When renewing Medicaid coverage, states only need to reverify information subject to change. While there is no authoritative list of items "subject to change", a combination of CMS guidance, regulation, research, and common sense has determine a list of items that do (or do not) fall into these categories.
Items that are NOT considered subject to change:
- SSN
- Birthday (and by extension, age)
- Citizenship/Satisfactory immigration status (October Guidance, page 16)
- Blindness status (42 CFR 435.916(b)(1))
- Disability status (42 CFR 435.916(b)(2))
- Medicare status
- Household composition (CBPP Step 4)
- Tax filing status (CBPP Step 4)
- State residency
- Anything verified in the last six months
Items that are considered subject to change:
- Income
- Assets
- Pregnancy status (if previously determined pregnant)
- Immigration status if not satisfactory
However, states may be over-verifying items that are not subject to change unnecessarily. This can result in people failing out of ex parte due to data unavailability, or data source errors. It's also been observed that some states consider certain types of verifications "better" than others; an electronic verification is considered more reliable than a paper verification, for example, and paper verifications are re-verified on renewal. This is not grounded in any policy or regulation, and simply results in more work for both eligibility workers and clients.
Some signs a state may be verifiying unnecessarily:
- Verification errors for anything in the list above NOT subject to change
- Verification errors for data older than six months
- Verification errors for data verified manually or on paper
Rely on policy, regulation, guidance, and the examples of other states to get policy alignment on what needs to be re-verified (and what doesn't). After alignment is obtained, the checks can simply be removed.