As the state prepares to transition to a unified disability determination system, thus ending the Medicaid spend-down program, additional information about who will be affected by the transition, and the impact of these changes, has been released. The Governor’s Office of Health Transformation (OHT) published an overview of the changes. The impact of the state’s transition from a 209(b) state to a 1634 state (this means the state is implementing Section 1634 of the Social Security Act, rather than using Section 209(b)) will vary depending on an individual’s current eligibility status and income. Under the new eligibility criteria, those who meet disability under Supplemental Security Income (SSI) will also qualify for Medicaid. Medicaid income and asset limits will increase to match current SSI eligibility criteria at 75 percent of the Federal Poverty Level (FPL) or $743 of income and a $2,000 asset limit. The Center for Community Solutions has been following the implementation of these changes as part of a group of interested stakeholders working closely together, and with the Ohio Department of Medicaid (ODM) to help people who are impacted by these changes have accurate, timely, and clear information.
ODM has stated that all current Medicaid aged, blind, and disabled (ABD) enrollees will be automatically moved over to the new system and retain full Medicaid benefits, without spend-down. This automatic transition also applies to anyone who spent-down to Medicaid eligibility levels between July 1, 2015, and June 30, 2016, even if they do not fall into one of the previously mentioned ABD categories. This transition to the new system is planned for July, 2016. ODM is awaiting a response from the federal Centers for Medicare and Medicaid Services (CMS) to allow a waiver of ABD Medicaid renewals for July 1 – December 31, 2016. This will allow time to adjust to the new disability determination system. If approved, annual renewals will commence January 1, 2017, and the new eligibility criteria will apply moving forward. The new eligibility criteria will apply to anyone seeking new Medicaid coverage as of July 1, 2016.
A subset of the current Medicaid spend-down enrollees did not spend-down within the last 12 months (July, 2015- June, 2016) and do not otherwise meet the new eligibility criteria. These individuals will need to find health coverage through the federal Marketplace and, based on their income, should qualify for subsidies to purchase insurance.
These changes are complex and happening soon. ODM has been working with a group of stakeholders to craft letters that will be sent to individuals to notify them of changes to their coverage. Making sure that these letters are timely and easily understood is important, so that people can stay connected to the appropriate form of health coverage.
The Office of Health Transformation provided in its overview of DDR a table that outlines how different populations will be impacted by these changes. This table is the source for the information below, but has been broken out by the different populations that are impacted. The first and second tables describe the populations that will be automatically transitioned to the new system (some with specific action required). The third table describes the populations who will have to seek other sources of health coverage.
Long-Term Care or Medicaid ABD Recipients Residing in Community
Population Description | Monthly Income | Source of Coverage- Post Transition | Action Required | Estimated Number of People Impacted[i] |
Long Term Care (includes MBIWD[ii]) |
<$2,199 (225% FPL) | Medicaid | None | 131,042 |
>$2,199 (225% FPL) | Medicaid | Establish a Qualified Income Trust (QIT) (also known as Miller Trust) prior to redetermination | 8,870 | |
209(b) Community ABD (includes MBIWDii) |
<$643 (64% FPL) | Medicaid | None | 206,480 |
Spent-down to $643 in at least 1 of 12 prior months | Medicaid | None | 34,043 |
SSI Recipient, Single Adult with Income between 75 and 138% FPL, or Individual with Severe and Persistent Mental Illness
Population Description | Monthly Income | Source of Coverage- Post Transition | Action Required | Estimated Number of People Impactedi |
SSI Recipient | <$743 (75% FPL) | Medicaid | None | 11,804 |
Single Adult | $743-$1,367 age <65 (75-138% FPL) |
Medicaid | None | 3,943 |
Individuals with Severe and Persistent Mental Illness (SPMI) | $1,367-$2,199 with SPMI (138-225% FPL) | Medicaid & Specialized Recovery Services (SRS) |
Enroll in Medicaid SRS waiver prior to next redetermination | 5,527 |
Individuals Who Will Move to Other Sources of Health Coverage
Population Description | Monthly Income | Source of Coverage- Post Transition | Action Required | Estimated Number of People Impactedi |
Transition from Medicaid Spend Down to Medicare Only | $743-$1,337 (75-135% FPL) |
Medicare Premium Assistance Program (MPAP) | Enroll in MPAP | 2,813 |
>$1,367 (138% FPL) | Medicare | Enroll in Medicare | 12,483 | |
Individuals Who Did Not Spend-Down in Any of the Last 12 Months and Do Not Meet Income Eligibility Criteria | $990-$3,960 (100-400% FPL) |
Federally Subsidized Private Insurance in Marketplace |
Private Insurance Enroll in a Marketplace plan | 18,285 |
>$3,960 (400% FPL) | Private Insurance | Enroll in private insurance | 469 |
Source for all tables and citations: Governor’s Office of Health Transformation, Simplify and Integrate Eligibility Determination, Ohio’s Disability Determination Redesign http://www.healthtransformation.ohio.gov/LinkClick.aspx?fileticket=nwrdhnOoQqo%3d&tabid=117, Accessed May 10, 2016.
[i] Estimated enrollment is based on Ohio Medicaid analysis of data in CRIS-E. The actual conversion from CRIS-E to Ohio Benefits will be based on data available in July 2016.
[ii] Adults with a disability who work but have monthly income below $2,475 are eligible to pay a premium and “buy in” to Medicaid coverage. Individuals enrolled in Medicaid Buy-In for Workers with Disabilities (MBIWD) are included in the ABD community and long-term care enrollment totals and will automatically retain coverage.