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Turn off the Medicaid optional aged/disabled pathway in 14 states that cover only SSI recipients - #10361

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@hua7450 hua7450 commented Oct 21, 2026 •

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Part of #9734 (step 1, the states that cover only SSI recipients). #9735 fixed the seven states whose standard is the SSI rate.

What changes

is_optional_senior_or_disabled_for_medicaid covers aged, blind and disabled people who don't receive SSI, up to the state's senior_or_disabled.income.limit. That limit is 0.75 of the poverty guideline in 14 states whose rules have no such group. They cover aged, blind and disabled people as categorically needy only if they receive SSI (or a state supplement): Alabama, Delaware, Georgia, Kansas, Kentucky, Maryland, Mississippi, Nevada, New Mexico, North Dakota, South Dakota, Tennessee, Texas and Wyoming.

  • New parameter gov.hhs.medicaid.eligibility.categories.senior_or_disabled.covers_non_ssi_recipients, by state. It is false for the 14 states and true elsewhere.
    • Mississippi is false from 2006-01-01. Its poverty-level aged and disabled group ended on December 31, 2005.
    • Mississippi is true before that. The earliest source found that shows the group in force is the Division of Medicaid's fiscal year 1997 annual report, so the true entry is dated 1996-07-01, when that fiscal year began. The group's start date is not sourced. The model starts in 2015, so this entry changes no modeled result.
    • The other entries start on 2018-01-01, like the other senior_or_disabled parameters.
    • The file sits outside income/ and assets/.
  • is_optional_senior_or_disabled_for_medicaid now requires the flag for people who pass the Medicaid immigration test.
    • Everyone who fails that test keeps the pathway. That includes people the model treats as meeting SSI's noncitizen rules: permanent residents in the five-year bar with 40 quarters, one-year parolees and conditional entrants in the bar, and refugees from 2027 (the October 2026 change to Medicaid's statuses, read on January 1).
    • medicaid_category ignores immigration status, and emergency Medicaid (is_emergency_medicaid_eligible) needs a category. Without this exception, undocumented aged or disabled people in the 14 states would lose emergency Medicaid.
    • Federal law waives the SSI receipt requirement for them. Emergency Medicaid pays for an alien who "otherwise meets the eligibility requirements for medical assistance under the State plan approved under this subchapter (other than the requirement of the receipt of aid or assistance under subchapter IV, supplemental security income benefits under subchapter XVI, or a State supplementary payment)" (42 U.S.C. 1396b(v)(2)(B)). 42 CFR 435.406(b) says the same ("except for receipt of AFDC, SSI, or State Supplementary payments"), and 42 CFR 440.255(c) defines the services.
    • Texas applies it: "Certain aliens with an emergency medical condition who meet all SSI criteria, except citizenship, may be eligible for Medicaid coverage for the medical emergency" (MEPD Handbook A-2200).
    • In the 14 states they are tested against the SSI federal benefit rate for an individual or a couple, at or below it, since only SSI receipt is waived (Texas: "meet all SSI criteria, except citizenship"; SSI covers income "at a rate of not more than" the rate, 42 U.S.C. 1382(a)(1)(A)). medicaid_optional_senior_or_disabled_income_limit uses the SSI rate wherever covers_non_ssi_recipients is false, and requires_income_below_limit stays false.
    • The limit binds now for noncitizens who meet SSI's noncitizen rules. For those who fail them, medicaid_optional_senior_or_disabled_countable_income counts no income until Count income of aged, blind, or disabled people who fail SSI's noncitizen test #10240 merges, so they qualify at any income until then, as on main.
    • North Dakota's 209(b) SSI recipients read the same limit, so theirs becomes the SSI rate here too. That is North Dakota's level (N.D.A.C. 75-02-02.1-40(1)(a)(2)), the change Use the SSI rate as the Medicaid aged/disabled income limit in West Virginia and North Dakota #10373 makes.

