The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 provides
that SSI payments may only begin as of the first day of the month following the later
of (1) the date the application is filed or (2) the date the individual becomes eligible
for such benefits (SI 00601.009). As a result of this policy, cash SSI payments are not paid for the first month
of SSI eligibility; the first month of SSI eligibility is the E02 month. Since no
SSI cash payments are paid for the E02 month, no Medicaid certification is made to
THHSC by SSA.
However, THHSC decided to provide coverage for the SSI E02 month using a systems default
(as explained in SI DAL01730.009D, step 1.) to define the E02 month rather than always using the E02 as determined
by SSA. Please note that this is a THHSC agency decision and does not affect or change
the SSI program policy or procedures.
THHSC adapted the “3-month-prior-to-SSI-application” Medicaid coverage policy to provide
coverage for the E02 month. The THHSC system has defaults which start the “3-month-prior”
period with the month immediately prior to the first SSI cash payment month. This
results in Medicaid coverage provided by THHSC for the E02 month in most cases, but
it may also result in Medicaid coverage for a month of SSI ineligibility. For example,
an individual applied in January and the PSY for January, February, and March are
E02, N01, and C01, respectively. The THHSC system default considers February to be
the E02 month because it is the month immediately before the first C01 month, and
Medicaid is provided by THHSC for a month of SSI ineligibility (i.e., N01). The application
with THHSC for the “3-month prior” Medicaid coverage would be for the remaining two
months of December and January.
Since Medicaid coverage will automatically be provided for new SSI recipients for
the “month immediately preceding the SSI payment month”, THHSC will issue a notice
inviting recipients with unpaid medical expenses to file for Medicaid coverage for
the remaining two months of the “3-month prior” period.
The option for Medicaid for “3-month prior to the date of SSI application” did not
change for denied SSI applicants. A notice will be sent advising denied applicants
of the option to apply for this Medicaid coverage. Since the SSI claim was denied
for benefits, there is no SSI cash payment or E02 month to be considered.
SSA should never certify Medicaid coverage for any month of SSI ineligibility (e.g.,
N04), the E02 month, the 3-month prior period, or a month of non-SSI cash payment
(e.g., E01, N01) unless the non-cash month is a Section 1619(b) month.