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Will your Clients Receive Extra Help In 2009?
It is now time for redetermining eligibility for Extra Help in 2009. Every summer many Extra Help recipients are re-evaluated for future Extra Help eligibility. The many clients who you assisted to get Extra Help may now contact you with their questions and requests for assistance with the Extra Help re-evaluation processes. When you are familiar with these procedures, you can help make sure your clients continue to get Extra Help in 2009.
Re-Deeming for Extra Help — CMS
Who Gets Re-Deemed and How?
State Medicaid agencies began sending lists beginning in July and monthly through December to CMS containing data about everybody with Medicare who was covered by any type of Medicaid coverage in that month. These lists form the basis of redeeming people with Medicare and Medicaid for Extra Help in 2009.
Everybody who was on the July list is redeemed by CMS and will get Extra Help in 2009. Remember that anyone with Medicare who has any type of Medicaid is deemed eligible for Extra Help; this includes people getting waiver home care or nursing home care whose income may exceed the Extra Help eligibility limits. If they are on Medicaid in July 2008, they are deemed eligible for Extra Help for all of 2009 with no further actions or inquiries needed. It’s important to understand that those whose Extra Help will remain the same in 2009 will not receive any notification from CMS.
What about people who go on Medicaid between August and December 2008? State Medicaid agencies transmit lists to CMS each month to update the July lists.
People Who Get Un-Deemed and How You Can Help Them
People who got Extra Help because they received Medicaid but who no longer have Medicaid are not on a State Medicaid agency MMA list that CMS receives from the state Medicaid agencies. That means they are not deemed eligible for Extra Help for 2009. These individuals will lose their Extra Help at the end of December 2008 unless they take some action before then. They get a letter from CMS (138Kb Word file) in September 2008 explaining that they will lose their deemed eligibility for Extra Help as of the end of 2008. The letter is printed on grey paper.
If the data transmitted by the State Medicaid agency reveals that the Extra Help Level will change, CMS generates a letter (55Kb PDF file) in October 2008 printed on orange paper explaining the Extra Help change for 2008.
What can People Losing Their Extra Help Deemed Status Do?
- They might be eligible for a Medicare Savings Program. You can help them find out. See more on Medicare Savings Programs (98Kb PDF file).
- Regardless of whether they are eligible for a Medicare Savings Program, you can help them figure out if they can get back onto Medicaid by spending down income. In this way, they can be redeemed for Extra Help.
- They should complete and submit the Extra Help application. The ABCs of LIS (pdf file) guides you through the questions on the Extra Help Application. Remember you can help your clients apply for Extra Help on BenefitsCheckUp and simultaneously screen them for other benefits for which they may be eligible.
People Who Get Medicaid by Spending Down Surplus Income and Continued Extra Help
Some people get Medicaid by spending, or incurring, their income that is in excess of the applicable Medicaid eligibility level on medical expenses. This kind of Medicaid is generally called surplus income, spend down, or medically needy Medicaid. Please note that your state might have a different name of this kind of Medicaid. People who qualify for Medicaid by spending down their surplus income are deemed eligible for Extra Help for the remainder of the calendar year. Moreover, people with Medicare who spend down their surplus income and qualify for Medicaid in any month between July and December 2008 will also get Extra Help for the full calendar year of 2009.
An example may help to illustrate these concepts:
Spending Down in June 2008: Mrs. B.
Mrs. B. qualifies for Medicaid by spending down her excess income to her state’s Medicaid level in June 2008. In addition to getting Medicaid, she will be deemed eligible for and receive Extra Help only until the end of December 2008.
If she wants Extra Help for 2009, she will have to use the strategies suggested above for people being unredeemed for Extra Help.
She could
- Submit an application for Extra Help. She can use BenefitsCheckUp.org
- Investigate with her State Medicaid agency whether she is eligible for one of the Medicare Savings Programs; because she would be redeemed if she is found eligible for a Medicare Savings Program.
- If she is not eligible for a Medicare Savings Program, she would only get Extra Help in 2009 if she applies, or if she can again spend down her surplus income to get back onto Medicaid at some point during 2009.
Spending Down in July 2008; Mr. C: Mr. C. is Ms. B’s next door neighbor. Because he went to see a benefits counselor, he waits and qualifies for Medicaid by spending his excess income down in July 2008. He is deemed eligible for Extra Help for the rest of 2008 and also through calendar year 2009, even if he is unable to qualify for Medicaid at any time during the rest of 2008 nor during 2009.
How Can You Help Your Extra Help Clients with Redeeming and Redeterminations?
It is anticipated that CMS will release data by state, county and zip code on the numbers of people who were deemed for Extra Help in 2008 but will not be deemed eligible in 2009. This data can help you to target your outreach, education and enrollment counseling. We will post it here.
- You could use the CMS data to determine where in your community to target your education and outreach efforts. Knowing your numbers of unredeemed people down to the zip code level should help you guess where they congregate and who are their trusted intermediaries.
- You could contact your clients who were deemed eligible for Extra Help in 2008 to help them either to verify that they were re-deemed for 2009 or pursue their options to get Extra Help in 2009.
- You can help all of them make educated decisions about which plan to select for 2009, based upon cost, coverage, convenience and customer service
2009 Extra Help Redeterminations
Redetermining Eligibility for Extra Help – Social Security Administration
There are three different types of Social Security redeterminations of eligibility for Extra Help.
