Current through Register Vol. 42, No. 11, August 30, 2024
(1) The Medicare
Catastrophic Coverage Act (MCCA) of 1988 provides for the special treatment of
income and resources of a married couple. The special treatment is to protect
the income and resources for the maintenance needs of the community spouse
while the spouse is in a medical institution or nursing facility. In
determining Medicaid eligibility for an institutionalized spouse, the
provisions of this section supersede any other inconsistent provisions of this
chapter, including the determination of income and resources.
(2) For purposes of this section, the
following definitions apply:
(a) SPOUSE -
Person legally married to another under State law. The SSI definition as
applied to the QMB/SLMB cases is not applicable to spousal cases. Legal
marriage is a traditional marriage conducted by legal authority or a common law
marriage recognized by a court and entered into prior to January 1,
2017.
(b) INSTITUTIONALIZED SPOUSE
(IS) - Legally married person who resides in a medical institution or nursing
facility and can reasonably be expected to continue to reside in the medical
institution or nursing facility for a continuous period.
(c) COMMUNITY SPOUSE (CS) - Legally married
person who is not living in a medical institution or nursing facility, and has
a spouse residing in a medical institution or nursing facility for a continuous
period.
(d) CONTINUOUS PERIOD OF
INSTITUTIONALIZATION - At least 30 consecutive days of institutionalization in
qualified medical institutions and/or nursing facilities.
(e) OTHERWISE AVAILABLE INCOME - Income that
would be used to determine eligibility without benefit of disregards (including
federal, state and local taxes) - gross income as defined by SSI.
(f) MAINTENANCE NEEDS STANDARDS - Income
standards against which community spouses' and other family members' incomes
are compared for purposes of determining the amount that can be allocated in
the post-eligibility calculation.
(g) MONTHLY MAINTENANCE NEEDS ALLOWANCE - The
minimum income the community spouse is entitled to have each month. This is an
amount deducted in the post-eligibility calculation of income for maintenance
needs of the community spouse (if both spouses agree to the allocation) or
other dependent family members to meet their needs in the community.
(h) SPOUSAL SHARE - The set total value
amount of resources protected for the community spouse. The Spousal Share is
the greater of the Minimum Protected Resource Amount or one-half of the total
value of the married couple's combined countable resources, not to exceed the
Maximum Protected Resource Amount.
(3) Protecting Income and Resources for the
Community Spouse.
(a) A monthly maintenance
needs allowance can be protected for the community spouse and family dependents
at home.
(b) Spousal Impoverishment
- To determine eligibility for an institutionalized spouse who has a community
spouse, all resources, whether owned jointly or individually by either spouse,
must be "pooled" beginning with the point that a spouse was institutionalized
to perform a Spousal Assessment. A Spousal Assessment must be conducted at both
the beginning of the first continuous period of institutionalization and at the
time of application for Medicaid benefits. A Spousal Assessment will calculate
the total value amount of both the resources available to the institutionalized
spouse and the protected Spousal Share of the community spouse. A Spousal
Assessment is to be completed at the request of either of the married couple,
an authorized representative acting on behalf of either spouse, or at the time
of application for Medicaid benefits. A Spousal Assessment is to be
accomplished in a prompt manner.
(c) When a married couple is both
institutionalized and both apply, each is treated as individuals rather than as
a couple. Treatment as individuals begins as of the first day of the month
following the month both are institutionalized. Spousal impoverishment rules do
not apply and an assessment of resources shall not be conducted.
(d) If a married couple is institutionalized
and only one applies for Medicaid, they are treated as individuals as of the
beginning of the first full month of separation. Income and assets of the
ineligible spouse must be deemed during the partial month.
(e) Spousal impoverishment rules apply to
legally married couples when one enters a medical institution or nursing
facility while the other remains in the community. The institutionalized spouse
must remain in an institution for 30 continuous days or longer.
(f) Spousal impoverishment does not apply if
a claimant is not legally married at the time he/she enters the medical
institution or nursing facility, unless he or she subsequently
marries.
(g) If there is a change
in circumstances such that there is no community spouse or institutional
spouse, spousal impoverishment provisions cease to apply. The effective date of
the cessation is the first full month following the change in status, for
example, the community spouse enters a medical institution or nursing facility;
or if the marriage is ended by death, divorce or annulment.
