Medicaid aged/disabled income limit is 75% of poverty where the state standard is the SSI rate (MT, CO, IA, LA, OH, OR, WA) #9733

Summary

gov.hhs.medicaid.eligibility.categories.senior_or_disabled.income.limit gives Montana and 22 other states an income limit of 0.75 of the federal poverty guideline for the "optional senior or disabled pathway". Montana's own rules set that limit at the SSI payment rate in dollars ($994 a month for an individual and $1,491 for a couple in 2026), and Montana has not elected the poverty-level group. Colorado, Iowa, Louisiana, Ohio, Oregon and Washington set the same standard in their own rules.

The 0.75 is the SSI rate written as a share of the one-person guideline in the parameter's source (KFF). Encoding it as a share of the guideline has two effects:

• A band of income gets Medicaid without SSI. In 2026 the SSI rate is $11,928 a year and 0.75 of the guideline is $11,970. An aged person with countable income between them gets no SSI but is Medicaid-eligible in the model.
• The couple limit is too low. The file applies 0.75 to the two-person guideline ($16,230 in 2026). The SSI couple rate is $17,892.

Found while reviewing PolicyEngine/microcosm-dynamics#506, where an illustrative Montana household lands in the band.

Reproduction on main (20ccd5ac7c, 2.18.4)

A single person aged 70 in Montana, 2026, no assets, Social Security only. Countable income is Social Security less the $240 general exclusion.

The last row is $996 a month of countable income, $2 over Montana's $994 standard.

The old limit against the SSI rate, by year (annual dollars, from the model's own parameters on 1 January):

ssi is defined only for people who take up SSI, so the pathway also decides Medicaid for people who are eligible for SSI and do not take it up. For couples in that position the limit is $1,155 to $1,662 a year too low.

What the parameter's cited source says

Both KFF reports the parameter cites, retrieved 2026-10-01:

• 2018 survey, Appendix Table 1. Montana's cell under "Seniors and People with Disabilities up to 100% FPL" is blank. 21 states are checked.
• 2018 survey, Appendix Table 2. Montana: $750 | $1,125 | $20 | 74% | $2,000 | $3,000. The note reads: "States generally must provide Medicaid to SSI beneficiaries (equivalent to 74% FPL in 2018) and have the option to extend eligibility for seniors and people with disabilities up to 100% FPL."
• June 2024 appendix, Table 1. Montana: No under "Higher Income Limits for SSI or Seniors and People with Disabilities up to 100% FPL".
• June 2024 appendix, Table 2. Montana: 943 | 1415 | 20 | 20 | 75 | 1634 State | 2000 | 3000. The note reads: "Eligibility limits are for an individual. The maximum federal Supplemental Security Income (SSI) benefit is equivalent to 75% FPL."

$750 / $1,125 and $943 / $1,415 are the SSI rates for 2018 and 2024. The 23 states KFF marks No in 2024 are exactly the 23 states at 0.75 in the file.

What Montana's own sources say

• DPHHS Medicaid manual, ABD 008, "Table of Standards-Categorically Needy Income" (effective 01/01/2026). "Individual living in the community … $994", "Couple living in the community … $1491". "The Categorically Needy Income Standards are the benefit amounts paid by the Social Security Administration to Supplemental Security Income (SSI) cash recipients." "Applicants with monthly countable income equal to or less than these income standards are categorically needy Medicaid eligible. This means that they are considered qualified for SSI money payments if they choose to apply." "Applicants with monthly countable income in excess of these income standards are not categorically needy eligible. However, these applicants may be eligible for medically needy coverage." https://dphhs.mt.gov/assets/hcsd/mamanual/ABD008.pdf
• DPHHS Medicaid manual, ABD 200, "Groups Covered-Overview" (effective July 01, 2016). Lists eleven categorically needy groups. Group 4 is "Aged, blind and disabled individuals with countable income at or below the categorically needy income standard". There is no poverty-level aged or disabled group. https://dphhs.mt.gov/assets/hcsd/mamanual/ABD200July012016.pdf
• Montana Medicaid State Plan, Attachment 3.1-F page 7 (TN 24-0002, approved 05/03/2024, effective 07/01/2024). Row 7, "Aged, Blind or Disabled Individuals Eligible for but Not Receiving Cash" (§435.210 and §435.230), is marked. Row 15, "Poverty Level Aged or Disabled" (1902(a)(10)(A)(ii)(X) and 1902(m)(1)), has no mark and "N/A" in the notes column. https://www.medicaid.gov/sites/default/files/2024-05/MT-24-0002.pdf (PDF page 10)

