State CHIP-Specific Eligibility Verification Plans
*Chart updated May 8, 2014
As a result of the ACA’s new eligibility rules, states were required to develop plans outlining their Medicaid and CHIP eligibility verification procedures. A previously published State Refor(u)m chart, State Medicaid and CHIP Eligibility Verification Plans, highlights key elements from states’ Medicaid and CHIP eligibility verification plans, such as which eligibility factors are verified through electronic data and the specific data sources states are using. While many of the eligibility procedures highlighted in the Medicaid and CHIP chart are shared across both programs, CHIP, and particularly separate CHIP programs, have some unique eligibility factors that pre-date the ACA. The chart below highlights these additional CHIP eligibility factors, including whether an applicant has access to other coverage; whether an applicant has access to an affordable offer of employer-sponsored insurance (ESI); whether a child has recently had coverage (as applicable to the states’ waiting period); whether an applicant has access to public employee coverage; and whether the state has additional waiting period exemptions unique to each state.
Only separate CHIP programs are required to complete the CHIP-specific section of the eligibility verification plans (Section C on the federal verification plan); however, many states with Medicaid expansion CHIP programs opted to provide additional CHIP program information so we have included all available information in our chart. For more CHIP-specific program information, including eligibility requirements, see the Medicaid and CHIP Payment and Access Commission’s (MACPAC) March 2011 report.
This chart is based on information contained in approved state Medicaid and CHIP eligibility verification plans; each state abbreviation links to each state’s plan. Please note that not all state verification plans have been approved so some states do not have eligibility verification procedures listed below. Information from the remaining states will be added to this chart as it becomes available.
Like all State Refor(u)m research, this chart is a collaborative effort with you, the user. Our team periodically supplements, analyzes, and compiles this key content. Do you know of information that should be added to this chart? Your feedback is central to our ongoing, real-time process, so tell us in a comment below, or email a staff member with your suggestion. You can reach Kris Wiitala at kwiitala@oldsite.nashp.org.
Only separate CHIP programs are required to complete the CHIP-specific section of the eligibility verification plans (Section C on the federal verification plan); however, many states with Medicaid expansion CHIP programs opted to provide additional CHIP program information so we have included all available information in our chart. For more CHIP-specific program information, including eligibility requirements, see the Medicaid and CHIP Payment and Access Commission’s (MACPAC) March 2011 report.
This chart is based on information contained in approved state Medicaid and CHIP eligibility verification plans; each state abbreviation links to each state’s plan. Please note that not all state verification plans have been approved so some states do not have eligibility verification procedures listed below. Information from the remaining states will be added to this chart as it becomes available.
Like all State Refor(u)m research, this chart is a collaborative effort with you, the user. Our team periodically supplements, analyzes, and compiles this key content. Do you know of information that should be added to this chart? Your feedback is central to our ongoing, real-time process, so tell us in a comment below, or email a staff member with your suggestion. You can reach Kris Wiitala at kwiitala@oldsite.nashp.org.
