The American Rescue Plan Act (ARPA) was signed into law on March 11, 2021 as a signature effort to assist in the recovery from the COVID-19 pandemic and the related economic downturn. Included as part of the sweeping legislation is a program to fully subsidize COBRA coverage for six months starting in April of 2021. This expert perspective provides a short overview of COBRA and mini-COBRA, the major elements of the ARPA COBRA Assistance program, and considerations for state policymakers related to the program.
Analysis of Federal Statutory and Regulatory Eligibility and Enrollment
Manatt Health Solutions
The following chart, prepared by Manatt Health Solutions, with support from the State Network, summarizes the federal statutory and regulatory eligibility and enrollment requirements for Medicaid using the Modified Adjusted Gross Income (MAGI) methodology, CHIP, Non-MAGI Medicaid, Temporary Assistance for Needy Families (TANF), Child Care Assistance Program and Supplemental Nutrition Assistance Program (SNAP). This analysis highlights points of alignment and meaningful differences across all six programs. A summary document that reflects further detailed analysis can be found here.
Many states are considering the legal, technical, and operational implications of integrating their eligibility determinations for Medicaid and CHIP under MAGI with eligibility determinations for other means tested programs such as TANF, child care, SNAP and Non-MAGI Medicaid. Despite the many shared eligibility requirements across the six programs there are a number of requirements that are distinct to one or several of the programs that create a barrier to full alignment. Ultimately, development of a multi-benefit application offers states the opportunity to evaluate, streamline and simplify eligibility and enrollment rules for its public benefit programs.