(h) In order for spousal impoverishment rules
to apply there must be a community spouse both at the point of
institutionalization and at the point of application.
(i) If the claimant marries after the initial
determination of eligibility, spousal rules apply. The resource assessment is
computed based on the assets owned by the couple, individually or jointly, at
the beginning of the institutionalized spouse's most recent continuous period
of institutionalization even though that point precedes the point in time where
there is a known community spouse.
(j) If both spouses enter an institution at
the same time, but one spouse returns to the community, an assessment must be
completed. The assessment is computed based on the resources owned by the
couple (individually or jointly) at the beginning of the institutionalized
spouse's most recent continuous period of institutionalization, even though
both spouses were institutionalized at that point.
(4) When a claimant for Medicaid was divorced
during the look-back period (60 months), the district office should review the
divorce settlement. If the claimant did not receive an equal share of the
marital estate, it may be considered a transfer of resources.
(5) Treatment of Income - The following rules
apply in determining ownership of income for eligibility purposes:
(a) Consider available to each spouse
one-half of any income paid in the name of both spouses,
(b) Consider any income paid solely to each
spouse as income to that spouse,
(c) Consider income paid in the name of
another party and both spouses, or one spouse, available to each spouse in
proportion to each spouse's interest (or one-half of the total amount to each
when payment is made to both spouses),
(d) Consider available to each spouse,
one-half of any income that has no instrument establishing ownership. The
institutionalized spouse is allowed to submit evidence to Medicaid to rebut the
determination of available income (other than trust income). Prenuptial
agreements are not binding nor considered for Medicaid eligibility purposes or
for spousal impoverishment.
(e) If
the institutionalized spouse is the grantor of a trust providing for payment of
income to him or her, the maximum amount payable by the terms of the trust will
be counted as available. No income paid only to a community spouse shall be
counted in determining eligibility or amount of the payment to the nursing home
for the institutionalized spouse for any month of institutionalization. The
rule on trust income incorporates Section 1902(k) of the Social Security Act,
the Medicaid Qualifying Trust provision.
(6) Compare the institutionalized spouse's
countable income to the institutional income limit.
(a) After the institutionalized spouse has
been determined income and resource eligible, determine the amount of income,
if any, to be applied toward the cost of institutional care (i.e., liability
amount) by deducting the following from the institutionalized spouse's income
in the following order:
1. Personal Needs
Allowance,
2. Community Spouse
Monthly Maintenance Needs Allowance, if applicable,
3. Family Maintenance Needs Allowance, if
applicable,
4. Amount for Health
Insurance premiums, if applicable.
(b) The remainder should be the amount the
claimant must pay to the nursing facility. In the case of a divorced couple,
alimony is not considered to be an income deduction for decreasing the
liability amount to be paid to the nursing facility.
(7) The minimum monthly maintenance needs
standard for the community spouse is recalculated each year. Changes, if any,
in this amount are effective in July. The community spouse monthly maintenance
needs allowance is determined as follows: Deduct the community spouse's monthly
income from the minimum monthly maintenance needs standard. This amount is
published each year by the U. S. Department of Health & Human Services
(HHS) and is 150 percent of the federal poverty level for a couple. Available
income of the community spouse includes income that would be used to determine
eligibility for the claimant, without benefit of disregards (including federal,
state, and local taxes)(gross income according to SSI standards). Any remaining
amount is the monthly maintenance needs allowance (if allocated to the spouse).
This amount is used in the post-eligibility calculation for allocation to the
community spouse. If in excess, an allowance is not made available. When
allowances are not made available to (or for the benefit of) the community
spouse, Medicaid will not deduct the allowance. The following are mandated
deductions for the institutionalized spouse and may reduce the monthly
maintenance needs allowance for the community spouse:
(a) personal needs allowance,
(b) Veterans Administration aid and
attendance allowance,
(c) Veterans
Administration payments for unusual medical expenses, and
(d) Veterans Administration continuing
medical expenses.