| State | Self-Attestation Accepted without Additional Verification for: | Self-Attestation Accepted with Post-enrollment Verification for: | Electronic Data Source Used for Verification of: | Paper Documentation Required for: | CHIP Waiting Period Exemptions Verification Methods [1] | CHIP Waiting Period Duration and Income-related Groups Exempt from Waiting Period [2] |
|---|---|---|---|---|---|---|
| AK | No other coverage | None | None | Not used unless a discrepancy is found | N/A | N/A |
| AL | No access to affordable ESI; access to public employee coverage | No other coverage; when child has had coverage | No other coverage; when child has had coverage | No other coverage; when child has had coverage | N/A | State eliminated CHIP waiting period |
| AR | No other coverage; no access to affordable ESI; when child has had coverage | None | None | None | Self attestation is accepted without additional verification for all waiting period exemptions | State shortened CHIP waiting period to 90 days Exempt groups: Below 133% FPL <6 years old Below 100% FPL >6 years old |
| AZ | None | None | No other coverage; when child has had coverage | No other coverage; when child has had coverage | Self attestation is accepted without additional verification if the child is seriously ill For the two other exemptions, an electronic data source is used and paper documentation is required when an electronic data source is not available |
90-day waiting period |
| CA | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | None | None | Not used unless a discrepancy is found | N/A | State eliminated CHIP waiting period as part of move to Medicaid expansion CHIP |
| CO | No other coverage | None | None | None | N/A | State eliminated CHIP waiting period |
| CT | State eliminated CHIP waiting period | |||||
| DC | N/A | |||||
| DE | Access to public employee coverage | No other coverage; when child has had coverage | No other coverage; when child has had coverage | Not used unless unable to resolve discrepancy through data source and reasonable explanation | N/A | State eliminated CHIP waiting period |
| FL | No other coverage; when child has had coverage | None | Access to public employee coverage | None | Self attestation is accepted without additional verification for all waiting period exemptions | 60-day waiting period |
| GA | When child has had coverage | No other coverage | No other coverage | No other coverage; no access to affordable ESI | Paper documentation is required for all waiting period exemptions | State shortened CHIP waiting period to 2 months |
| HI | None | None | No other coverage; no access to affordable ESI | Not used unless a discrepancy is found | N/A | N/A |
| IA | Access to public employee coverage | None | No other coverage; when child has had coverage | No other coverage; when child has had coverage | Electronic data source is used to verify a child is moving from Medicaid to CHIP To verify a child has a serious medical condition or disability, self attestation is accepted with post-enrollment verification and paper documentation Paper documentation is required for all remaining waiting period exemptions |
30-day waiting period Exempt groups: Below 200% FPL |
| ID | No other coverage; no access to affordable ESI; when child has had coverage | None | Access to public employee coverage | None | N/A | State eliminated CHIP waiting period |
| IL | N/A [3] | |||||
| IN | No other coverage | None | When child has had coverage | No access to affordable ESI; access to public employee coverage | Paper documentation is required for all waiting period exemptions | 90-day waiting period |
| KS | State shortened CHIP waiting period to 90 days Exempt groups: Below 200% FPL |
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| KY | Access to public employee coverage | No other coverage; no access to affordable ESI; when child has had coverage | No other coverage; no access to affordable ESI; when child has had coverage | None | N/A | State eliminated CHIP waiting period |
| LA | None | None | No other coverage; when child has had coverage; access to public employee coverage | None | Electronic data source is used to verify all of the state’s 8 waiting period exemptions Additional paper documentation is required for 2 exemptions – applicant lost insurance due to death of a parent or lifetime maximum limit reached |
State shortened CHIP waiting period to 90 days Exempt groups: Below 200% FPL |
| MA | No access to affordable ESI; when child has had coverage; access to public employee coverage | No other coverage; no access to affordable ESI; access to public employee coverage | No other coverage; no access to affordable ESI; access to public employee coverage | None | N/A | State eliminated CHIP waiting period |
| MD | None | No other coverage | No other coverage | None | N/A | State eliminated CHIP waiting period |
| ME | No access to affordable ESI; when child has had coverage | No other coverage; access to public employee coverage | No other coverage; access to public employee coverage | No other coverage; access to public employee coverage | Self attestation is accepted with post-enrollment verification through an electronic data source and paper documentation if an individual not residing with the child dropped coverage Paper documentation is required to verify a family pays 50% or more of the cost of the child’s coverage An electronic data source is used to verify a family pays over 10% of all family income for family coverage An electronic data source and paper documentation are required to verify there was good cause to terminate the child’s insurance coverage |
90-day waiting period |
| MI | State shortened CHIP waiting period to 90 days | |||||
| MN | No other coverage | None | None | None | N/A | N/A [4] |
| MO | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | None | Not used unless a discrepancy is found | Not used unless a discrepancy is found | Self attestation with post-enrollment verification is accepted using paper documentation to verify the child has special health care needs Self attestation without additional verification accepted for all other waiting period exemptions |