This removes Medicaid from SSI-eligible people who don't take up SSI in these 14 states, so microsimulation results change. Noncitizens there who pass Medicaid's immigration test but fail SSI's (for example, a permanent resident past the five-year bar without 40 quarters) lose the pathway the same way. It also closes the band between the SSI rate and 0.75 of the guideline ($42 a year in 2026). People in that band can get Medicaid only through medically needy coverage, where the state has it and they spend down to its limit.

Unchanged:

  • The 209(b) SSI-recipient path. North Dakota is a 209(b) state. Its SSI recipients are tested by is_209b_ssi_recipient_income_eligible_for_medicaid, which reads is_optional_senior_or_disabled_income_eligible, not the gated variable, so the flag doesn't gate them; their limit becomes the SSI rate (above). None of the other 13 states is a 209(b) state.
  • SSI recipients. is_ssi_recipient_for_medicaid (ssi > 0 or receives_ssi) still covers them.
  • Everything else. Every other state, and the pathway's countable income, disregards and asset limits. The income limit changes only in the 14 states.

West Virginia is not included

Issue 9734 lists West Virginia as covering only SSI recipients, but its current Income Maintenance Manual has the group:

  • § 23.9 lists "SSI Related/Non-Cash Assistance" among the optional aged, blind and disabled groups.
  • § 23.11.4 covers people who meet the SSI definition of aged, blind or disabled when "Countable income must be under the SSI Maximum Payment level", with assets up to $2,000 for an individual and $3,000 for a couple.
  • The archived § 16.7.H (revision 10/13) has the same group.

So West Virginia stays true and keeps today's 0.75 limit here. #10373 sets West Virginia's limit to the SSI rate with an at-or-below test (42 U.S.C. 1382(a)(1)(A); IMM § 4.14.3 Step 5), recording § 23.11.4's "under" as a source-conflict candidate.

Sources

Each was read on 2026-10-21.

State Source Text
Alabama Ala. Admin. Code r. 560-X-25-.03(1) "(a) Aged, blind or disabled persons who receive Supplemental Security Income (SSI) under Title XVI"; the other groups are institutional, waiver, people who lost SSI, and Medicare Savings Programs
Delaware DSSM 17100 "receiving a benefit through the Supplemental Security Income program, is automatically eligible for Medicaid in Delaware"
Georgia PAMMS 2111, 2101 "Georgia SSI recipients are automatically eligible for Medicaid for any month in which they receive a check"; 2101 lists no poverty-level or 435.210 class
Kansas SPA KS-25-0019, effective 2025-07-01 "Individuals Eligible for but Not Receiving Cash Assistance" and "Age and Disability-Related Poverty Level" are not checked as covered
Kentucky 907 KAR 20:005 §§ 1(1), 9(3) "An individual who would be eligible for SSI benefits but who has not made application shall not be eligible for Medicaid."
Maryland Coverage Groups guide (April 2025), S02 and S98 S02 covers "all SSI recipients"; S98 covers aged, blind or disabled people "within the MA community medically needy income and resource standards"
Mississippi Miss. Code § 43-13-115(11) (as reprinted in 2024 HB 464); manual Appendix A-4-c; FY 1997 annual report "Until the end of the day on December 31, 2005 ... After December 31, 2005, only those individuals covered under the 1115(c) Healthier Mississippi waiver will be covered under this category"; PLAD categories 041-043 list an ending date of 12/31/2005. The FY 1997 report (July 1996 to June 1997) lists "Persons who are age 65 or over or disabled whose income is below 100 percent of the federal poverty level whose resources are at SSI levels" (read 2026-10-26)
Nevada Medical Assistance Manual B-300 (March 2025) B-315 "Verified SSI recipients"; B-320 "Countable net income (after disregards) must be less than the applicable SSI payment amounts"; B-340 Prior Medical covers past months only
New Mexico 8.200.400.10(C)(1) NMAC "Medicaid for individuals who are eligible for SSI. Eligibility for SSI is determined by the social security administration (SSA)."
North Dakota N.D. Admin. Code 75-02-02.1-05 (1)(n), (2) and (3)(e) The categorically needy group covers aged, blind or disabled people "who are receiving supplemental security income payments" (plus zero-pay and suspended cases). The optional categorically needy groups in (2) include no non-SSI aged or disabled group, and (3)(e) makes aged, blind or disabled people "who are not in receipt of supplemental security income" medically needy. The February 2017 edition has the same text.
South Dakota ARSD 67:46:01:02(2) "A person who is a recipient of a money payment under the supplemental security income program"
Tennessee Tenn. Comp. R. & Regs. 1200-13-20-.08(1) "Aged, blind or disabled individuals who are determined eligible for SSI payments by the SSA are eligible for TennCare Medicaid." Medically needy covers only children and pregnant women
Texas MEPD Handbook A-2000, A-3000 Mandatory groups are SSI, emergency Medicaid for aliens, and the RSDI COLA increase. A-3000: "HHSC only provides benefits to a person who is a member of one of the following optional coverage groups"; none covers SSI non-recipients in the community
Wyoming Wyo. Admin. Rules 048.0037.18 § 8(a) (effective 2025-05-23); Eligibility Online Manual M1005 "Entitled to or receiving SSI, or SSI-related programs". M1005's SSI-related list covers DAC, E01 (institutions only), Goldberg-Kelly, Pickle, 1619, "SSI Eligible" (SSA current-pay status), widows and widowers, and presumptive disability

