The Affordable Care Act (ACA) and the HUSKY Redetermination Process Department of Social Services September 12, 2014

The ACA and the HUSKY Redetermination Process ACA Eligibility Changes Classic Medicaid to MAGI Medicaid Redeterminations MAGI-to-MAGI Redeterminations

MAGI (Modified Adjusted Gross Income) New methodology mandated by the ACA Changes the way we determine eligibility for HUSKY A HUSKY B HUSKY D Changes the way we count income, and whose income is counted Based on federal income tax rules Used by Access Health CT to determine tax subsidies and cost-sharing amounts Not used for HUSKY C or the Medicare Savings Programs

Income Included as Income for Classic Medicaid Included as Income for MAGI Medicaid Type of Income Wages, Salaries, Tips Child Support Received Veterans Benefits Workers Compensation Social Security Benefits (retirement, survivor, disability) Supplemental Security Income (SSI) Taxable amount of Pension, Annuity, Dividends or IRA distributions Unemployment Compensation Business Income Rental Real Estate, Partnerships, Royalties, S Corps, trusts, etc. Taxable Interest Alimony Received Scholarships, Grants, Awards used for Educational purposes Gifts and Inheritances Lump Sums Yes (Gross Wages) Yes No Income in month recv’d Yes (Federal Taxable Gross) No Yes Income in month recv’d

Income Deductions Income Disregard (5% of FPL) Child Care Expenses Deduction for Classic Medicaid Deduction for MAGI Medicaid Type of Deduction Income Disregard (5% of FPL) Child Care Expenses Work Expense Disregard Child Support Received Disregard Certain Self-employment expenses Student loan interest Tuition and fees Educator Expenses IRA deduction Moving expenses Penalty on early withdrawal of savings Health Savings Account deduction Alimony Paid Step-Parent’s income No Yes Yes No No (not countable income) Yes (includes depreciation)

Household Composition Determine the household for each person requesting assistance: A. Does the individual expect to file taxes? i. If no – continue to step B ii. If yes – does the individual expect to be claimed as a tax dependent by anyone else? 1. If no - the household consists of the taxpayer, a spouse living with the taxpayer, and all persons whom the taxpayer expects to claim as a tax dependent 2. If yes – continue to step B

Household Composition (continued) B. Does the individual expect to be claimed as a tax dependent? i. If no – continue to step C ii. If yes – does the individual meet any of the following exceptions? The individual expects to be claimed as a tax dependent of someone other than a spouse or a biological, adopted, or step parent The individual is a child living with both parents, but the parents do not expect to file a joint tax return. The individual is a child who expects to be claimed by a non-custodial parent 1. If no – the household is the household of the taxpayer claiming her/him as a tax dependent Is the individual married? If yes - the household also includes the individual’s spouse 2. If yes – continue to step C

Household Composition (continued) C. For individuals who neither expect to file a tax return nor expect to be claimed as a tax dependent, as well as tax dependents who meet one of the exceptions in B.ii., the household consists of the individual and, if living with the individual— The individual's spouse; The individual's natural, adopted and step children under the age 19; and In the case of individuals under age 19, the individual's natural, adopted and step parents and natural, adoptive and step siblings under age 19.

Income Limits The Center for Medicare and Medicaid Services (CMS) converted classic income limits to MAGI-based income limits Reflects the changes to countable income, deductions and household composition The conversion is intended to be population-neutral

MAGI Income Limits

Classic Medicaid vs. MAGI Example: Marie, 20-years old, requests Medicaid Marie lives with her mother Her mother claims her as a tax dependent Her mother earns $4,500 per month Marie has no income

Classic Medicaid Marie’s category of coverage is HUSKY D (Medicaid for Low Income Adults) The household consists solely of Marie Marie qualifies for HUSKY D as her income ($0) is less than the HUSKY D income limit (54% FPL)

MAGI Medicaid Marie’s category of coverage is HUSKY D (ACA Adult Group) The household consists of Marie and her mother Marie is not eligible for Medicaid as the household income ($4,500 per month) is more than the HUSKY D income limit ($1,809.18, which is 138% FPL for 2 people)