State shortened CHIP waiting period to 90 days Exempt groups: Below 150% FPL |
| MS | No other coverage | None | None | Not used unless a discrepancy is found | N/A | N/A |
| MT | No other coverage; when child has had coverage | None | None | No other coverage (only for Medicaid expansion program) | Self attestation accepted without additional verification for all waiting period exemptions | 90-day waiting period |
| NC | None | No other coverage; access to public employee coverage | No other coverage; access to public employee coverage | Not used unless a discrepancy is found | N/A | N/A |
| ND | For state’s separate CHIP program: no other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | For state’s Medicaid expansion program: no other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | None | Not used unless a discrepancy is found or if individual attests to having access to public employee coverage | Self attestation with post-enrollment verification accepted using electronic data sources and paper documentation for all waiting period exemptions | State shortened CHIP waiting period to 90 days |
| NE | No other coverage | None | No other coverage (only for individuals with BCBS of Nebraska) | Not used unless a discrepancy is found | N/A | N/A |
| NH | No other coverage; no access to affordable ESI; access to public employee coverage | None | None | None | N/A | N/A |
| NJ | None | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | When child has had coverage; access to public employee coverage | Paper documentation is required for all waiting period exemptions | 90-day waiting period |
| NM | No other coverage | None | None | None | N/A | State eliminated CHIP waiting period |
| NV | None | No other coverage; when child has had coverage; access to public employee coverage | No other coverage; when child has had coverage | Not used unless a discrepancy is found | N/A | State eliminated CHIP waiting period |
| NY | When child has had coverage | No other coverage; access to public employee coverage | No other coverage; access to public employee coverage | Not used unless a discrepancy is found | Self attestation is accepted without additional verification for all waiting period exemptions | State shortened CHIP waiting period to 90 days Exempt groups: Below 250% FPL |
| OH | No other coverage | None | None | None | N/A | N/A |
| OK | None | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | Not used unless state is unable to internally verify access to affordable ESI | N/A | N/A [5] |
| OR | None | No other coverage; no access to affordable ESI | No other coverage; no access to affordable ESI | Not used unless data source unavailable and client cannot be reached via phone or email for follow-up questions | N/A | State eliminated CHIP waiting period |
| PA | None | Access to public employee coverage | No other coverage; when child has had coverage; access to public employee coverage | No other coverage; when child has had coverage; access to public employee coverage | N/A | State eliminated CHIP waiting period |
| RI | None | No other coverage; no access to affordable ESI | No other coverage; no access to affordable ESI | No other coverage; no access to affordable ESI | N/A | N/A |
| SC | None | No other coverage | No other coverage | Not used unless a discrepancy is found | N/A | N/A |
| SD | Access to public employee coverage | No other coverage; when child has had coverage | No other coverage; when child has had coverage (no electronic data source is available at time of application) | Not used unless a discrepancy is found | Self attestation with post-enrollment verification is accepted using paper documentation to verify that the cost of discontinued coverage for the child exceeded 5% of the household income or that the cost of family coverage exceeds 9.5% of the household income Self attestation is accepted without additional verification for all other waiting period exemptions |
90-day waiting period |
| TN | None | No other coverage; access to public employee coverage | No other coverage; access to public employee coverage | Not used unless a discrepancy is found | N/A | State eliminated CHIP waiting period |
| TX | No other coverage; no access to affordable ESI; when child has had coverage | None | None | None | Self attestation without additional verification is accepted for all waiting period exemptions | 90-day waiting period |
| UT | 90-day waiting period | |||||
| VA | No other coverage; no access to affordable ESI; access to public employee coverage | None | None | When child has had coverage | N/A | State eliminated CHIP waiting period [6] |
| VT | No other coverage | None | None | Not used unless a discrepancy is found | N/A | N/A |
| WA | State eliminated CHIP waiting period | |||||
| WI | 90-day waiting period | |||||
| WV | None | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | No other coverage; no access to affordable ESI; when child has had coverage; access to public employee coverage | No other coverage; when child has had coverage; access to public employee coverage | N/A | State eliminated CHIP waiting period |
| WY | No other coverage; when child has had coverage; access to public employee coverage | None | No other coverage (only if discrepancy found); no access to affordable ESI | Not used unless a discrepancy is found or an electronic data source is not available | Electronic data source is used to verify that premiums paid for the child’s coverage exceed 5% of household income or that the cost of family coverage exceeds 9.5% of household income Paper documentation is required only if a discrepancy is found Self attestation is accepted for all other waiting period exemptions |
30-day waiting period |
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Notes:
Unless otherwise noted, all data is from individual state verification plans.
