Medicaid Renewals / Redeterminations for Long Term Care: Frequency, Considerations & Process

Summary
After you or your loved one is enrolled in Medicaid Long Term Care, you must continue to meet the eligibility criteria in order to keep your Medicaid coverage. This is known as Medicaid renewal, but it’s also called Medicaid redetermination or recertification. In most cases, Medicaid renewal happens once a year, but how it happens depends on the individual Medicaid beneficiary, their financial situation, and their state of residence. If you don’t complete the Medicaid renewal process, or you are ruled ineligible during the process, you could have lapses in coverage or even lose your benefits.

 Attention: Renewals were suspended during Covid. However, the suspension has lapsed and as of April 1, 2023 all Medicaid beneficiaries must be renewed to continue to receive coverage.

 

What is Medicaid Long Term Care Renewal?

Medicaid renewal is the process state governments use to make sure Medicaid beneficiaries in their state continue to meet the state’s Medicaid eligibility criteria. Medicaid is for people of limited financial means, and individuals need to meet an asset limit and an income limit in order to be eligible. So, if someone comes into money, property, or some other asset while they are enrolled in Medicaid, they could go over the asset limit and become ineligible. The same is true if they find a new source of income or if an exempt asset become countable while they are enrolled in Medicaid.

The Medicaid renewal process also ensures that individuals continue to receive their benefits from any of the three Medicaid Long Term Care programs – Nursing Home Medicaid, Home and Community Based Services (HCBS) Waivers, and Aged, Blind, and Disabled (ABD) Medicaid. ABD Medicaid can sometimes be referred to as Regular Medicaid for Seniors, but this shouldn’t be confused with the Regular Medicaid that is available to low-income people of all ages.

The federal government (which oversees and funds state Medicaid programs) suspended all Medicaid Renewals during the COVID-19 Public Health Emergency (PHE). But states were allowed to resume Medicaid Renewals on April 1, 2023. Guidance from the Centers for Medicare and Medicaid Services gave states up to 12 months to initiate all Renewals and 14 months to complete them.

The restart of Medicaid renewals is also known as the “unwinding” period or process. This is because the return of renewals “unwinds” the continuous Medicaid enrollment that was available during the PHE.

 

What Factors are Considered During the Renewal Process?

During the Medicaid renewal process, state Medicaid officials will examine the beneficiary’s financial status to see if they still meet the state’s income limit and asset limit, and to determine the value of their home, if applicable. They will also evaluate beneficiaries to ensure they still have a medical need for care. The state will do this electronically if possible. This is known as automatic renewal (or ex parte renewal) and requires little or no action from the beneficiary.

If a Medicaid beneficiary’s financial status cannot be checked automatically, they will get a letter and/or an email with a Medicaid Renewal Form that must be completed, dated, signed and returned within 30 days to ensure continued coverage. The Renewal Form may be “pre-populated” with information the state has been able to gather about the beneficiary’s financial status. In some states, beneficiaries also have the option to complete the Renewal Form over the phone, online, or in person.

The types of financial holdings, documents, and limits the state will be examining during the Medicaid Renewal process can be broken down into the following categories – Income, Assets, Home Ownership:

 

Income

Almost all income is counted toward the Medicaid eligibility income limit – Social Security benefits, IRA payments, pension payments, wages, salary, alimony, property income, stock dividends, etc. COVID-19 stimulus checks and Holocaust restitution payments are not considered income.

The documents and records state officials might examine to determine income for Medicaid Renewal purposes include tax forms, SSI or VA benefit award letters, pension statements and alimony checks. In cases where there is no other written proof of income, a self-declaration letter may be enough.

In most states in 2024, the individual income limit for Nursing Home Medicaid and Home and Community Based Service (HCBS) Waivers is $2,829/month. The individual income limit varies more by state when it comes to Aged, Blind and Disabled (ABD) Medicaid, but in most states it ranges from $943/month to $1,751/month.

 

Assets

Assets that count against Medicaid’s eligibility asset limit include bank accounts, retirement accounts, stocks, bonds, certificates of deposit, cash, second vehicles, second/vacation homes and any other financial holdings or property that can be easily converted to cash. A beneficiary’s primary home does not always count against the asset limit (details discussed below), and neither does their primary vehicle, or essential personal and household items like clothing, furniture and appliances.

