Some "dual eligible" beneficiaries (people who have Medicare and Medicaid) are entitled to receive reimbursement of their Medicare Part B premiums from New York State through the Medicare Insurance Premium Payment Program (MIPP).   The Part B premium is $148.50 in 2021.   MIPP is for some groups who are either not eligible for --  or who are not yet enrolled in--  the Medicare Savings Program (MSP), which is the main program that pays the Medicare Part B premium for low-income people.   Some people are not eligible for an MSP even though they have full Medicaid with no spend down. This is because they are in a special Medicaid eligibility category -- discussed below -- with Medicaid income limits that are actually HIGHER than the MSP income limits.   MIPP reimburses them for their Part B premium because they  have “full Medicaid” (no spend down) but are ineligible for MSP because their income is above the MSP SLIMB level (120% of the Federal Poverty Level (FPL). Even if their income is under the QI-1 MSP level (135% FPL), someone cannot have both QI-1 and Medicaid). Instead, these consumers can have their Part B premium reimbursed through the MIPP program.

In this article:

1. Five Groups who are Eligible for MIPP
2. MIPP vs MSPs- How are They Different?
3. MIPP Enrollment 
4. Health Insurance Premium Payment Program (HIPP)
5. MIPP Guidance and Directives

A.  Five Groups who are Eligible for MIPP

The MIPP program was established because the State determined that those who have full Medicaid and Medicare Part B should be reimbursed for their Part B premium, even if they do not qualify for MSP, because Medicare is considered cost effective third party health insurance, and because consumers must enroll in Medicare as a condition of eligibility for Medicaid (See 89 ADM 7). There are generally five groups of dual-eligible consumers that are eligible for MIPP:

1.  Those Enrolled in the Medicaid Buy in for Working People with Disabilities (MBI-WPD):

• MBI-WPD is a program for people under 65 who are disabled and working.  They have two big financial advantages:

  1. They can be eligible for Medicaid at much higher income limits. The 2022 MBI WPD net income limit is $2,832 per month (250% FPL), compared to the regular disabled/aged/blind (DAB) Medicaid income limit of $934 per month. (Both of those limits are net income, after applicable income disregards). See this article for current income limits.

  2.  Earned income has a special "disregard" as a work incentive.  Subtract $65 from monthly gross earned income, then deduct half of the remainder.  So less than half of gross monthly income counts against the higher MBI-WPD income level.   See links in this article for a more detailed explanation.

Therefore, many MBI WPD consumers have incomes higher than what MSP normally allows, but still have full Medicaid with no spend down. Those consumers can qualify for MIPP and have their Part B premiums reimbursed. See  HIPP/MIPP DOH Training Notebook-- Health Insurance Training Center 2017 (Excerpt of relevant pages)(pp. 19, 25 of PDF).  Here is an example.

• Sam is age 50 and has Medicare and MBI-WPD. She gets $1500/mo gross from Social Security Disability and also makes $400/month through work activity. 

•     $ 167.50  -- EARNED INCOME - Because she is disabled, the DAB earned income disregard applies: 

$400 - $65 = $335.     Her countable earned income is 1/2 of $335 = $167.50

• +  $1500.00 -- UNEARNED INCOME from Social Security Disability 

• = $1,667.50 --TOTAL income. This is above the SLIMB limit of $1,359 (2022) but she can still qualify for MIPP.

2.  Parent/Caretaker Relatives with MAGI-like Budgeting - Including Medicare Beneficiaries:

• Consumers who fall into the DAB category (Age 65+/Disabled/Blind)  and would otherwise be budgeted with non-MAGI rules can opt to use Affordable Care Act MAGI rules if they are the parent/caretaker of a child under age 18 or under age 19 and in school full time. This is referred to as “MAGI-like budgeting.” Under MAGI rules income can be up to 138% of the FPL—again, higher than the limit for DAB budgeting, which is equivalent to only 83% FPL.  

•  MAGI-like consumers can be enrolled in either MSP or MIPP, depending on if their income is higher or lower than 120% of the FPL. If their income is under 120% FPL, they are eligible for MSP as a SLIMB.  If income is above 120% FPL, then they can enroll in MIPP.  (See GIS 18 MA/001 - 2018 Medicaid Managed Care Transition for Enrollees Gaining Medicare, #4).

3.  Medicaid Recipients whose Medicaid is Handled on the NYS of Health Marketplace and are newly enrolled in Medicare and Not Yet in a Medicare Savings Program

• When a consumer has Medicaid through the New York State of Health (NYSoH) Marketplace and then enrolls in Medicare when she turns age 65 or because she received Social Security Disability for 24 months, her Medicaid case is normally** transferred to the local department of social services (LDSS)(HRA in NYC) to be rebudgeted under non-MAGI budgeting.   During the transition process, she should be reimbursed for the Part B premiums via MIPP.  However, the transition time can vary based on age.

