Eligibility Online Manual

M1406 National Public Health Emergency Related To The COVID-19 Virus (This Policy Sunset April 1, 2023 due to the Unwinding of the Continuous Enrollment of Medicaid and CHIP)


Purpose:  This section will assist in determining eligibility and processing ongoing cases during the National Public Health Emergency.


Current Policy Effective Date:  January 1, 2023

Date Last Reviewed:  October 7, 2023

Previous Policy: July 1, 2022

POL M1406:  CASE PROCESSING PROCEDURES DURING THE NATIONAL PUBLIC HEALTH EMERGENCY 

1.    Benefits May Not Be Closed Or Reduced During The National Public Health Emergency (PHE) Beginning March 18, 2020 (See Number 9 Below For Additional Clarification Published November 6, 2020.) 

All clients who had benefits March 1, 2020 that were sent closure notices must be reopened and sent a notice informing them their enrollment would be re-evaluated once the PHE ends.

Benefits may not be closed or reduced, during the PHE, when a client fails to review, has excess resources, transfers a resource at less than fair market value or is no longer eligible under a coverage group, with the following exceptions:

Benefits may be closed under the following circumstances, when the client:

2    EID Clients Must not be Charged a Premium 

Applicants on the Employed Individuals with Disabilities (EID) Program must not be charged a premium starting April 1, 2020 until the end of the PHE.  

3.    Child Support and Birth Cost Sanctions are Being Held and Tracked 

All clients that are sanctioned from child support beginning March 2020 through the month of the National Public Health Emergency are being held and tracked for further review and processing when the National Public Health Emergency Expires.

4.    Aging Out 

Starting March 1, 2020 - Clients on Medicaid turning 19 who would otherwise lose coverage must be continued through the end of the PHE.  Clients on Kid Care CHIP prior to October 2020 who are turning 19 should be denied if not eligible for another program.

Starting October 1, 2020 - Kid Care CHIP converted to an M-CHIP and the Kid Care CHIP clients who turned 19 after the transition must be continued through the end of the PHE.

5.    COVID-19 Related Unemployment Income Must Be Exempted 

Federal Pandemic Unemployment Compensation is exempt when determining income for Medicaid and Kid Care CHIP.

Regular Unemployment Insurance payment is still countable and should be entered into WES.

The first round of Federal Pandemic Unemployment can be up to $600 weekly.

The second round of Federal Pandemic Unemployment can be up to $300 weekly.

The third round of Federal Pandemic Unemployment can be up to $300 weekly.

6.    Stimulus Payments Must Be Exempted 

Exempt as income in the month received.

Exempt this resource for up to one year.

The first round of stimulus payments are $1,200 per person, $2,400 per married couple filing a joint return and $500 per qualifying child under age 17.

The second round of stimulus payments are $600 per person, $1,200 per married couple filing a joint return and $600 per qualifying child under age 17.

The third round of stimulus payments are $1,400 per person, $2,800 per married couple filing a joint return and $1,400 for each dependent listed on a person's 2019 or 2020 tax return.  Previously, only children under the age of 17 qualified.

7.    Child Tax Credit

Beginning in July 2021, half of the yearly child tax credit will be paid in monthly installments from July 2021-December 2021.

Eligible families will receive $300 per month for each child under age 6 and $250 per month for each child age 6 through the age of 17.

These payments are considered exempt when determining Medicaid eligibility.

8.    Notices May Be Sent 

As a courtesy, clients who are no longer eligible for benefits but are being continued due to the PHE may be sent a notice informing them that their benefits are being continued due to the PHE.

Clients must be sent a notice when switching to another Minimum Essential Program (MEC) if it has a lower level of benefits. 

9.    Clarifications Under the Final FMAP Rule Published November 6, 2020 

Clients who are no longer eligible under their current program may be moved to another MEC Program.  Medicare Savings Programs are considered a MEC program.

Clients can now be closed for substantiated fraud or for agency error with timely notice.

Transfer penalties that occurred during the national emergency should be enforced beginning 11/2/2020 based on the CMS guidance provided in the Final FMAP rule.

In December of 2022, CMS reversed guidance related to moving clients from full Medicaid programs to MSP groups.  The agency re-evaluated all clients in this circumstance and reinstated the original Medicaid program for those who did not request closure or move out of state under Carr v. Bacerra.

10.    Public Assistance Reporting Information System (PARIS) Match Closures 

Beginning December 2020, the PARIS auto-closure batch was turned off due to further clarification of the Final FMAP Rule Published November 6, 2020.  

If third party verification can be obtained to substantiate a client's residency in another state, these clients will be closed manually.

Reference:

Defining Requirement:    Families First Coronavirus Response Act (FFCRA)

                                        Coronavirus Aid, Relief, and Economic Security Act (CARES Act)

                                        42 CFR Parts 410, 411, 414, 417, 433 and 510

                                        The Economic Relief Package Related to COVID-19 (December 2020)

Clarifying Information:

Worker Responsibilities:

Documenting Exempt Income

1. Make a case note when excluding exempt unemployment income.

2.  If an applicant or client self-reports that they received stimulus money or they submit verification of this payment, do not enter this amount into WES.  If a hard copy verification is received, document with a case note.