THE AFFORDABLE CARE ACT (ACA) has had a significant effect on the way consumers, payers, and providers operate in the health care market. For Medicaid programs in particular, the ACA implemented changes that affected eligibility, funding, and policy related to the Medicaid pro- gram. While 28 states are moving forward with
the implementation of Medicaid eligibility expansion for individuals between the ages of 18 and 64 and below 138 percent of
the federal poverty level (FPL),
1 many other aspects of the 2010
legislation provide additional opportunities for eligibility and
benefit changes that would interest key stakeholders and warrant consideration in actuarial budget forecasts.
One of the additional items relates to Section 1915(i) of the
Social Security Act (SSA), which addresses the inclusion of
home and community-based services (HCBS) in the state plan.
State plan services refer to the scope of benefits that are covered
by the Medicaid program and are agreed upon by the state and
federal government agencies. While Section 1915(i) predated
the enactment of the ACA, the ACA legislation provided some
modifications to Section 1915(i) that increased its visibility in the
HCBS landscape. The modifications have prompted a number
of states to apply for the inclusion of HCBS in their respective
state plans through the 1915(i) provision.
The 1915(i) state plan option is viewed as a flexible solution
to meeting the HCBS needs of individuals who do not qualify
for the more restrictive eligibility criteria under a 1915(c) waiv-
er program. Prior to deciding to implement a 1915(i) state plan
option, there are several important implications that must be
considered. This article discusses several features and consid-
erations of the 1915(i) state plan option. We will also consider
a unique example of a state that overcame Medicaid eligibility
challenges by implementing a program using the 1915(i) state
and the ACA The sweeping health care reform eans some big changes for home and community-
and who’s eligible
to receive them.
By Robert M. Damler and Marlene T. Howard