Several other potential benefits might accrue to states and beneficiaries as a result of implementing ELE. First, ELE can address the problem of siloed public benefits. Low-income families seeking several forms of assistance must typically provide the same information to more than one program, each of which pays its staff to process that information. This creates needless administrative costs for government agencies, as well as more demanding application procedures for families that reduce participation levels. One reason for such redundancy involves technical differences between program eligibility rules. For example, SNAP generally limits benefits to households with “net income” at or below 100 percent of the Federal poverty level (for comparison, Medicaid minimum thresholds are 133 percent of the Federal poverty level for children from birth through age 5 and 100 percent of the Federal poverty level for children ages 6 to 19). One might think that SNAP-recipient children are thus necessarily income-eligible for Medicaid and that, when families seek Medicaid on their behalf, they could be relieved of the need to document income. However, SNAP determines “net income” by applying excess shelter cost deductions that Medicaid does not use. SNAP and Medicaid also use different definitions of the household members whose needs and earnings count in determining income. Therefore, SNAP eligibility determinations typically cannot qualify children for Medicaid without families providing additional information or Medicaid staff meticulously “cross-walking” information from SNAP records into the categories established by Medicaid eligibility rules.
A traditional approach to breaking down these silos involves modifying different programs’ rules and procedures so they align. Although this approach has considerable merit, it is not easy to change the rules of multiple programs. ELE takes a different approach that may, under some circumstances, be easier to implement. In this approach, each program continues to apply its own eligibility methodologies, but one agency uses the other agency’s findings to qualify people for subsidies, despite their methodological differences.
Second, ELE also provides a new way to address the challenges created by delinking Medicaid and cash assistance. Before the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) passed in 1996, the typical route to Medicaid ran through applications for cash assistance, which represented a higher priority than health coverage for many low-income families. With ELE, a state can once again connect health coverage to other benefits, like SNAP, that many families perceive as higher priority.
It is true that public benefit programs have long offered application forms that permit families to simultaneously seek SNAP, Medicaid, cash assistance, and sometimes other benefits (such as energy assistance). However, such forms request the information needed by all these programs, a burden that defeats many applicants. To help families avoid long forms, some states have encouraged families to file SNAP-only applications or Medicaid/CHIP-only applications. ELE offers states a way to reduce the burden of multi-program enrollment: a family filing a SNAP-only application, for example, can receive Medicaid or CHIP as well.
Finally, ELE might help states implement the Affordable Care Act. The Affordable Care Act requires states to transition to data-based eligibility methods that will qualify people for Medicaid, CHIP, and subsidies in the Affordable Insurance Exchanges (a new marketplace for obtaining coverage, often referred to as “the exchanges”).7 Because of the central role of modified adjusted gross income (MAGI) and tax return information under the Affordable Care Act, this progress could be particularly meaningful for states that use ELE to grant eligibility based on data matches with tax agencies. ELE might also preserve linkages between programs like SNAP, NSLP, Medicaid, and CHIP, assuring that eligible children remain insured as states focus on systems issues and covering newly eligible individuals in 2014. In addition, SNAP linkages may be useful for states seeking to reduce their administrative burdens by prequalifying low-income adults who will be newly eligible for Medicaid in 2014. More fundamentally, the Affordable Care Act requires that, whenever possible, eligibility for Medicaid, CHIP, and subsidies in the exchange must be established, verified, and renewed based on matches with reliable data sources. With ELE, states can begin making the challenging shift from traditional, manual methods to data-based routines for processing applications and renewals.
7 The development of Affordable Insurance Exchanges (operated by states or the Federal government) through which certified health plans and subsidies would be made available to eligible individuals was legislated as part of the Affordable Care Act. The exchanges must coordinate eligibility determinations with Medicaid and CHIP so that eligibility for the appropriate program is established based on a single application that a person can submit online, over the telephone, by mail, or in person.