Depending on the individual’s situation, the following steps may be required:
- Documenting recent income using pay stubs or similar records. SNAP regulations require such documentation as a matter of first resort, unlike Medicaid regulations under the ACA, which require using data matches to establish eligibility whenever possible. Moreover, SNAP requires precise income documentation, since each dollar difference in earnings can translate into a 30-cent difference in benefits. By contrast, consumers are financially eligible for Medicaid if their income does not exceed 138 percent FPL, making it unnecessary to determine whether an individual’s income is at, for example, 90 or 70 percent FPL. Medicaid’s income determination does not end SNAP’s process of establishing financial eligibility, for these reasons as well as those described below.
- Documenting citizenship, satisfactory immigration status, and other facts for which health programs rely on the federal data hub. Health programs will verify citizenship, immigration status, and other facts using information from the Federal Data Services Hub—a new system that provides, in a single cyber-location, a link to information from the Social Security Administration, the Department of Homeland Security, and other data sources. Federal guidance currently limits the extent to which health programs can share information from the federal data hub with human services programs. As a result, consumers applying for SNAP may need to document facts relevant to eligibility, typically including but potentially going beyond citizenship and immigration status, for which health programs rely on the federal data hub.
- Documenting limited assets. Under the ACA’s new approach to Medicaid eligibility as well as subsidy eligibility for Marketplace coverage, income alone determines financial eligibility. For SNAP, by contrast, assets like bank accounts are relevant in many states, where applicants must identify them and document their value.
- Household composition. For most Medicaid beneficiaries under the ACA and for Marketplace subsidies, households are defined much as under tax law. In SNAP, they are defined differently, including people who live together and jointly buy and prepare food. Unrelated roommates can comprise a single SNAP household, but insurance affordability programs will treat them as separate households. Household size may thus need to be described and documented to qualify for SNAP, even for consumers who have already completed a health application.
- Direct communication with caseworkers. Traditionally, SNAP has required in-person interviews before benefits begin. However, many states now permit interviews to occur by phone. No interview process is required to qualify for health coverage, so applying for SNAP will often involve an extra step of meeting with caseworkers, in person or by phone.
Even though federal policymakers have focused on creating simplified applications, qualifying for insurance affordability programs will not be instantaneous or effortless. At a minimum, applicants will need to provide much personal information (contact information, social security number, address, date of birth, etc.) and attest to income and citizenship or immigration status. If data matches fail to provide verification, applicants may need to document these attestations. People who qualify for Medicaid but apply for coverage at a Marketplace are supposed to have their application handled seamlessly without any need for further effort on the applicant’s part. However, in practice some consumers who start their applications at the Marketplace may need to provide information a second time after their files are transferred to their states’ Medicaid programs; such “glitches” will presumably end after Marketplaces and Medicaid agencies have transitioned to full implementation of the ACA’s procedural requirements.59
Consumers who qualify for Marketplace subsidies rather than Medicaid face additional complications. They must shop for private insurance plans, analyzing the impact of possible premium tax credits and cost-sharing reductions. They will need to make complex decisions, weighing advantages and disadvantages related to multiple factors: specific benefits provided within the 10 required benefit categories (plus additional benefits that a particular plan may choose to cover);60 provider networks, including both whether one’s doctor is included in a plan’s network and the general breadth of a plan’s provider network; and costs associated with insurance plans, including plan tiers, premiums, deductibles, copayments, coinsurance, etc.
Such a complex analysis will need to encompass many plans. A recent analysis finds that the average marketplace rating area is served by five carriers that together offer 47 different qualified health plans.61