In response to President Trump’s October 12 executive order (EO), the U.S. Departments of Health and Human Services (HHS), Labor (DOL) and Treasury have published proposed rules to expand the availability of health coverage sold through short-term, limited duration insurance (STDLI). The public has until April 23, 2018 to submit comments on these proposed rules; the new standards are slated to be effective 60 days after publication of the final rules.
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.