Adoptive Parents Face Problems in Renewing Their Children's Medicaid Benefits

An adoptive parent, whose son was receiving Title IV-E Adoption Assistance, recently contacted me concerning problems with renewing his eligibility for Medicaid. From its origins, children participating in the Title IV-E Adoption Assistance program have been automatically (categorically) eligible for Medicaid. (See 42 United States Code (U.S.C.) 673 (b) Question 1, Section 8.2B.8 of the federal Child Welfare Policy Manual, Ohio Administrative Code rule OAC 5180:2-49-19 (A)).

For these children, renewal of eligibility for Medicaid coverage can be verified by the aptly named DCF 01451-B “Title IV-E Adoption Assistance Annual Assurance of Legal Responsibility, School Attendance and Continued Eligibility for Medicaid Coverage“ form. Traditionally this has been administered by the county children services agency or unit.

But, instead of simply confirming her child’s continuing eligibility for IV-E adoption assistance through the children services agency, the local county Job and Family Services (JFS) agency requested information related to financial need as the basis for verifying her child’s Medicaid eligibility. The agency sent the adoptive parent a form letter inquiring about the nature of her relationship with the child’s adoptive father, and asked both adoptive parents for pay stubs and other income related information. The form also requested tax related information. The letter obviously did not recognize that IV-E Adoption Assistance confers eligibility for Medicaid and the need-based criteria for regular Medicaid did not apply.

The adoptive parent also told me that her situation was not an isolated one and was not confined to her county alone. Other adoptive parents in her online support group from a number of other Ohio counties had received similar letters. She said that in some cases, the adoptive child’s Medicaid coverage had been suspended because the parents had not submitted the requested information by a particular date. The application of incorrect criteria to verify Medicaid eligibility for children with IV-E Adoption Assistance is clearly a problem the State must address.

How Widespread is This Problem?

Officials at the state’s Department of Children and Youth (DCY) informed me that they were aware of that county JFS agency’s applying the wrong criteria to verify IV-E Adoption Assistance children’s continuing eligibility for Medicaid. So far, however, I have not been able to identify the origins of the problem or the proposed remedy. I don’t know why county JFS agencies are conducting continuing Medicaid eligibility reviews for IV-E Adoption Assistance children. And, I don’t know how widespread this practice is.

The adoptive parent who contacted me about the letter requesting incorrect documentation for her son’s continuing Medicaid eligibility, subsequently received a puzzling, follow up e-mail from the county JFS agency. The e-mail acknowledged the parent’s refusal to submit need-based income documentation to confirm her son’s eligibility for Medicaid. However, the agency representative failed to respond to the parent’s correct insistence that her child was automatically eligible for Medicaid. While declining to address the question of a IV-E Adoption Assistance child’s Medicaid status, the agency representative told the adoptive parent that the form letters requesting income and other e -based verification would continue, writing,

I have received your request for no further verification requests; however, you will still receive a renewal form and verification requests once a year, regardless of refusal to cooperate. This is something that automated and we do not have any control over that part of the process.

I don’t know what to make of all this. Please let me know if a county JFS agency has requested need or income based documentation as a requirement for verifying your child’s Medicaid eligibility. Please identify the county and agency. Please let me know if your child’s Medicaid eligibility has been discontinued. Hopefully, we can obtain some sense of the scope of the problem. I will try to pass on the information you provide to state officials.