(8) A
maintenance needs allowance may be provided from the institutionalized spouse
to other dependent family members. The dependent family member is defined as: a
minor child, dependent adult child, dependent parent, or dependent sibling of
either spouse, who is living with the community spouse and who is listed on the
federal tax forms as a dependent (Internal Revenue Service tax dependent) of
the community spouse.
(a) Allowances for each
family member are determined as follows:
1.
Step 1. Deduct the gross income of the family member from the community spouse
minimum monthly maintenance standard;
2. Step 2. Divide the remainder in Step 1 by
3.
3. Step 3. The remainder in Step
2, rounded down to the nearest dollar, is the minimum family monthly
maintenance needs allowance used in the post-eligibility calculation to be
allocated to the family member. If in excess, an allowance is not made
available, deduct allowances for other family members, regardless of whether
institutionalized spouses make their income available to such
persons.
(b) When there
is no community spouse and there are other family members, the current AFDC
payment standard will be used. The total number of family members at home will
be computed against this table. This standard will be used when there are other
family members, even though in some instances the needs allowance will be less
than that of a spouse only. Any income of the family at home will be deducted
from the standard to determine allocation. If the family at home has no income,
the standard will be allocated. If the income of the institutionalized spouse
is below the standard, the entire income will be allocated except for the
protected personal needs allowance and the veterans aid and attendance
allowance, veterans reimbursement for continuing unusual medical expenses. The
current AFDC definition of family units will be used in determining who is a
family member.
(9)
Treatment of Resources - Medicaid shall "pool" the resources of an
institutionalized and community spouse when:
(a) Either spouse requests an assessment at
the beginning of the institutionalized spouse's first continuous period of
institutionalization; and
(b)
Although the married couple may not have requested a Spousal Assessment at the
time one of the spouses was institutionalized, Medicaid shall determine the
total combined resources existing at the point of institutionalization when the
initial Medicaid application is filed. At the time of application, Medicaid
computes the total combined value of the resources of the married couple and a
Spousal Share. A Spousal Assessment will be conducted both at the time and date
of institutionalization, and at the time of initial eligibility determination
(i.e., eligibility or ineligibility). All the resources owned by either the
institutionalized spouse or the community spouse, or both, shall be considered
a countable resource available to the institutionalized spouse, except for the
community spouse's Spousal Share.
(c) At the beginning of a continuous period
of institutionalization of a spouse, Medicaid shall to determine the total
value amount of both the Spousal Share of the community spouse and Medicaid
eligibility for the institutionalized spouse for the first month of a
continuous period of institutionalization as follows:
1. Step 1. List all combined countable
resources owned individually or jointly by the married couple at the date and
time of entry to the medical institution or nursing facility. The following
types of otherwise excluded resources shall be included in a Spousal
Assessment:
(i) equity value of real property
normally excluded from assets due to a bona fide effort to sell;
(ii) equity value of real property normally
excluded from assets because it is jointly owned, and the sale of the property
would cause the other owner undue hardship because of the loss of
housing;
(iii) equity value of real
property normally excluded because of a legal impediment; and/or
(iv) equity value of real property normally
excluded because it is income producing.
2. Step 2. Determine the total value of items
listed in Step 1 above. If the total in Step 2 is less than the Minimum
Protected Resource Amount (published annually by HHS), stop here. All resources
may be protected as the Spousal Share. If the amount in Step 2 is greater than
the Minimum Protected Resource Amount, go to Step 3.
3. Step 3. Determine 1/2 of the total value
in Step 2.
4. Step 4. Compare the
amount in Step 3 with the Maximum Protected Resource Amount (published annually
by HHS). If the amount in Step 3 is less than the Maximum Protected Resource
Amount, protect the amount in Step 3 as the Spousal Share. If the amount in
Step 3 is greater than the Maximum Protected Resource Amount, protect the
Maximum Protected Resource Amount as the Spousal Share.
5. Step 5. Subtract the amount in Step 4 from
the total amount in Step 2 above. The remaining amount is a countable resource
to be used for the institutionalized spouse. If this remaining amount exceeds
the current resource limit for an institutionalized case, the claimant is
ineligible until those assets and assets accumulated during the spend-down
period are spent down to the appropriate level.
