Projected 2024 Medicaid Long Term Care Financial Eligibility Criteria

Introduction
Medicaid long term care’s various financial eligibility criteria change multiple times per year with the largest changes effective Jan. 1. This article contains Eldercare Resource Planning’s projections for the 2024 calendar year. We want to emphasize that these are projected limits and while our projections are typically accurate within a few dollars, these should not be used for Medicaid planning purposes.

Summary

• FBR Income Limits – The majority of states use 300% of the Federal Benefit Rate (FBR) as their income limit. The FBR for 2024 has already been released, and therefore, these figures are not projected. Effective Jan. 1, 2024, the FBR will be $943 / month for an individual and $1,415 / month for a couple. For states using 300% of the FBR as the income limit, a single applicant will be limited to $2,829 / month, and a married couple (with both spouses as applicants) will be limited to $5,658 / month.
• FPL Income Limits – Some states use a percentage of the Federal Poverty Level (FPL) as their income limit. We do not have projected FPL limits for 2024, but these figures are generally released and effective mid-late January.
• Assets Limits – It is projected that most states will not change their asset limits for single or married applicants for 2024. California is eliminating their asset limits effective Jan. 1, 2024.
• Minimum Monthly Maintenance Needs Allowance – For those states that use a Min. MMNA, it will remain $2,465 / month until July 1, 2024. We currently have no projection for the new figure.
• Maximum Monthly Maintenance Needs Allowance – For those states that use a Max. MMNA, it is projected to be $3,853 / month effective Jan. 1, 2024.
• Minimum Community Spouse Resource Allowance – For those states that use a Min. CSRA, it is projected to be $30,824 effective Jan. 1, 2024.
• Maximum Community Spouse Resource Allowance – For those states that use a Max. CSRA, it is projected to be $154,119 effective Jan. 1, 2024.
• Home Equity Limits – For those states that use $688,000 or $1,033,000 in 2023, the projected 2024 limits will be $713,000 and $1,071,000, respectively. California will continue to have no upper limit on home equity. ID, ME, and WI are addressed below.

Below we discuss each of the Medicaid financial limits in more detail. We include current 2023 limits, projected 2024 limits, state-specific limits, and exceptions to the rules. Note that the information contained below is not entirely comprehensive, nor does it cover all nuances in all states.

Federal Benefit Rate Income Limits

The federal government caps the income limit for Institutional Medicaid and HCBS Waivers at 300% of the Federal Benefit Rate (FBR) for an individual. While states can set a lower monthly income limit, most states elect to use 300% of the FBR.

In 2023, the FBR is $914 / month for an individual, and 300% of the FBR for an individual is $2,742 / month. When both spouses of a married couple are applicants, the income of each spouse is limited to $2,742 / month ($5,484 / month as a couple). For married couples with just one spouse as an applicant, the applicant spouse is limited to $2,742 / month in income, and the non-applicant spouse’s income is disregarded. Furthermore, spousal impoverishment rules apply. For income, it is the monthly maintenance needs allowance that is relevant.

Effective Jan. 1, 2024, the FBR will be $943 / month for an individual, and 300% of the FBR for an individual will be $2,829 / month. When both spouses of a married couple are applicants, the income of each will be limited to $2,829 / month ($5,658 / month as a couple). For married couples with just one spouse as an applicant, the applicant spouse will be limited to $2,829 / month in income. The non-applicant spouse’s income will be disregarded. Additionally, spousal impoverishment rules apply, and it is the monthly maintenance needs allowance that is relevant to the discussion of income.

We break the states that use the FBR as income limits into two groups 1) Those that use 300% of the FBR 2) Exceptions.

Group 1 – Will use the income limits of $2,829 / month for an individual and $5,658 / month for a couple (with both spouses as applicants) effective Jan. 1, 2024. These states include Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, District of Columbia, Florida, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Nevada, New Hampshire, New Jersey, New Mexico, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming. While most of these states use 300% of the FBR for their income limit for both Institutional Medicaid and HCBS Waivers, some states may use this figure for only one of these programs. This means that one of the programs may have an income limit based on the FBR while the other program has an income limit based on the Federal Poverty Level (FPL).

