Protected Medicaid for Special Populations

Special Groups of Former SSI Recipients

According to SSA, categorical Medicaid eligibility for the “aged, blind and disabled” is directly related to receipt of SSI in most states. Loss of SSI payments can result in loss of Medicaid coverage. 

To preserve Medicaid coverage for certain groups of individuals who lose SSI payments, Congress enacted special Medicaid continuation provisions. These provisions require the State Medicaid agencies to continue to consider specified groups of former SSI beneficiaries as SSI beneficiaries for Medicaid purposes, as long as they would otherwise be eligible for SSI payments. In addition, Medicaid agencies are required to determine if the individual would be eligible for Medicaid under any other group.

Section 1619 Eligibles 

Individuals who are utilizing the section 1619(b) work incentive provision do not receive SSI payments. In order to continue Medicaid eligibility, section 1619(b) participants are deemed by law to be receiving an SSI payment for Medicaid purposes. 
Reminder:  SSA promotes use of the SSI work incentives. If an SSA Field Office (FO) discovers that a section 1619 participant does not have Medicaid coverage, and there is no Medicaid bar on the SSR, the FO should either contact the Medicaid agency by telephone or prepare a note for the beneficiary to take to the Medicaid agency.   

EXAMPLE
If Daisy gets a major promotion increasing her salary dramatically or Mike gets even the slightest raise, they will lose their SSI cash benefits. However, they will retain their Medicaid.

Title II COLA (“Pickle Amendment”)

Medicaid eligibility is protected for SSI recipients who lost SSI eligibility because of SSDI (Title II) cost-of-living adjustments (COLAs). 

Under section 503 of Public Law 94-566, the “Pickle Amendment,” Title II beneficiaries who would continue to receive SSI payments (or would continue to be eligible for SSI under section 1619b) but for their Title II COLAs, continue to be considered SSI recipients for Medicaid purposes. If an individual’s other income would not have precluded continuing SSI eligibility without the Title II COLAs, the State must continue to consider the individual to be an SSI recipient for Medicaid purposes. 

SSA informs all States annually about potential members of this group at COLA time — each State gets two separate files to help them locate potential eligibles. SSI recipients who go into payment status EØ1 because of COLA’s are also potential members of this group.   

EXAMPLE
If the COLA increases SSDI by one more dollar and brings Mike’s SSDI to above the maximum, he would lose his SSI payment and, therefore, also would lose Medicaid paying his Medicare Premiums.

Disabled Adult Children (Childhood Disability Beneficiaries)
This provision requires States to consider Title II childhood disability beneficiaries (also known as disabled adult children, DACs) who lose SSI eligibility as if they were still SSI recipients for Medicaid purposes so long as they would have remained otherwise eligible for SSI benefits but for their entitlement to (or increase in) Title II benefits on or after July 1, 1987.

Disabled Adult Children (Childhood Disability Beneficiaries)
States must consider title II childhood disability beneficiaries (also known as disabled adult children, DACs, or childhood disability beneficiaries, CDBs) who lose SSI eligibility as if they were still SSI recipients for Medicaid purposes so long as they would have remained otherwise eligible for SSI benefits but for their entitlement to (or increase in) title II benefits . 

SSA notifies states about members of this group in their automated Notices of Planned Action when: 

  • they lose SSI eligibility due to excess income in a month of title II entitlement; and 
  • they are at least age 18; and 
  • the SSI computer record reflects title II continuing income with a Beneficiary Identification Code (BIC) of “C”.