6. During the continuous period of
institutionalization, after the month in which an institutionalized spouse is
determined to be eligible, no resources of the community spouse shall be deemed
to the institutionalized spouse.
7.
Once an assessment has been made, a new assessment can only be made if the
claimant is discharged from the nursing facility or medical institution for 30
continuous days and then readmitted for another 30-continuous day period. The
assessment can be reevaluated if it is determined that inaccurate information
was provided during the original assessment. Only the resources on hand at the
point of continuous institutionalization of the institutionalized spouse, and
the value of those resources can be used in the reevaluation of the assessment.
After the assessment is completed, the amount attributed to the
institutionalized spouse and any additional money accumulated or acquired by
either spouse, must be spent down to $2,000.00 on the institutionalized spouse
in order to be eligible. Gifts and resource exclusions that are otherwise
available when determining an individual's eligibility do not qualify as an
appropriate spend down. The institutionalized spouse may spend the money on
nursing home care, items he or she needs in the nursing home, to pay legitimate
debts belonging solely to him or her, maintenance on property in proportion to
the ownership interest, or other appropriate expenses. If the community spouse
or institutionalized spouse acquires additional resources during the spend-down
period, those additional resources must be spent down also. The only amount
that the community spouse can retain, prior to and at the time of the effective
date of eligibility for institutionalized Medicaid benefits, is the protected
amount determined in the assessment. After the effective date of eligibility
for institutionalized Medicaid benefits, no resources of the community spouse
shall be deemed available to the institutionalized spouse.
(10) Undue Hardship
(a) If information is available to make a
determination that excess resources exist and the institutionalized spouse or
sponsor claims an undue hardship exists, the case will be sent to the
Beneficiary Services East or West Division to determine whether an undue
hardship exists. If it is determined that an undue hardship exists, the
institutionalized spouse may be awarded eligibility.
(b) An undue hardship exists under this
section when Medicaid determines by clear and convincing evidence that the
institutionalized spouse lacks the right, authority, or power to access the
excess countable resources attributed to such spouse under 1924 (c)(2) of the
Social Security Act, and ineligibility for Medicaid benefits will result in
non-receipt of necessary medical services. In determining the existence of
"undue hardship," Medicaid will consider all circumstances involving the
situation of the institutionalized spouse, including but not limited to the
following:
1. Whether the institutionalized
spouse (or authorized representative) has exhausted all reasonable efforts to
obtain and utilize the resources in question; or
2. Whether the institutionalized spouse (or
authorized representative) has exhausted all reasonable efforts to meet his/her
needs from all other available sources; or
3. Whether the institutionalized spouse has
been determined to be a person in need of care and protection pursuant to the
Adult Protective Services Act, Code of Ala. 1975,
§
38-9-1, et seq.
(11) In situations when
the community spouse cannot be located, is alleged deceased, or refuses to
cooperate with the institutionalized spouse:
(a) The record shall contain a sworn
statement completed by the institutionalized spouse or other person with
knowledge of the whereabouts of the community spouse and must show the
following:
1. last known name;
2. last known address;
3. forwarding address at the post
office;
4. last known
employment;
5. circumstances
surrounding disappearance;
6.
health of the individual at time of disappearance;
7. state of mind of the individual at time of
disappearance;
8. efforts to
locate;
9. SSN/VA claim
number/other identifying information on the individual; and
10. if alleged to be deceased, obtain death
certificate from the Department of Public Health.
(b) The eligibility specialist must follow up
on any leads noted above and must verify the following: financial accounts,
property, and employment.
(12) Transfers by the community spouse to a
person or persons other than the institutionalized spouse may result in a
period of ineligibility for nursing home payments for the institutionalized
spouse. The institutionalized spouse will need to actually transfer (within 12
months) sufficient resources to equal the amount protected as the Spousal Share
so that such resources do not continue to cause ineligibility.
(13) All countable resources in excess of the
amount protected for the Spousal Share shall be countable resources to the
institutionalized spouse whether they are in the name of the institutionalized
spouse or community spouse.
Author: Denise Banks, Associate Director, Policy
and Training, Beneficiary Services Division
Statutory Authority:
42
USC 1396r-5. Social Security Act, Section
1924(a) through (g).