  • AGE 65+  Those who enroll in Medicare at age 65+ will receive a letter from their local district asking them to "renew" Medicaid through their  local district.  See 2014 LCM-02. The Medicaid case takes about four months to be rebudgeted and approved by the LDSS.  The consumer is entitled to MIPP payments for at least three months during the transition.  Once the case is with the LDSS she should automatically be re-evaluated for MSP, even if the LDSS determines the consumer is not eligible for Medicaid because of excess income or assets.  08 OHIP/ADM-4. 

  • Consumers UNDER 65 who receive Medicare due to disability status are entitled to keep MAGI Medicaid through NYSoH for up to 12 months (also known as continuous coverage, See NY Social Services Law 366, subd. 4(c). These consumers should receive MIPP payments for as long as their cases remain with NYSoH and throughout the transition to the LDSS.   NOTE during COVID-19 emergency their case may  remain with NYSoH for more than 12 months.  See here. 

    • EXAMPLE:  Sam, age 60,  was last authorized for Medicaid on the Marketplace in June 2020.  He became enrolled in Medicare based on disability in August 2020, and started receiving Social Security in the same month (he won a hearing approving Social Security disability benefits retroactively, after first being denied disability).  Even though his Social Security is too high, he can keep Medicaid for 12 months beginning June 2020.  

      • Sam has to pay for his Part B premium - it is deducted from his Social Security check.  He may call the Marketplace and request a refund.  This will continue until the end of his 12 months of continuous MAGI Medicaid eligibility.  He will be reimbursed regardless of whether he is in a Medicaid managed care plan. See  GIS 18 MA/001 Medicaid Managed Care Transition for Enrollees Gaining Medicare   (PDF) When that ends, he will renew Medicaid and apply for MSP with his local district.

  • See GIS 18 MA/001 - 2018 Medicaid Managed Care Transition for Enrollees Gaining Medicare, #4 for an explanation of this process.  That directive also clarified that reimbursement of the Part B premium will be made regardless of whether the individual is still in a Medicaid managed care (MMC) plan.

• Note: During the COVID-19 emergency, those who have Medicaid through the NYSOH marketplace and enroll in Medicare should NOT have their cases transitioned to the LDSS. They should keep the same MAGI budgeting and automatically receive MIPP payments. See GIS 20 MA/04 or this article on COVID eligibility changes

4.  Those with Special Budgeting after Losing SSI (DAC, Pickle, 1619b)

Disabled Adult Child (DAC): 

• Special budgeting is available to those who are 18+ and lose SSI because they begin receiving Disabled Adult Child (DAC) benefits (or receive an increase in the amount of their benefit). Consumer must have become disabled or blind before age 22 to receive the benefit. If the new DAC benefit amount was disregarded and the consumer would otherwise be eligible for SSI, they can keep Medicaid eligibility with NO SPEND DOWN. See this article.

• Consumers may have income higher than MSP limits, but keep full Medicaid with no spend down. Therefore, they are eligible for payment of their Part B premiums. See page 96 of the Medicaid Reference Guide (Categorical Factors). If their income is lower than the MSP SLIMB threshold, they can be added to MSP. If higher than the threshold, they can be reimbursed via MIPP. 

• See also 95-ADM-11: Medical Assistance Eligibility for Disabled Adult Children, Section C (pg 8):

  • "Individuals who are certified as DAC MA eligible and who are in receipt of Medicare Part B are eligible to have MA pay the appropriate Medicare premium on their behalf through the Buy-In system."

Pickle & 1619B:

• Similarly, consumers with full Medicaid under the Pickle Amendment or 1619B are also eligible to have their premiums reimbursed under the buy-in program. See page 80 of the Medicaid Reference Guide (Categorical Factors).

5.  When the Part B Premium Reduces Countable Income to Below the Medicaid Limit

• Since the Part B premium can be used as a deduction from gross income, it may reduce someone's countable income to below the Medicaid limit. The consumer should be paid the difference to bring her up to the Medicaid level ($904/month in 2021). They will only be reimbursed for the difference between their countable income and $904, not necessarily the full amount of the premium.
• See GIS 02-MA-019: Reimbursement of Health Insurance Premiums

B.  MIPP vs. MSPs - How are They Different?

MIPP and MSP are similar in that they both pay for the Medicare Part B premium, but there are some key differences:

• MIPP structures the payments as reimbursement -- beneficiaries must continue to pay their premium (via a monthly deduction from their Social Security check or quarterly billing, if they do not receive Social Security) and then are reimbursed via check.
  • In contrast, MSP enrollees are not charged for their premium.  Their Social Security check usually increases because the Part B premium is no longer withheld from their check.

