Arizona and Florida are the latest states to ask the Centers for Medicare and Medicaid Services (CMS) to waive the requirement that states provide three months of retroactive Medicaid coverage to eligible Medicaid recipients.
Medicaid law allows a Medicaid applicant to be eligible for benefits for up to three months before the month of the application if the applicant met eligibility requirements at the earlier time. This helps people who are unexpectedly admitted to a nursing home and can't file a Medicaid application right away.
Now Arizona and Florida have joined a growing list of states that are asking to eliminate the retroactive benefits. Arizona's proposal is to begin Medicaid coverage on the first day of the month in which the Medicaid application is filed for all Medicaid applicants, while Florida proposes eliminating the three-month Medicaid retroactive eligibility period for non-pregnant recipients aged 21 years and older effective July 1, 2018. Over the past year, CMS has approved requests by Iowa, Kentucky, Indiana, and New Hampshire to waive retroactive coverage. A lawsuit is challenging Kentucky's waiver, which also imposes work requirements for Medicaid recipients.
The comment period for Arizona's proposal ended on May 22, 2018, but CMS is accepting comments on Florida's proposal until June 5, 2018. Justice in Aging has sample comments that can be adapted for this comment period.