For Medicaid Renewal purposes, the documents and records state officials might examine include statements from stocks, bonds, certificates of deposit, and savings, checking, retirement and money market accounts. Copies of life insurance policies may also be requested, since the cash surrender value of life insurance policies also counts as an asset for Medicaid eligibility.

In most states in 2024, the individual asset limit for all three types of Medicaid Long Term Care – Nursing Home Medicaid, Home and Community Based Services (HCBS) Waivers, and Aged, Blind and Disabled Medicaid – is $2,000. But this can vary greatly by state. In Illinois, for example, it’s $17,500. See asset limits by state here.

 

Home Ownership

If a person owns a home, it is usually their most valuable asset, and if it was counted for Medicaid Renewal purposes, that home would likely push them over the asset limit for eligibility. However, in many situations the home is not counted against the asset limit, but that often depends on the value of the home as measured by home equity interest (the portion of the home’s equity value that the applicant owns minus any outstanding mortgage / debt). So, if the value of a senior’s home has increased while they are enrolled in Medicaid, it may push the home above the home equity exempt limit in their state, which would make the senior ineligible.

If the Medicaid beneficiary lives in their home and the home equity interest is less than $713,000 or $1,071,000 (as of 2024 and depending on state) then the home will NOT be counted against the limit (also known as exempt). States with higher average property values use the $1,071,00 and states with lower property values use the $713,000 figure. If the beneficiary’s spouse, minor child, or blind or disabled child of any age lives there, the home is exempt regardless of the beneficiary’s home equity interest, and regardless of where the beneficiary lives. If none of the above-mentioned people live in the home, the home can be exempt if the beneficiary files an “intent to return” home and the home equity interest is at or below $713,000 or $1,071,000, depending on the state.

It’s important to note that the rules regarding home equity amounts only apply to Nursing Home Medicaid and Home and Community Based Services (HCBS) Waivers beneficiaries. Value does not matter when it comes a home’s exempt status for Aged, Blind, and Disabled (ABD) Medicaid beneficiaries.

 

Care Requirements

In addition to meeting financial criteria, Medicaid Long Term Care beneficiaries also have to meet functional, or medical, criteria to qualify for certain programs. This medical criteria may also be reevaluated during the Medicaid Renewal process, but in general states are more focused on reassessing financial criteria. In most cases, seniors who have previously met the medical criteria will continue to meet it.

The following are some general guidelines to the medical criteria for the three types of Medicaid Long Term Care:

To qualify for Nursing Home Medicaid, a senior must require a “Nursing Facility Level of Care,” which means they can’t live independently and need 24/7 supervision. Each state has their own method for determining a Medicaid applicant’s level of care need, but in general they will conduct an in-person assessment and communicate with the applicant’s doctors. For renewals, this is often a formality since it is unlikely a long-term, nursing home resident will improve to the point where they no longer require nursing home level care.

To qualify for most Home and Community Based Services (HCBS) Waivers in most states, applicants must require a Nursing Facility Level of Care, or be at risk of requiring that level of care, or be unable to live independently without the services provided by the HCBS Waiver. It’s important to note that these are just guidelines and HCBS Waiver functional criteria can vary from state to state and program to program.

There is no medical criteria for Aged, Blind and Disabled (ABD) Medicaid, other than being age 65 or over (or blind or disabled if you’re under age 65). However, to receive long-term care services and supports through ABD Medicaid, a senior must show a need for those supports. The need and services can be medical (like needing in-home nursing visits to help with a dialysis machine), or they can be non-medical (like getting meals delivered).

 

How Often Do Medicaid Renewals Happen?

Before the COVID-19 pandemic, Medicaid renewals usually happened once a year on the anniversary of the beneficiary’s initial Medicaid enrollment date. That won’t necessarily be the case during the unwinding period. According to this April 2023 report from KFF, 35 of 49 replying states planned to schedule renewals based on several factors, like vulnerability, potential ineligibility and time since last renewal. This approach allows states to delay renewals (and any potential gaps in coverage) with at-risk groups, such as seniors in nursing homes.

Medicaid renewals can happen more than once a year according to federal regulations, but it’s unlikely. Also, it’s important to note that Medicaid beneficiaries are required to report any changes in income or assets within 10-30 days of the change.

 

What Happens if Denied During a Medicaid Renewal?