The parameter also cites 42 CFR 435.210, 42 U.S.C. 1396a(m), and KFF's June 2024 Appendix Table 1, which marks these states No for the poverty-level group.

Readers checked

Reader Effect
medicaid_category People who leave the pathway fall to the next category, usually MEDICALLY_NEEDY or NONE.
is_medically_needy_for_medicaid Its not_in_other_pathway sums the covered categories, so the pathway no longer blocks medically needy coverage. The effect differs by state:
• GA, KS, KY and MD have finite medically needy limits for aged and disabled people in the model, so people there can now spend down to them.
• ND's medically needy group is switched off in the model today. #10374 switches it on (83% of the guideline, then 90% from 2024-01-01), so until then North Dakotans who leave the pathway get no category.
• NV and NM have the medically needy flags on but -inf limits, so nobody qualifies.
• AL, DE, MS, SD, TN, TX and WY have no aged or disabled medically needy group.
Medically needy parameters are unchanged; the KS limit is being fixed under #10357 and #10358.
medicaid_group People who move to MEDICALLY_NEEDY stay AGED_DISABLED.
ms_hmw_other_coverage_ineligible (Healthier Mississippi Waiver) Mississippi's pathway is now always false, so it no longer excludes anyone from the waiver. The waiver's own income, resource and Medicare tests still apply.
is_209b_ssi_recipient_for_medicaid Reads the asset and income variables directly. Unchanged.
Medicare Savings Programs is_qi_eligible reads is_medicaid_eligible, but QI starts at 120% of the guideline, above everyone affected. No other MSP variable reads the pathway.
ACA, Lifeline, CHIP, Pell, DART and other is_medicaid_eligible / medicaid_enrolled readers Follow Medicaid eligibility. A person who loses Medicaid can become eligible for the premium tax credit if their income is at least 100% of the guideline (see the partner test below).