Group 2 – Delaware uses 250% of the FBR as their income limit. Effective Jan. 1, 2024, DE’s income limit will be $2,357.50 / month for an individual and $4,715 / month for a couple (with both spouses as applicants). Missouri uses a FBR percentage as their income limit, but the percentage differs based on the program.

Federal Poverty Level Income Limits

A handful of states use a percentage of the Federal Poverty Level (FPL) as their income limits. Many of these states use 100% of the FPL, which in 2023, is $1,215 / month for a household of one and $1,643 / month for a household of two. For married couples, with just one spouse as an applicant, the applicant is limited to $1,215 / month in income. When both spouses of a married couple are applicants, the couples’ combined income is limited to $1,643 / month. For married couples with just one spouse as an applicant, the applicant spouse is limited to $1,215 / month in income and the non-applicant spouse’s income is disregarded. Furthermore, spousal impoverishment rules. For income, it is the monthly maintenance needs allowance that is relevant.

While we do not have projections for the 2024 FPLs, we expect the figures to be released mid-late January. When a state chooses to implement the new income limits is state-specific. Some states implement their new limits immediately, while others wait until later in the year. For example, California and Illinois change their income limits in April.

We break the states that use the FPL as income limits into two groups 1) Those that use 100% of the FPL 2) Exceptions.

Group 1 – States that use 100% of the FPL: Illinois, Massachusetts, Minnesota, Nebraska, North Carolina, and Utah. Hawaii also uses 100% of the FPL, but the FPL for Hawaii differs from the rest of the states. In 2023, 100% of the FPL in Hawaii is $1,398 / month for an individual.

Group 2 – States that use the FPL as their income limit, but do not use 100%. We include the FPL percentage that is used as the income limit in parenthesis following a state’s name. California (138%), North Dakota (83%), and New York (138%).

States may use the FPL income limit for both Institutional Medicaid and HCBS Waivers or for just one of the programs. This means that one of the programs may have an income limit based on the FPL while the other program has an income limit based on the Federal Benefit Rate (FBR).

Asset Limits

Medicaid asset limits typically do not change from year to year. When they do change, it is based on state rules rather than federal rules. In 2023, the asset limit in most states is $2,000 for an individual and $3,000 for a married couple (with both spouses as applicants). Note that some states use $4,000 as the asset limit for couples with both spouses as applicants ($2,000 / spouse). For married couples with just one spouse as an applicant, the applicant spouse is limited to $2,000 in assets, which the non-applicant spouse is allocated a larger amount of the couple’s assets. This is a spousal impoverishment rule called the community spouse resource allowance.

There are a couple of significant exceptions to the asset limits mentioned above. In 2023, New York has an asset limit of $30,182 for an individual and $40,821 for a couple (with both spouses as applicants). Illinois is another exception. The state increased their asset limit to $17,500 for an individual and $35,000 for a couple (with both spouses as applicants) effective May 12, 2023. It is unclear if these states will increase their asset limits in 2024. California is yet another exception. The state increased their asset limit on July 1, 2022 to $130,000 for an individual and $195,000 for a couple (with both spouses applying). The state is eliminating the asset limit altogether effective Jan. 1, 2024.

Minimum & Maximum Monthly Maintenance Needs Allowance

The monthly maintenance needs allowance (MMNA) is a spousal impoverishment rule that allows an applicant spouse to transfer a portion of their income, or in some cases, all of their income, to their non-applicant spouse as a spousal income allowance to prevent spousal impoverishment. Currently, the federally set minimum MMNA is $2,465 and the maximum MMNA is $3,715.50. The minimum MMNA increases annually effective July 1, and we currently have no projection for this figure for July 1, 2024. The maximum MMNA increases each year effective Jan. 1. This amount is determined based on the Consumer Price Index (CPI) and we project it to be $3,853 for 2024 based on September’s CPI. All states fall into one of three groups 1) Those that use the federally set minimum and maximum MMNAs 2) Those that use only the maximum MMNA 3) Exceptions.

Group 1 – Projected to use $2,465 as the minimum MMNA and $3,853 as the maximum MMNA effective Jan. 1, 2024. These states include the following: Arizona, Arkansas, Colorado, Connecticut, Delaware, District of Columbia, Florida, Idaho, Indiana, Kansas, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, South Dakota, Tennessee, Utah, Vermont, Virginia, Washington, and West Virginia (only applies to Institutional Medicaid).

