Which states have formally submitted state plan amendments electing MAGI‑like methodologies for non‑MAGI Medicaid groups?
Executive summary
States may elect to apply "MAGI‑like" financial methodologies to non‑MAGI Medicaid eligibility groups by submitting State Plan Amendments (SPAs), but the documents provided here explain the option and process rather than listing states that have formally filed those SPA elections; no source in the provided reporting names specific states that have submitted SPAs electing MAGI‑like methodologies for non‑MAGI groups [1] [2] [3].
1. What the option is and why it matters
The Centers for Medicare & Medicaid Services (CMS) allows a state, when electing MAGI‑like methodologies, to apply MAGI‑style household construction and income counting to groups traditionally determined under SSI/TANF‑era rules — an option described in CMS implementation guides and MACPro guidance on Non‑MAGI Methodologies and MAGI‑Based Methodologies [1] [4] [2]. This election can replace asset tests and many pre‑ACA disregards with the MAGI framework’s tax‑based household rules and no resource test, which has practical consequences for eligibility and continuity of coverage [4] [3].
2. What the provided sources actually show about state submissions
The provided material consists largely of CMS implementation guides, state technical documents, and policy surveys that explain the mechanism and policy tradeoffs but do not catalogue SPA filings; the CMS guides lay out how to prepare Reviewable Units (RUs) in MACPro for Non‑MAGI Methodologies and note dependent relationships among RUs for submission, but they do not contain a public roll call of which states have submitted or received approval for MAGI‑like elections [1] [2] [5]. Major policy trackers like KFF describe state variation in non‑MAGI eligibility rules and the optional nature of many non‑MAGI pathways, but KFF’s reporting likewise summarizes survey findings rather than listing SPA filings for MAGI‑like elections [6] [7].
3. Why reporting often skirts the direct answer
Most secondary sources emphasize conceptual differences between MAGI and non‑MAGI methodologies — for example, that MAGI disallows resource tests and standardizes income counting while non‑MAGI typically follows SSI rules — which informs debate but diverts attention from the granular administrative question of which states have formally submitted SPAs electing MAGI‑like methods [4] [3]. Implementation guides are procedural documents for states and CMS reviewers (describing MACPro RUs and the option to “apply the same definition of a parent that is used for MAGI”), not public registries of state policy changes [1] [2].
4. What can be concluded from the available evidence
From the supplied sources, it can only be concluded that: (a) the pathway to elect MAGI‑like methodologies exists and is documented by CMS guidance [1] [2]; (b) states retain wide discretion over non‑MAGI eligibility levels and methodologies, and many non‑MAGI pathways remain optional and varied across states [6] [7]; and (c) the public reporting presented here does not disclose a list of states that have filed or secured SPA approval to adopt MAGI‑like approaches for non‑MAGI groups [1] [5]. Any definitive identification of specific states that have formally submitted SPAs requires review of CMS SPA approval records or individual state SPA postings not included among these documents.
5. Implications, competing perspectives, and where to look next
Advocates argue that MAGI‑like methodologies can simplify enrollment and align Medicaid with marketplace rules, potentially reducing churn [4]; critics warn that shifting non‑MAGI groups to MAGI rules could strip away asset protections and change how household composition is counted for seniors and people with disabilities [3] [8]. To move from policy description to a definitive state list, the appropriate next step is to query CMS’s SPA approval database or each state Medicaid agency’s SPA docket — sources not present in the provided reporting but necessary to answer the original question exhaustively [1] [2].