations for the new adult group or similar populations.

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Demonstrations focused on changes to how health care services are delivered, such as the use of managed care, will not generally affect the state's matching rate. Please refer to our February 2013 FAQs, which provide further clarification on the two increased federal match rates: the newly eligible rate and the expansion state rate as well as the final FMAP rule published on April 2, 2013. Additionally, CMS issued two State Medicaid Director letters, on July 10, 2012, that provide guidance on how states can adopt integrated care models without the need for a section 1115 demonstration.

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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.

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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.

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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.

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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.

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Yes. These children are considered to be targeted low-income children and eligible to receive child health assistance in a separate child health program. Other eligibility factors such as the state's separate CHIP upper income limit, current creditable health insurance coverage or other state defined criteria, should not be applied to this population or preclude them from receiving coverage under the separate CHIP. The only exceptions to CHIP eligibility that apply are those found in section 2110(b)(2) of the Social Security Act and implemented through section 457.310(3)(c), which include:

• Children who have access to coverage through a state health benefits plan on the basis of a family member's employment with a public agency ("public employee restriction");
• Children who are inmates of a public institution;
• Children who are patients in an institution for mental disease (IMD).

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Once children protected by Section 2101(f) are enrolled in a separate CHIP, they remain enrolled until their next scheduled annual review (12 months), unless they reach age 19, move out of state, request removal from the program, or are deceased. At the point of renewal, these children will be considered for CHIP eligibility based on all the eligibility criteria applicable to children generally for coverage under the state's separate CHIP, including the income standard.

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We anticipate that this provision will impact a relatively small number of children, and mostly in states without a separate CHIP that already provides coverage for all children above the state's Medicaid income limit. This provision only applies to children who are made ineligible for Medicaid as a result of the elimination of income disregards and are not otherwise eligible for an existing separate CHIP.

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