Many of you have asked, on behalf of your residents, what impact the $1200 COVID-19 stimulus checks will have on Medicaid eligibility. Neither CMS nor the IRS has conclusively answered that in terms of Medicaid, however, we’ve dug deep and believe we can offer the below advice.
Short answer: The stimulus checks will be excluded from consideration as either income or resources for 12 months from receipt.
Long answer: The Stimulus funds are considered a tax credit, or more specifically, an advance credit against an individual’s 2020 return per the language of the CARES Act. IRS Section 6409 provides, in pertinent part “… any refund (or advance payment with respect to a refundable credit) made to any individual… shall not be taken into account as income and shall not be taken into account as resources for a period of 12 months from receipt, for purposes of determining the eligibility of such individual for benefits or assistance… under any Federal program or under any state or local program financed in whole or in part Federal funds.” Further under federal law, income excluded from eligibility calculations must also be excluded from patient liability calculations; thus the COVID-19 check should not impact your residents’ patient liability/cost share.
Our analysis is consistent with a statement made today by the SSA Commission, that “we will not consider economic impact payments as income for SSI recipients, and the payments are excluded from resources for 12 months.” Click here for more information.
If you have questions, please do not hesitate to contact Kelly Hayes, at khayes@stotlerhayes.com
