Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-2334-P
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, SW.
Washington, DC 20201
Re: Comment on Proposed Rules on Medicaid, Children’s Health Insurance Programs, and Exchanges [RIN 0938-AR04]
Dear Sir or Madam:
Young Invincibles is a non-profit, non-partisan organization that works to amplify the voices of young Americans and expand economic opportunity for our generation. As one of the leading organizations focusing on young adults and health care, we thank you for this opportunity to comment on the proposed rules on Medicaid, Children’s Health Insurance Programs, and Exchanges: Essential Health Benefits in Alternative Benefit Plans, Eligibility Notices, Fair Hearing and Appeal Processes for Medicaid and Exchange Eligibility Appeals and Other Provisions Related to Eligibility and Enrollment for Exchanges, Medicaid and CHIP, and Medicaid Premiums and Cost Sharing.
Our comments focus on CMS’ interpretation of Medicaid eligibility for former foster children under ACA Sections 2004 and 10201. We applaud the provisions of the proposed rule that help ensure that all former foster youth will have access to full coverage under Medicaid. However, we are concerned about the interpretation in the proposed rule that a youth is only eligible for Medicaid coverage in the same state in which he or she was in foster care at age 18 and enrolled in Medicaid.
Young Invincibles is pleased that CMS has clarified the statutory language with respect to eligibility for Medicaid for former foster care youth. Beginning in 2014, states must provide Medicaid coverage for individuals under age 26 who were in foster care at age 18 and receiving Medicaid. The proposed rule further clarifies that a former foster youth may apply for and be determined eligible at any point in time between attaining age 18 and 26. On turning 26, and losing coverage under this eligibility category, Medicaid coverage will only be terminated if the youth is not eligible under any other adult Medicaid eligibility group. Additionally, no income or resource tests are applied in determining Medicaid eligibility for this population. Importantly, the proposed rule amends §440.315(h) to codify that the new eligibility category of former foster youth will be eligible for full Medicaid benefits and not the Alternative Benefit Plan. Young Invincibles strongly supports these provisions.
Click here to read the full comment.
Comment on Proposed Rules on Medicaid, Children’s Health Insurance Programs, and Exchanges [RIN 0938-AR04]
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-2334-P
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, SW.
Washington, DC 20201
Re: Comment on Proposed Rules on Medicaid, Children’s Health Insurance Programs, and Exchanges [RIN 0938-AR04]
Dear Sir or Madam:
Young Invincibles is a non-profit, non-partisan organization that works to amplify the voices of young Americans and expand economic opportunity for our generation. As one of the leading organizations focusing on young adults and health care, we thank you for this opportunity to comment on the proposed rules on Medicaid, Children’s Health Insurance Programs, and Exchanges: Essential Health Benefits in Alternative Benefit Plans, Eligibility Notices, Fair Hearing and Appeal Processes for Medicaid and Exchange Eligibility Appeals and Other Provisions Related to Eligibility and Enrollment for Exchanges, Medicaid and CHIP, and Medicaid Premiums and Cost Sharing.
Our comments focus on CMS’ interpretation of Medicaid eligibility for former foster children under ACA Sections 2004 and 10201. We applaud the provisions of the proposed rule that help ensure that all former foster youth will have access to full coverage under Medicaid. However, we are concerned about the interpretation in the proposed rule that a youth is only eligible for Medicaid coverage in the same state in which he or she was in foster care at age 18 and enrolled in Medicaid.
Young Invincibles is pleased that CMS has clarified the statutory language with respect to eligibility for Medicaid for former foster care youth. Beginning in 2014, states must provide Medicaid coverage for individuals under age 26 who were in foster care at age 18 and receiving Medicaid. The proposed rule further clarifies that a former foster youth may apply for and be determined eligible at any point in time between attaining age 18 and 26. On turning 26, and losing coverage under this eligibility category, Medicaid coverage will only be terminated if the youth is not eligible under any other adult Medicaid eligibility group. Additionally, no income or resource tests are applied in determining Medicaid eligibility for this population. Importantly, the proposed rule amends §440.315(h) to codify that the new eligibility category of former foster youth will be eligible for full Medicaid benefits and not the Alternative Benefit Plan. Young Invincibles strongly supports these provisions.
Click here to read the full comment.