- Starting in 2007, Social Security decided not to screen all new Extra Help people. Rather, Social Security selected from this group those individuals whom Social Security has reason to believe may have experienced a change in circumstances that could affect Extra Help eligibility. In 2008, the Social Security Extra Help first time redetermination process is applicable to people who applied through Social Security and were found eligible for Extra Help between May 2007 and April 2008. Social Security calls these initial redeterminations. Included in the selected category are:
- People receiving in-kind support and maintenance;
- People who reported changes in income and resources between January and August 2008; and
- People whose Social Security records indicate a change that could affect Extra Help status.
The Social Security Administration processes initial redeterminations of Extra Help eligibility starting in August 2008. Those beneficiaries who have been selected for review will receive a redetermination form (987Kb PDF file) along with an envelope addressed to Social Security. They must complete and return the form within 30 days, even if they report that in fact nothing has changed. They can get one 30 day extension by asking SSA.
The form is scannable so all of the rules that pertain to Extra Help applications are also applicable to the redetermination forms - use black or blue ink or a Number 2 pencil, do not fold the form multiple times, etc.
Everyone who gets the Social Security redetermination form will receive a Social Security notice when the redetermination is completed. The notice will inform them of their Extra Help status for 2009:
- No change from 2008
- An increase or decrease in the level of their Extra Help
- Termination of their Extra Help
Everyone who was found eligible for Extra Help by Social Security between May 2007 and April 2008 who was not selected for initial redetermination will continue to be eligible for Extra Help in 2009.
2. Cyclical Redeterminations
Social Security has established a cyclical redetermination process to comply with the statutory requirement in the Medicare Modernization Act requiring annual determination of Extra Help eligibility. Each year, Social Security selects a portion of the Extra Help population and send them the same scannable redetermination form sent to those undergoing their initial redetermination. As with initial redeterminations, any changes to Extra Help status will become effective the following January 1, 2009.
Example:
Mrs. C. has been on Extra Help since 2006. She is surprised to receive a letter from Social Security in early September 2008. Nothing has changed in her circumstances so she is anxious about losing the Extra Help that allows her to afford the medicines she takes to control her severe arthritis, her chronic obstructive pulmonary disease and her diabetes.
You can reassure her that the redetermination is a routine annual process and you can help her check the box on the form to indicate “no change” and make sure she mails the form in the envelope provided. You can also remind her that you can help her assess her Part D plan selection for 2009 and that she can contact you if she encounters any problems next January.
3. Subsidy Changing Event Redeterminations
Subsidy changing events must be promptly reported to Social Security. A subsidy changing event is a change in marital status, including:
- Marriage
- Divorce
- Separation
- Annulment
- Death of spouse
Extra Help beneficiaries can call the Social Security Hotline 1-800-772-1213 to report such changes. Social Security responds to such reports by sending a special subsidy changing event redetermination form. Extra Help beneficiaries are required to complete and submit the form within 90 days of receipt. If they do not respond, they will be discontinued from Extra Help. If they do respond, the change to their Extra Help status becomes effective the next month after Social Security receives the completed form.
Example:
Mr. D’s wife of 52 years died last month. He is distraught and his daughter, herself a senior receiving Extra Help, has called you to find out if anything needs to be done to continue her father’s retirement benefit, Medicare and Qualified Medicare Beneficiary (QMB) benefits, since her mom and dad had “received everything as a couple,” as she tells you. You can help the daughter make the report of Mr. D’s change in marital status to Social Security and the Medicaid office. You can help her to monitor implementation of the changes to assure that Mr. D. continues to get his Social Security check, and is not charged excessive amounts for his prescriptions and other Medicare-covered services.
See the official Social Security policies on Extra Help redeterminations (180Kb Word file). The Social Security Administration has a flyer describing the redetermination process (240Kb PDF file).
Important Info to Help Your Clients Losing Extra Help
CMS has given Part D plans some very important information that will help you to counsel your clients who are losing Extra Help at the end of the year. We thought you'd like to know this information. First, as you probably already know, your clients who are losing Extra Help have a three month Special Enrollment Period, from January 1, 2009 through March 31, 2009 to switch to another Part D plan. You can assist your clients who lost Extra Help to determine if another plan might better meet their needs in terms of cost, coverage, customer service and convenience.
Part D plans are also permitted, although not required to offer beneficiaries who lost Extra Help a three month grace period to pay the plan premium and regular cost-sharing after they lose the premium and cost-sharing subsidies they had with Extra Help.
What does all this mean? Your clients who lose Extra Help at the end of 2008 would have until the end of March 2009 to switch to a different plan. Moreover, if their 2008 plan decides not to participate in Part D in 2009, or decides to offer the premium and cost-sharing subsidy to former Extra Help beneficiaries, your clients have until March 31, 2009 to arrange payment of the new premium and cost-sharing for which they will be responsible without Extra Help in 2009. Here is the October 22, 2007 CMS Memorandum to Part D plans about the Special Enrollment Period and grace period option.
What is the big caveat to all this?
Of course you'll want to make sure that your clients really are not Extra-Help-eligible in 2009. Discuss how you'll look at your clients' income and assets, explore if they might be entitled to any form of Medicaid, or if they should apply for Extra Help – just to be sure before you move onto helping them in the ways described above. Share your thoughts with your colleagues on our Forums page.
