Medical Expense Deduction: Issues and Best Practices Ty Jones AASD Conference September 23, 2013 1 Our Plan for Today 1.Overview of Medical Expense Deduction Policy 2.Advocates’ Perspective 3.Lessons from South Dakota 4. Q & A Why Talk About this Deduction? • The excess medical deduction plays an important role in targeting food assistance to households with high out of pocket medical costs. • The excess medical expense deduction is one of the most underutilized of the SNAP income deductions. 3 Share of Elderly or Disabled Households Claiming Medical Expense Deduction SNAP Households Claiming Medical Expense Deduction = 996,594 SNAP Households with Elderly or Disabled Members =12,256,213 8% 92% 4 Wide Variation Across States in Share of Eligible Claiming the Deduction 25% Share of households with elderly/disabled claiming the medical deduction 22.7% 20% 15% 11.6% 10.2% 10% 5% 1.4% 0% U.S. Total Source: USDA Household Characteristics Data, 2011 Kansas Colorado South Dakota Why Aren’t More Households Claiming the Deduction? • State policies & procedures • Participant and advocate lack of awareness 6 Types of Medical Expenses that Qualify Allowed Expenses Medical and dental services, Hospital bills, Prescriptions, Medical equipment, Transportation to & from medical services/treatment • Attendant or home health aide • Medical insurance premiums or Medicare supplemental insurance policies • • • • • Disallowed Expenses • Expenses incurred that include the cost of a special diet, • Costs of health and accident policies, • Medical expenses covered by vendor payments, and • Medical expenses covered by reimbursements. 7 State Applications Can Help Households Claim the Deduction 8 Application Design Can Hinder the Deduction Use 9 Verification Policy Can Be a Barrier • Federal regulations require: –The amount of any medical expenses deductible shall be verified prior to initial certification. –Other factors such as the allowable services provided or the eligibility of the person incurring the cost, shall be verified, if questionable. 10 Paper Verification is Not the Only Way • Clients and advocates identify verification as a key barrier to eligible households claiming medical expenses. • States and workers often only accept paper documentation. – No specific document can be required. – Other forms of verification could work also, collateral contacts. – State agencies have a duty to assist with verification 11 Strategies to Ensure Eligible Households Claim Medical Expenses States are assessing the medical expense take-up rates and reviewing their policy and procedures. – Require verification only at initial certification. – Lift unnecessary restrictions on allowable medical expenses – Standard Medical Expense Deduction waiver – Outreach to senior and disabled individuals and advocacy groups 12 Standardized Medical Deduction Waiver • A waiver from USDA started in 2005 • Currently 14 State agencies are operating with these waivers • Designed to: – Test the impact of increasing access to SNAP by the elderly and disabled – Increase administrative efficiency – Reduce the risk of quality control errors. 13 Standard Medical Deduction Waiver in 14 States What’s A Successful Standard Medical Deduction? • Increases use of medical expense deduction amongst eligible households, directing more food assistance to vulnerable seniors and people with disabilities. • Households with extreme medical expenses continue to claim actuals. • Offset to rest of SNAP population is minimum. • Increases administrative efficiency. 15 Caveat Emptor: Standard Medical Deduction Waivers Aren’t A Silver Bullet • Cost-Neutrality Determination • Offset Dilemma • Gathering Data • Constraints on Staff Time • Risks to households with high medical costs 16 What is Cost Neutrality? Cost of Standard Medical Deduction Federal Government Cost Standard Medical Deduction Offset Increased Benefits to Participants (SUA, income) Benefits to Participants 17 Possible Downsides To Standard Medical Deduction Cost of Standard Medical Deduction Federal Government Cost Standard Medical Deduction Increased Benefits to Participants 18 So What’s a State To Do? • Gather Data – How many claim the deduction now? • Assess Barriers • Set Clear Policy and Expectations – Verifications – Assess impacts on households with high medical costs • Review Training • Engage Advocates and Assisters 20