Low-Income Subsidy Redeterminations

Recipients of the Part D low-income subsidy (or extra help) are being reevaluated to determine their eligibility for the subsidy. Both CMS and SSA conduct redeterminations. The processes being used by SSA require beneficiaries to take action.

• CMS Redetermination Process: CMS reviews all beneficiaries who were deemed eligible for “extra help” because they receive Medicaid (including a Medicare Savings Program) or Supplemental Security Income (SSI) benefits. This process is called “redeeming.”
  
• SSA Redetermination Processes: SSA conducts two types of redeterminations—initial and cyclical. Both processes pertain only to beneficiaries who applied for extra help through the SSA. 
  
  • Initial: SSA selects a group of beneficiaries from all those who applied and were found eligible for extra help during the past year. SSA selects beneficiaries whom they believe have experienced a change in their circumstances that may have affected their eligibility for extra help. These beneficiaries should receive a redetermination form in the mail in early September. The form, “Social Security Administration Review of Your Eligibility for Extra Help,” must be completed and returned within 30 days of receipt, even if nothing has changed. If a beneficiary does not complete and return the form, eligibility for extra help may be terminated, effective January 1.
    
  • Cyclical: Each year SSA selects a random group of extra help recipients for redetermination. These beneficiaries should receive a redetermination form in the mail in early September. (The form is the same form sent to those selected for the initial redetermination.) Beneficiaries must respond to the form within 30 days of receipt, even if nothing has changed. If a beneficiary does not complete and return the form, eligibility for extra help may be terminated, effective January 1.

In addition to conducting initial and cyclical redeterminations, the SSA continues to conduct subsidy changing event (SCE) redeterminations. Subsidy changing events, including marriage, divorce, separation, annulment, and death of spouse, must be reported immediately. The SSA will send a special SCE redetermination form. Beneficiaries are required to complete and submit the form within 90 days of receipt. Beneficiaries who do not respond will no longer receive extra help; for those that do respond, their extra help status will change the month after SSA receives the completed form. More information about SCEs is available from the SSA Program Operations Manual System (POMS).

Beneficiaries may appeal a reduction or termination of their subsidy. According to the POMS, “It may be more advantageous to the individual to file an appeal than to file a new application. This is because the individual may lose one or more months of Part D subsidy by filing a new application. An appeal would preserve the retroactivity of the subsidy while a new application would not" (20 CFR 418.3605 - 418.3680). Beneficiaries should use the SSA appeals form.

More information on the Social Security Administration’s updated redetermination processes and procedures can be found in the SSA Program Operations Manual System (POMS). SSA has also prepared a 1-page sheet, “Review of Your Eligibility for Extra Help With Medicare Prescription Drug Plan Costs: Some Things You Should Know,” in both English and Spanish.

The National Senior Citizens Law Center has also created a guide to the Low-Income Subsidy redeeming and redeterminations processes.