Classic Medicaid vs. MAGI Example: Medicaid is requested for the James, age 7 James lives with his mother and stepfather James’ mother earns $2,000.00 per month James’ stepfather earns $2,500 per month

Classic Medicaid James’ category of coverage is HUSKY A Household consists of James and his mother James qualifies for HUSKY A as his mother’s income is less than the HUSKY A income limit (185% FPL for 2)

MAGI Medicaid James’ category of coverage is HUSKY A The household consists of James, his mother and his stepfather James is not eligible for HUSKY A as the monthly household income ($4500.00) is over the HUSKY A income limit ($3,316.50, which is 201% FPL for a family of 3) James qualifies for HUSKY B, Band 2

Classic Medicaid to MAGI Medicaid Redetermination Process Redeterminations delayed by three months beginning in January 2014 Rolling delay - January delayed to April, February to May, March to June etc. Redeterminations resumed for those due in April and May 2014 During this time, CMS approved our request for an additional delay. Redeterminations delayed by three months beginning in June 2014 Rolling delay – June to September, July to October etc. Redeterminations resumed for those due in September HUSKY C and MSP redeterminations have not been delayed

Classic Medicaid to MAGI Medicaid Redetermination Process (continued) Our shared system with Access Health CT (AHCT) supports the new MAGI Medicaid rules Clients will receive a new form to complete a renewal for MAGI Medicaid (AH3) along with a return envelope The quickest way to complete the redetermination process and receive an eligibility determination, is to go to Access Health CT (www.accesshealthct.Com) Individuals can complete their redetermination by phone by calling Access Health CT at 1-855-805-4325

Classic Medicaid to MAGI Medicaid Redetermination Process (continued) On-line and Phone redeterminations are the most expedient and result in an immediate eligibility decision. Some post-eligibility verifications may be needed if information is not matched against the federal data services hub or other sources 90 days of coverage is provided while verification documentation is requested and reviewed Paper applications are mailed to AHCT via Scan Optics where they are later accessed by Xerox State Health Care workers who data enter the information from the paper into the AHCT/DSS share eligibility system

Classic Medicaid to MAGI Medicaid Redetermination Process (continued) Clients may mail paper forms to AHCT via Scan Optics Xerox data enters the information into the AHCT/DSS eligibility system Xerox enters the final eligibility decision into EMS (HUSKY A and HUSKY D) and into ConneXion (HUSKY B) Currently, there is no electronic interface between the AHCT and EMS or ConneXion. This manual data entry may have to continue until 2016 when the new EMS system (ImpaCT) is completed. Once the determination is made, READ ABOVE…

Classic Medicaid to MAGI Medicaid Redetermination Process (continued) MAGI rules do not apply to HUSKY C or the Medicare Savings Program (MSP) HUSKY C and MSP continue to follow the traditional redetermination process Non-MAGI redeterminations are processed through our ConneCT system

MAGI-to-MAGI Redeterminations MAGI-to-MAGI redeterminations will be processed in the AHCT/DSS shared system administrative renewal procedures used to lessen burden on families System will check electronic data sources before taking action Clients remain enrolled for another 12 months so long as data matches Clients may need to provide additional information if there are changes (e.g. income) There is a new 90 day “reconsideration period” provision for applicants who renew after closure. No new application is required.

Reconsideration Period The Reconsideration Period is a 90 day grace period to complete redeterminations after the case has been closed The Reconsideration Period begins when Medicaid stops due to an incomplete redetermination Client will automatically receive retroactive coverage back to the date of discontinuance once the redetermination is completed (if eligible) This provides better continuity of coverage

Reconsideration Period The Reconsideration Period is a 90 day grace period to complete redeterminations after the case has been closed The Reconsideration Period begins when Medicaid stops due to an incomplete redetermination Client will automatically receive retroactive coverage back to the date of discontinuance once the redetermination is completed (if eligible) This provides better continuity of coverage