Tests

  • is_optional_senior_or_disabled_for_medicaid.yaml
    • Case 3: an Alabaman aged 70 with $900 a month of Social Security who doesn't take up SSI. Income-eligible ($10,560 countable, under the $11,928 SSI rate) but not covered; medicaid_category is NONE.
    • Case 4: the same person in Pennsylvania, which keeps the group, is SENIOR_OR_DISABLED.
    • Case 5: a disabled North Dakotan aged 50 with $900 a month of SSDI who doesn't take up SSI is income-eligible but not covered.
    • Case 6: an undocumented Alabaman aged 70 with $800 a month of wages keeps the pathway, unlike the citizen in Case 3. medicaid_category is SENIOR_OR_DISABLED, is_medicaid_eligible is false and is_emergency_medicaid_eligible is true. The wages are under the $11,928 limit before any disregard, so the case holds after Count income of aged, blind, or disabled people who fail SSI's noncitizen test #10240 too.
    • Case 7: a permanent resident in Alabama two years after entry (five-year bar), aged 70, with $11,940 of countable income, $12 over the $11,928 SSI rate: income-ineligible, so no pathway, category NONE and no emergency Medicaid despite an emergency condition.
    • Case 8: a couple of such permanent residents with $8,946 each, exactly the $17,892 SSI couple rate (12 x $1,491): both keep the pathway (SENIOR_OR_DISABLED); emergency Medicaid only for the spouse with an emergency condition.
  • tests/unit/test_medicaid_abd_ssi_rate_standard_properties.py: the SSI-rate property tests read covers_non_ssi_recipients. test_no_medicaid_without_ssi_above_the_ssi_rate expects the pathway only where the state covers the group, and test_unflagged_states_keep_their_share_of_the_poverty_guideline skips the 14 states, which now use the SSI rate.
  • medicaid_category.yaml
    • Case 13: the same Alabaman taking up SSI gets $1,368 a year and is SSI_RECIPIENT.
    • Case 14: the same person in Maryland, not taking up SSI, with $7,200 of other medical expenses, is MEDICALLY_NEEDY (limit $350 a month).
  • ms/dom/hmw/integration.yaml, Case 7: renamed. The old name said the person was "eligible under standard optional ABD Medicaid", which Mississippi no longer has in the model. The person receives SSI, so the case now also asserts is_ssi_recipient_for_medicaid: true; its other expected values are unchanged.
  • Other tests in the 14 states: I checked every YAML case with an aged, blind or disabled person and an output that depends on Medicaid. Each person receives SSI, overrides the pathway as an input, or fails it on income or assets, except the partner case below.
  • Local runs at 707e042, one process at a time. Everything added after it (Cases 6 to 8, the Mississippi entry, the references, the SSI-rate limit and the property-test changes) was not run locally; CI validates.
    • gov/hhs/medicaid (batched): all passed. This includes emergency_medicaid/integration.yaml Case 20, an undocumented disabled Texan with an emergency, which failed before the immigration exception.
    • MS HMW, KS SSPP, TX CEAP and TX Lifeline: 96 passed.
    • tests/unit/test_medicaid_abd_ssi_rate_standard_properties.py, tests/core/test_ssi_state_supplement_medicaid_dependency.py, test_parameter_files.py and tests/code_health: 537 passed, 1 skipped (run before the immigration exception).
    • Partner cash/ssi/federal.yaml: 13 passed, plus the expected failure below (medicaid@2026 0.0 vs 13,708.5).

Partner test impact

partners/analytics_coverage/edge_cases/federal/cash/ssi/federal.yaml, case ssi_earned_income_at_breakeven_ineligible (federal), is expected to fail. It is a 65-year-old citizen in Dallas County, Texas, with $24,876 of wages. SSI countable income equals the SSI rate ($11,928), so ssi is 0. Its comment attributes the Medicaid to "TX's optional senior-or-disabled pathway", the $42 band above. Texas covers only SSI recipients (MEPD A-2000), so the person has no Medicaid after this PR.