Group 2 – Projected to use only the maximum MMNA of $3,853 effective Jan. 1, 2024. These states include the following: Alaska, California, Georgia, Hawaii, Illinois, Iowa, Louisiana, Mississippi, New York, Oklahoma, South Carolina, Texas, and Wyoming.

Group 3 – Wisconsin currently uses a minimum MMNA of $3,286.66 and a maximum MMNA of $3,715.50. We project the maximum MMNA to become $3,853 effective Jan. 1, 2024. Alabama currently uses a minimum MMNA of $2,465, and this will increase effective July 1, 2024. We have no current projection of the new figure. North Dakota uses a MMNA of $2,550. We are unsure if this will change in 2024.

Minimum & Maximum Community Spouse Resource Allowance

The community spouse resource allowance (CSRA) is a spousal impoverishment rule that allows a non-applicant spouse to keep a greater amount of a couple’s assets to prevent spousal impoverishment. (All assets of a married couple are considered to be jointly owned). In 2023, the federally set minimum CSRA is $29,724 and the maximum CSRA is $148,620. CSRAs increase each year effective January 1. The amounts are determined based on the Consumer Price Index (CPI) and we project the minimum CSRA to be $30,824 and the maximum CSRA to be $154,119 for 2024 based on September’s CPI. All states fall into one of four groups 1) Those that use the federally set minimum and maximum CSRAs 2) Those that use minimum and maximum CSRAs, but the minimum differs from the federally set amount 3) Those that use only the federally set maximum CSRA 4) Those that use a standard figure between the federally set minimum and maximum CSRAs.

Group 1 – Projected to use $30,824 as the minimum CSRA and $154,119 as the maximum CSRA eff. Jan. 1, 2024. These states include the following: Alabama, Arizona, Arkansas, Delaware, District of Columbia, Idaho, Indiana, Iowa, Kansas, Kentucky, Maryland, Massachusetts, Michigan, Missouri, Montana, Nebraska, New Hampshire, New Jersey, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Dakota, Tennessee, Texas, Utah, Virginia, and West Virginia.

Group 2 – Projected to use $154,119 as the maximum CSRA eff. Jan. 1, 2024. These states use a minimum CSRA greater than the federally set minimum CSRA. We are unsure if any of these figures will change in 2024. We include 2023 minimum CSRAs in parenthesis following a state’s name. The following states fall under this group: Connecticut ($50,000), New Mexico ($31,290), New York ($74,820), Washington ($68,301), and Wisconsin ($50,000).

Group 3 – Projected to use $154,119 as the standard CSRA figure eff. Jan. 1, 2024. To be clear, these states do not use a minimum and maximum CSRA; they use only one standard figure. These states include Alaska, California, Colorado, Florida, Georgia, Hawaii, Louisiana, Maine, Minnesota, Mississippi, Nevada, Vermont, and Wyoming.

Group 4 – Illinois uses a standard CSRA of $120,780, and South Carolina uses a standard CSRA of $66,480. In Washington, a standard figure of $68,301 is used for HCBS Waivers. We do not know if these figures will change in 2024.

Home Equity Limits

The home equity limit is the limit on the current value of one’s home after subtracting any outstanding debt against it. In 2023, the federally set minimum home equity limit is $688,000 and the maximum home equity limit is $1,033,000. Home equity limits increase annually effective Jan. 1. The amounts are determined based on the Consumer Price Index (CPI) and we project them to be $713,000 and $1,071,000 for 2024 based on September’s CPI. All states fall into one of three groups 1) Those using the minimum home equity limit 2) Those using the maximum home equity limit and 3) Those using neither limits.

Group 1 – Projected to use $713,000 as the home equity limit in 2024 and includes the following states: Alabama, Alaska, Arizona, Arkansas, Delaware, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, West Virginia, and Wyoming.

Group 2 – Projected to use $1,071,000 as the home equity limit in 2024 and includes the following states: Colorado, Connecticut, District of Columbia, Hawaii, Massachusetts, New Jersey, New York, and Washington.

Group 3 – California does not have a home equity limit. Idaho, Maine, and Wisconsin all use a home equity limit between the minimum and maximum home equity limits set by the federal government. In 2023, they all have a home equity limit of $750,000. It is unknown if this will change in 2024.