[1] States were required to submit their eligibility and enrollment verification plans to the Centers for Medicare and Medicaid Services (CMS) by summer 2013, but were not required to implement the new waiting period limit or newly mandated exceptions until January 1, 2014. As a result, states did not include the new waiting period exceptions in their verification plans. States are required to limit their waiting periods to 90-days and to provide “good cause exceptions” if: the child is transitioning from another Insurance Affordability Program (i.e., Medicaid or subsidized marketplace coverage); the cost of covering the child in a group plan exceeds 5% of household income; the cost of family coverage including the child exceeds 9.5% of household income; the employer stopped covering dependents or dropped employee coverage; there is a change in employment (including voluntary) which results in the child’s loss of ESI; the child has special health care needs; or the child lost coverage due to the death or divorce of a parent. Waiting period verification methods are not included for states that eliminated their waiting periods before January 1, 2014.
[2] Tricia Brooks and Martha Heberlein, Making Kids Wait for Coverage Makes No Sense in a Reformed Health System (Washington, DC: Georgetown University Health Policy Institute Center for Children and Families, December 2013).
[3] Illinois requires a 3-month waiting period for children between 133% and 200% FPL, however, the state funds coverage for those children during this period. Illinois also has a 12-month waiting period in its state-funded coverage between 200% and 300% FPL.
[4] Minnesota’s 120-day waiting period only applies to those children covered under the state’s Section 1115 waiver. Individuals at or below 200% FPL are exempt.
[5] Oklahoma has a 6-month waiting period in its Insure Oklahoma premium assistance program.
[6] Virginia’s legislature eliminated the state’s 120-day waiting period as part of the 2014 legislative session, effective July 1, 2014.
[1] States were required to submit their eligibility and enrollment verification plans to the Centers for Medicare and Medicaid Services (CMS) by summer 2013, but were not required to implement the new waiting period limit or newly mandated exceptions until January 1, 2014. As a result, states did not include the new waiting period exceptions in their verification plans. States are required to limit their waiting periods to 90-days and to provide “good cause exceptions” if: the child is transitioning from another Insurance Affordability Program (i.e., Medicaid or subsidized marketplace coverage); the cost of covering the child in a group plan exceeds 5% of household income; the cost of family coverage including the child exceeds 9.5% of household income; the employer stopped covering dependents or dropped employee coverage; there is a change in employment (including voluntary) which results in the child’s loss of ESI; the child has special health care needs; or the child lost coverage due to the death or divorce of a parent. Waiting period verification methods are not included for states that eliminated their waiting periods before January 1, 2014.
[2] Tricia Brooks and Martha Heberlein, Making Kids Wait for Coverage Makes No Sense in a Reformed Health System (Washington, DC: Georgetown University Health Policy Institute Center for Children and Families, December 2013).
[3] Illinois requires a 3-month waiting period for children between 133% and 200% FPL, however, the state funds coverage for those children during this period. Illinois also has a 12-month waiting period in its state-funded coverage between 200% and 300% FPL.
[4] Minnesota’s 120-day waiting period only applies to those children covered under the state’s Section 1115 waiver. Individuals at or below 200% FPL are exempt.
[5] Oklahoma has a 6-month waiting period in its Insure Oklahoma premium assistance program.
[6] Virginia’s legislature eliminated the state’s 120-day waiting period as part of the 2014 legislative session, effective July 1, 2014.
Chart produced by Jennifer Dolatshahi.
Support for the development of this chart came from Children in the Vanguard, a NASHP initiative funded by The Atlantic Philanthropies, and Maximizing Enrollment: Transforming State Health Coverage, a Robert Wood Johnson Foundation national initiative.
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