CI hasn't run on this draft, and the test runner stops at a case's first mismatch, so CI will report only medicaid. The five pins that change, traced from the model files (not run):

Output Expected now After this PR
medicaid 13,708.50 0
is_medicaid_eligible true false
is_aca_ptc_eligible false true
aca_ptc 0 18,344.28
premium_tax_credit 0 18,344.28

The premium tax credit:

  • MAGI fraction: 24,876 / 15,650 (the 2025 guideline, one person) = 1.5895, floored to 1.58 (aca_magi_fraction). That is between 1.00 and 4.00, and the case sets is_medicare_eligible and is_aca_eshi_eligible false, so with Medicaid gone is_aca_ptc_eligible is true.
  • Applicable figure, 2026 bracket 1.50 to 2.00: 0.0419 + (1.58 - 1.50) / 0.50 x (0.066 - 0.0419) = 0.045756. Contribution: 24,876 x 0.045756 = 1,138.23.
  • SLCSP: Dallas County is rating area 8; the 2026 age-0 cost there is $414 a month, and the default age curve gives 3.9216 at 64 and over (Texas has no family tiers). 414 x 3.9216 x 12 = 19,482.51.
  • Credit: 19,482.51 - 1,138.23 = 18,344.28, which premium_tax_credit takes as well.

Unchanged pins: ssi_countable_income 11,928, ssi 0, is_ssi_eligible true, is_ssi_aged true, msp 0, msp_eligible false and chip 0. The partner folder is not edited here; whether to update the case is the user's call.

Merge order

Not changed here

axiom: TheAxiomFoundation/rulespec-us#1927 queued

🤖 Generated with Claude Code

hua7450 and others added 2 commits October 21, 2026 16:57
…SSI recipients

Add gov.hhs.medicaid.eligibility.categories.senior_or_disabled.covers_non_ssi_recipients,
false for AL, DE, GA, KS, KY, MD, MS, NV, NM, SD, TN, TX and WY, and require it in
is_optional_senior_or_disabled_for_medicaid. The 209(b) SSI-recipient path is unchanged.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
N.D. Admin. Code 75-02-02.1-05 covers aged, blind and disabled people as
categorically needy only if they receive SSI; those who do not are medically
needy under (3)(e). The 209(b) SSI-recipient path does not read the gated
variable, so North Dakota's SSI recipients are unaffected.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
@hua7450 hua7450 changed the title Turn off the Medicaid optional aged/disabled pathway in 13 states that cover only SSI recipients Turn off the Medicaid optional aged/disabled pathway in 14 states that cover only SSI recipients Oct 22, 2026
…thway

Medicaid categories ignore immigration status, and emergency Medicaid needs
a category. In the states that cover only SSI recipients, noncitizens cannot
receive SSI, so the gate would have removed their emergency Medicaid. Texas
MEPD A-2200 covers aliens who meet all SSI criteria except citizenship.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
hua7450 and others added 2 commits October 26, 2026 16:34
- Add a case for an undocumented aged Alabaman who keeps the pathway and
  qualifies for emergency Medicaid.
- Cite 42 U.S.C. 1396b(v)(2)(B) and 42 CFR 435.406(b) for the exception.
- Mississippi covered people who do not receive SSI before 2006; date the
  earlier true value from the fiscal year 1997 annual report.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Add 42 U.S.C. 1396b(v) and 42 CFR 435.406(b) to the pathway variable's
references, since the immigration exception rests on them.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
In states that cover aged, blind or disabled people only if they receive
SSI, the pathway now reaches only noncitizens who fail the Medicaid
immigration test. 42 U.S.C. 1396b(v)(2)(B) waives SSI receipt alone, so
their income limit is the SSI federal benefit rate, at or below it.

- Add Case 7 (permanent resident in the five-year bar, $12 over the SSI
  rate) and Case 8 (a couple exactly at the SSI couple rate).
- Make the SSI-rate property tests aware of covers_non_ssi_recipients.
- Cite 1396b(v), 1382(a) and 42 CFR 440.255(c).

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
@hua7450
hua7450 marked this pull request as ready for review October 26, 2026 23:53
Cases 7 and 8 set only the pathway's countable income. With no SSI
income, the model paid the full SSI rate and classified the residents as
SSI recipients. Social Security that puts SSI countable income at or
above the SSI rate keeps them off SSI, as the cases intend.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>

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