It started out as a targeted enrollment strategy – a fast and efficient way to get eligible people enrolled in the ACA’s expanded coverage options by using SNAP enrollment to identify low-income beneficiaries who were income eligible but not enrolled in Medicaid. After all, gross income eligibility for SNAP (aka food stamps) at 130% FPL closely aligns with the Medicaid expansion eligibility level of 138% FPL. Plus SNAP does a thorough job of verifying income eligibility. As a targeted enrollment strategy, it was initially available through December 2015 under 1902(e)(14)(A) waiver authority (just saying that so you don’t think it’s one of those 1115 waivers that we often talk about). The resounding success of the strategy has prompted CMS to offer states the option to implement the policy option through a State Plan Amendment (SPA) for both new applications and renewals.
Some states have used the targeted enrollment strategies to enroll a large number of newly eligible people without having to process a new application – six states that reported data enrolled almost three-quarters of a million people using SNAP. Other states have found the strategy to be useful in addressing a backlog of pending applications or renewals. The strategy can be effective whether or not a state has expanded Medicaid.
The State Health Official letter (SHO) announcing the SPA option details certain criteria that must exist to ensure that individuals enrolled are certain to be financially eligible. Plus, it’s important to note that, unlike Express Lane Eligibility, which allows states to use other means-tested programs to enroll people who are eligible for Medicaid, the SNAP enrollment SPA does NOT allow for automatic enrollment. First, the state must make sure the individual is not already enrolled. It must also put forth a plan for verifying citizenship and qualified immigration status and for how it will obtain minimum requirements for an application such as a signature. There are other administrative requirements, which may take interested states some time to review and digest, although the states that have already been using the strategy will have a leg up.
While CMS had expected that this and other enrollment strategies outlined in its May 17, 2012 initial SHO under temporary waiver authority would no longer be needed by the end of 2015, ongoing systems challenges in some states have prompted CMS to extent the temporary waiver authority with a few changes. Namely, states must commit to determining eligibility using MAGI-based methodology no later than 12 months after use of the strategy at enrollment or renewal. The strategy cannot be used to renew eligibility for someone who was enrolled using the strategy initially.
By the way, the new SPA option isn’t limited to SNAP. The strategy may also be applied to participants of TANF and other public mean-tested benefit programs if the criteria required by the SPA are met.