Medicaid beneficiaries have 30 days to complete, date, sign, and submit their Renewal Forms. If they do not do this, their benefits and coverage will stop. This is also known as being disenrolled. If Medicaid beneficiaries are found to be no longer eligible after state officials have reviewed their Renewal Form, or if they are found to no longer be eligible during the renewal process, their benefits and coverage will also stop.

From the day of the stoppage, beneficiaries have another 90 days to submit or resubmit their Renewal Form. This gives them a chance to be re-enrolled in their Medicaid coverage without needing to reapply. If they do not submit or resubmit within 90 days, or if they are still found to be ineligible, they will lose their coverage and benefits and they will need to reapply for Medicaid.

The same KFF report mentioned above estimates that 18% of all Medicaid beneficiaries (about 17 million people) are likely to be disenrolled during this unwinding period. However, this percentage will vary widely by state, ranging anywhere from 7% to 33%. The rate of disenrollment will depend on the policies and capabilities of each state, which are analyzed in this May 2023 report from KFF. Click on the link if you want to find your state, but in general the states that are most likely to see high disenrollment numbers are Alaska, Arkansas, Hawaii, Kansas, Maine, Minnesota, Missouri, Nebraska, Oklahoma, South Dakota, West Virginia, Wyoming and the District of Columbia. And the states that are in the best position to help seniors renew successfully and avoid gaps in Medicaid coverage are Colorado, Indiana, Massachusetts and Virginia.

In a worst-case scenario, disenrollment could mean the individual being evicted from a nursing home. Or, in another worst-case scenario, it could mean losing in-home long-term care services and supports if they are in an HCBS Waivers program, and then potentially being put on a waitlist after reapplying and before receiving the long-term care benefits they were relying on.

However, in most cases, seniors who come into extra income or assets while they are enrolled in any of the Medicaid Long Term Care programs can come to an arrangement with the state that will allow them to stay in their nursing home or keep their in-home long-term care benefits. For example, they could potentially avoid any lapse in coverage by using their newfound money to cover costs for the nursing home, long-term care benefits, or any other Medicaid-approved healthcare expenses they need, until they get back under the Medicaid financial limits. While this kind of strategy is possible, it’s also complicated and would most likely require assistance from a Medicaid planning professional.

 

How to Prepare for a Medicaid Renewal

The first step in preparing for Medicaid Renewal is making sure your local Medicaid offices have your proper street address and email address. This will ensure you receive your Medicaid Renewal Form or notification of your automatic renewal. This May 2023 KFF report says 33% of all Medicaid beneficiaries have not updated their contact information with their state Medicaid offices. That same report also states that 68 percent of Medicaid beneficiaries over the age of 65 will be going through the renewal process for the first time. So, if you’re in unfamiliar territory, you’re not alone.

To help prepare for Medicaid renewal, you can also check your financial status against your state’s Medicaid criteria and see if you think you are still eligible. The easiest way to figure out your specific eligibility criteria is by using our Medicaid Long Term Care Eligibility Requirements Search Tool.

If you think you are going to be over the asset limit, you could start to spend those assets on Medicaid-approved healthcare goods and services in order to get below the limit before the renewal. It’s very important to strictly follow your state’s Medicaid guidelines during this “spend down” process, and implementing this strategy without the help of a Medicaid expert is not recommended. In fact, the majority (85%) of all Medicaid beneficiaries polled for the May 2023 KFF survey mentioned above said they would find it useful to have someone help them with the entire Medicaid renewal process.

If you think the state will not be able to conduct an automatic renewal for your case, you could start gathering some of the financial documents listed above. Gathering documents can be the most time-consuming part of the renewal process, so getting a head start can be a good idea.

 

Assistance Options to Help with Medicaid Renewals

If one’s financial situation and home ownership has not changed, and one still meets the Medicaid eligibility criteria, they can get free assistance from their Medicaid Case Managers. One might also find help from Public Benefits Counselors who work at Area Agencies on Aging, Aging and Disability Resource Centers, or even at state Medicaid offices.

However, if a senior has, for example, recently inherited money and no longer meet the Medicaid eligibility criteria, free assistance from a Public Benefits Counselor will not be available. Another example is when a home’s value or the residents of the home have changed. If this is your situation, you can get help with your Renewal through a Certified Medicaid Planner or some Elder Law Attorneys. The fees for this service can range anywhere from $1,500 to $3,000.