• MIPP  only provides reimbursement for Part B.  It does not have any of the other benefits MSPs can provide, such as:

  • Special Enrollment Period to enroll in Medicare Part B  outside of the usual time periods

  • Part D Extra Help automatic eligibility
  • Balance billing protection (for QMBs). and 
  • Eligibility for the Part A Buy-In that QMB beneficiaries may use to enroll in Part A, even if they lack enough quarters of coverage for premium-free Part A
• A consumer cannot have MIPP without also having Medicaid, whereas MSP enrollees can have MSP only. Of the above benefits, Medicaid also provides Part D Extra Help automatic eligibility. 

C. MIPP Enrollment 

• There is no application process for MIPP because consumers should be screened and enrolled automatically (00 OMM/ADM-7).

• Either the state or the LDSS is responsible for screening & distributing MIPP payments, depending on where the Medicaid case is held and administered (14 /2014 LCM-02 Section V).  

• If a consumer is eligible for MIPP and is not receiving it, they should contact whichever agency holds their case and request enrollment. Unfortunately, since there is no formal process for applying, it may require some advocacy.

  • If Medicaid case is at New York State of Health they should call 1-855-355-5777.  Consumers will likely have to ask for a supervisor in order to find someone familiar with MIPP.

  • If Medicaid case is with HRA in New York City, they should email mipp@hra.nyc.gov. 

  • If Medicaid case is with other local districts in NYS, call your local county DSS. 

  • See more here about consumers who have Medicaid on NYSofHealth who then enroll in Medicare - how they access MIPP.

• Once enrolled, it make take a few months for payments to begin.

• Payments will be made in the form of checks from the Computer Sciences Corporation (CSC), the fiscal agent for the New York State Medicaid program. The check itself comes attached to a remittance notice from Medicaid Management Information Systems (MMIS). Unfortunately, the notice is not consumer-friendly and may be confusing. See attached sample for what to look for.

D.  Health Insurance Premium Payment Program (HIPP)

• HIPP is a sister program to MIPP and will reimburse consumers for private third party health insurance when deemed “cost effective.”  Note that the cost-effective requirement does not apply to MIPP.
• Directives:

  • GIS 15 MA/004 - Clarification of Reimbursement Policy Regarding Third Party Health Insurance Premiums and Copayments

  • GIS 15 MA/014 - Health Insurance Premium Payment (HIPP) Program Changes

  • GIS 13 MA/012 Changes to the Criteria Used for Determining The Cost Benefit of Paying Health Insurance Premiums

E.  MIPP Guidance and Directives:

• 89 ADM 7 Implementation of the Medicare Catastrophic Coverage Act of 1988 Relating to the Medicaid Payment of Medicare Premiums, Deductibles and Coinsurance
• 02 MA019 - Reimbursement of Health Insurance Premium 
  • Definition of "cost effective" reimbursement
• GIS 18 MA/001 - 2018 Medicaid Managed Care Transition for Enrollees Gaining Medicare
  • MIPP eligibility for 1) New Medicare Beneficiaries and 2) Medicare Beneficiaries with "MAGI-like" budgeting.
• 00 OMM/ADM-7 Medicare Premium Payment Program
  • At each recertification, districts have a responsibility to screen consumers for all available Medicare Premium Payment Programs (MPPP), even if not explicitly requested by the consumer. Therefore, all consumers should be screened for MIPP & enrolled if eligible. 
• SSA POMS: HI 00815.001 State Buy In Program
• 14 /2014 LCM-02 - Medicaid Recipients Transferred at Renewal from New York State of Health to Local Departments of Social Services
  • MIPP eligibility and processes during the transition from NYSoH to LDSS
• GIS 20 MA/04 - Coronavirus (COVID-19) – Medicaid Eligibility Processes During Emergency Period
  • MIPP and HIPP will be automatically extended for any Medicaid cases extended during the Public Health Emergency
• NYC HRA MAP Office of Procedures-- The Journal 2015: Eligibility Guidance
• HIPP/MIPP DOH Training Notebook-- Health Insurance Training Center 2017 (Excerpt of relevant pages)
  • Full document can be found here
  • Accompanying PPT can be found here
  • Additional documents can be found here: http://www.caiglobal.co/caiglobal.co/tchip/. Enter each folder to find documents. To go back, choose "parent directory"
• HIICAP Notebook- Medicaid Chapter (see pg 53)
• Fair Hearing #8107966Q. Client had MAGI-like budgeting for 5 years and was not screened for or enrolled into MIPP during that time. Requested hearing for retroactive MIPP enrollment. Decision found MIPP enrollment cannot be retroactive but appellant could be reimbursed for Medicare premiums paid in error.