State Actions to Sustain Medicaid Long-Term Services and Supports During COVID-19

Issue Brief
  1. Missouri elects the Section 209 (b) option to apply Medicaid financial and/or functional eligibility rules to SSI beneficiaries that differ from federal SSI rules. KFF, Medicaid Financial Eligibility for Seniors and People with Disabilities: Findings from a 50-State Survey (June 2019), https://www.kff.org/report-section/medicaid-financial-eligibility-for-seniors-and-people-with-disabilities-findings-from-a-50-state-survey-issue-brief/. In its COVID-19 Frequently Asked Questions, CMS notes that “[i]n making disability determinations, a state must generally use the same definition of disability as used for supplemental security income (SSI). A positive diagnosis for COVID-19 is not a per se disability under SSI criteria and therefore cannot be the sole basis of a determination of disability for purposes of Medicaid eligibility.” CMS, COVID-19 Frequently Asked Questions (FAQs) for State Medicaid and Children’s Health Insurance Program (CHIP) Agencies at II.C.2 (last updated June 30, 2020), https://www.medicaid.gov/state-resource-center/Downloads/covid-19-faqs.pdf.

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  2. States generally must maintain Medicaid eligibility through the end of the month in which the public health emergency period ends for all individuals enrolled on or after March 18 2020, as a condition of receiving the 6.2 percentage point increase in federal matching funds. KFF, Key Questions About the New Increase in Federal Medical Matching Funds for COVID-19 (May 2020), https://www.kff.org/coronavirus-covid-19/issue-brief/key-questions-about-the-new-increase-in-federal-medicaid-matching-funds-for-covid-19/. CMS has clarified that states are not prohibited from conducting regular eligibility renewals during this period, but as a condition of receiving the enhanced federal matching funds, states cannot terminate coverage for any Medicaid beneficiary enrolled on or after March 18 2020, unless the individual is no longer a state resident or requests voluntary termination. CMS, Families First Coronavirus Response Act – Increased FMAP FAQs, question B.11 (updated as of 4/13/2020), https://www.medicaid.gov/state-resource-center/downloads/covid-19-section-6008-faqs.pdf.

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