Federal Rule on Medicare Savings Programs Will Cut Red Tape for Older Adults and People With Disabilities
End Notes
[1] Department of Health and Human Services (HHS), “Streamlining Medicaid; Medicare Savings Program Eligibility Determination and Enrollment,” 88 Fed. Reg. 65230, September 21, 2023, https://www.govinfo.gov/content/pkg/FR-2023-09-21/pdf/2023-20382.pdf.
[2] National Council on Aging (NCOA), “Medicare Savings Program Enrollment,” August 22, 2023, https://www.ncoa.org/article/medicaid-msp-enrollment.
[3] Centers for Medicare & Medicaid Services (CMS), “2024 Medicare Parts A & B Premiums and Deductibles,” October 12, 2023, https://www.cms.gov/newsroom/fact-sheets/2024-medicare-parts-b-premiums-and-deductibles.
[4] Some individuals who are eligible for both Medicaid and Medicare receive full Medicaid benefits along with Medicare and may also receive assistance through MSPs. Partial dual eligibles are enrolled in Medicare and receive assistance from MSPs to help afford that coverage. Medicaid and CHIP Payment and Access Commission (MACPAC), Medicare Savings Programs, https://www.macpac.gov/subtopic/medicare-savings-programs/.
[5] Medicare Part A generally covers inpatient care in hospital, skilled nursing facility care (not custodial or long-term care), hospice care, and home health care. Most Medicare enrollees do not pay a Part A premium but do pay significant deductibles and coinsurance for inpatient care. Medicare Part B helps cover outpatient care such as doctor’s visits and preventive care. Part B premiums vary based on income.
[6] CMS, “2024 Medicare Parts A & B Premiums and Deductibles.”
[7] Resource limits include money in the bank stocks, bonds, more than one car in the individual’s name, and burial expenses exceeding $1,500. CMS, “Medicare Savings Programs,” https://www.medicare.gov/medicare-savings-programs.
[8] MACPAC, “Medicare Savings Programs: New Estimates Continue to Show Many Eligible Individuals Not Enrolled,” August 2017, https://www.macpac.gov/wp-content/uploads/2017/08/Medicare-Savings-Programs-New-Estimates-Continue-to-Show-Many-Eligible-Individuals-Not-Enrolled.pdf.
[9] Suzanne Wikle et al., “States Can Reduce Medicaid’s Administrative Burdens to Advance Health and Racial Equity,” CBPP, July 19, 2022, https://www.cbpp.org/research/health/states-can-reduce-medicaids-administrative-burdens-to-advance-health-and-racial.
[10] MIPPA Resource Center for Professionals, “Part D Low Income Subsidy/Extra Help Eligibility and Coverage Chart,” January 25, 2024, National Council on Aging (NCOA), https://www.ncoa.org/article/part-d-low-income-subsidy-extra-help-eligibility-and-coverage-chart.
[11] NCOA, “Simultaneous LIS and MSP Application Submission,” January 7, 2020, https://www.ncoa.org/article/simultaneous-lis-msp-application.
[12] KFF, “Number of Low-Income Subsidy (LIS) Enrollees,” https://www.kff.org/medicare/state-indicator/number-of-low-income-subsidy-lis-enrollees/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%7D; HHS.
[13] The estimated cost and time savings of the final rule are part of the agency’s regulatory impact analysis, which is a required component of the rulemaking process so policymakers can assess the rule’s relative burden and benefits. CMS, “Streamlining Medicaid and CHIP, Final Rule, Fact Sheet,” September 18, 2023, https://www.cms.gov/newsroom/fact-sheets/streamlining-medicaid-and-chip-final-rule-fact-sheet#_ftn1.
[14] All states must pay the Part A premium for QMB enrollees who do not receive premium-free Part A; “buy-in” states include the Part A premium cost for QMBs in their existing buy-in agreement, which helps facilitate automatic enrollment in QMB any time of the year. When states use the group payer arrangement to pay Part A premiums, certain enrollment restrictions apply, such as only being able to apply for Medicare Part A during the Medicare General Enrollment Period (January 1-March 31 of each year) if they did not enroll during their Initial Enrollment Period (three months before turning 65 and three months after the month the individual turns 65, lasting seven months total). CMS, “Program Overview and Policy: Chapter 1,” https://www.cms.gov/files/document/chapter-1-program-overview-and-policy.pdf.
[15] Justice in Aging, “Medicare Part D Low Income Subsidy (LIS or ‘Extra Help’),” https://www.justiceinaging.org/wp-content/uploads/2018/11/Part-D-LIS-factsheet-revised-9.27-footnoted.pdf.
[16] D’Vera Cohn et al., “Financial Issues Top the List of Reasons U.S. Adults Live in Multigenerational Homes,” Pew Research Center, March 24, 2022, https://www.pewresearch.org/social-trends/2022/03/24/the-demographics-of-multigenerational-households/#:~:text=About%20a%20quarter%20of%20Asian,of%20those%20who%20are%20White.
[17] Whole life insurance face value is the amount paid by the insurance company if a death occurs. Whole life insurance surrender value is the amount paid if the individual cashes out their insurance policy before their death. Rachel Gershon, “Final Rule to Streamline Enrollment in Medicare Savings Programs,” Justice in Aging, November 2023, https://justiceinaging.org/wp-content/uploads/2023/11/Final-Rule-to-Streamline-Enrollment-in-Medicare-Savings-Programs.pdf.
[18] When verifying income, state Medicaid agencies compare the client attestation to available electronic data. The attestation and data source are considered “reasonably compatible” if both are below, at, or above the eligibility threshold, even if the amounts are different. Under reasonable compatibility, states can only require documentation when the difference between the attestation and data source affects eligibility.