health-reform-20

South Carolina 1115 Waiver Application Summary

June 11, 2019

McDermott+Consulting

On May 8, 2019, South Carolina submitted a new 1115 waiver application to the Centers for Medicare and Medicaid Services (CMS). The waiver includes work requirements, expands coverage for children, pregnant women and parents, and expands coverage for certain individuals with substance use disorders, who are chronically homeless or who are involved in the justice system. CMS is accepting comments on the application from June 10, 2019 through July 10, 2019.

The below summarizes key points of the waiver.

Waiver Elements

Work Requirements

Through the 1115 waiver, South Carolina is proposing to implement Medicaid work requirements for certain Medicaid beneficiaries. The following beneficiaries will be excluded from the work requirements: children, tribal organization members, pregnant women, individuals with disabilities, individuals over the age of 65, individuals who are the primary caregiver of a child or someone who is disabled, individuals receiving Social Security Disability Insurance (SSDI) or Supplemental Security Income (SSI), individuals participating in a substance use treatment program, individuals receiving treatment for cancer, and those compliant or exempt from SNAP and TANF work requirements.

Individuals that do not meet an exempt category and who are enrolled in South Carolina Medicaid through a Parent Caretaker Relative (PCR) program will be required to meet the work requirement. Work requirement compliant activities include: education, compliance with unemployment insurance work-search requirements, employment for no less than 80 hours per month, compliance with TANF and SNAP work requirements, or community or public service. South Carolina intends to develop standards that allow beneficiaries to demonstrate compliance by averaging 80 hours over the period of a quarter, even if they may not have met that target within individual months. The state also proposes not to issue any new eligibility suspensions for noncompliance during months in which the statewide unemployment rate is greater than eight percent.

Individuals who are not exempted and determined not to be in compliance with the work requirement for at least three consecutive months will have their eligibility suspended for three months or until the requirements are met.

Expanding Medicaid Coverage for Children, Pregnant Women and Parents

Through the waiver, South Carolina seeks to partially expand its current PCR Medicaid program to 100 percent of the federal poverty line (FPL). (Currently PCR income eligibility is 62 percent FPL.) To be eligible for the PCR Medicaid program, an individual must have a dependent child living at home, prove relationship to the child, and be a South Carolina resident and US citizen.

The state also intends to expand coverage for pregnant women/unborn children with incomes from 199 percent FPL to 246 percent FPL, and to extend coverage for pregnant women with incomes up to 199 percent FPL from 60 days postpartum to one year postpartum. For children on CHIP, the state proposes to expand CHIP eligibility from the current 213 percent FPL to 246 percent FPL.

Additionally, the waiver seeks to align Transitional Medicaid Assistance (TMA) with these new income thresholds by seeking such waivers and amendments as necessary to provide individuals who lose Medicaid coverage due to employment, who are also not eligible for employer-sponsored insurance, with the financial assistance necessary to purchase a qualifying health plan on the federal marketplace administered in South Carolina.

Expanding Medicaid Coverage for Certain Individuals with Substance Use Disorders, Justice-Involved and Chronically Homeless

Through the waiver South Carolina seeks to expand Medicaid coverage for certain individuals with substance use disorders. The state intends to use the waiver to expand Medicaid eligibility for a limited period to certain individuals who are not otherwise eligible for Medicaid or CHIP benefits, and who:

  • Have an income of zero percent FPL and are chronically homeless, subject to a standard five percent income disregard; or
  • Are justice-involved and need mental health or substance use treatment; or
  • Are uninsured, have an income of less than 95 percent FPL with a five percent income disregard, and need substance use treatment
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