So Montana covers aged, blind and disabled people who do not receive SSI through the group in 42 CFR 435.210, at the SSI rate, with an inclusive test.

One secondary source disagrees: MACPAC MACStats Exhibit 37 lists Montana in its "Poverty level" column at 74 (2022), 75 (2024) and 74 (2025). The figure equals its "SSI recipients" column each year, so it tracks the SSI rate and not a fixed share of poverty.

The other states at 0.75

I checked each state's own rules. Six set the same standard as Montana:

Louisiana is the one state of the 23 that has elected the poverty-level group, and its plan pegs the level to the SSI rate for an individual or a couple. An emergency rule terminated this "Provisional Medicaid" program effective July 1, 2018, but a second emergency rule rescinded that termination effective June 16, 2018 (Louisiana Register, July 20, 2018), and LDH's eligibility charts issued January 7, 2026 still list Provisional Medicaid.

The remaining sixteen states at 0.75, and the five states with higher values, need different fixes and are in #9734.

Proposed fix

Add a by-state boolean, senior_or_disabled.income.limit.uses_ssi_federal_benefit_rate, true for Colorado, Iowa, Louisiana, Montana, Ohio, Oregon and Washington. Where it is true, medicaid_optional_senior_or_disabled_income_limit returns twelve times the SSI individual or couple rate from gov.ssa.ssi.amount. Remove those states' 0.75 entries from the two share-of-poverty files.

Not changed: who the pathway covers, the $20 disregard, or the inclusive test. Oregon's rule says "below", so a person exactly at the standard is eligible in the model and not under the rule.

Sources

All retrieved 2026-10-01.

• KFF 2018 survey appendix tables: https://www.kff.org/report-section/medicaid-financial-eligibility-for-seniors-and-people-with-disabilities-findings-from-a-50-state-survey-appendix-tables/
• KFF June 2024 appendix: https://www.kff.org/report-section/medicaid-eligibility-and-enrollment-policies-for-seniors-and-people-with-disabilities-non-magi-during-the-unwinding-appendix/
• 42 CFR 435.210: https://www.ecfr.gov/current/title-42/section-435.210
• 42 U.S.C. 1396a(a)(10)(A)(ii)(I), (X) and (m): https://www.govinfo.gov/link/uscode/42/1396a
• SSA, SSI Federal Payment Amounts: https://www.ssa.gov/oact/cola/SSIamts.html
• MACPAC MACStats Exhibit 37 (2024): https://www.macpac.gov/wp-content/uploads/2024/12/EXHIBIT-37.-Medicaid-Income-Eligibility-Levels-as-a-Percentage-of-the-FPL-for-Individuals-Age-65-and-Older-and-Persons-with-Disabilities-2024-2.pdf
• Colorado: https://www.law.cornell.edu/regulations/colorado/10-CCR-2505-10-8.100_v2
• Iowa: https://www.law.cornell.edu/regulations/iowa/Iowa-Admin-Code-r-441-75-1
• Louisiana: https://www.law.cornell.edu/regulations/louisiana/La-Admin-Code-tit-50-SS-III-2305 and https://www.medicaid.gov/State-resource-center/Medicaid-State-Plan-Amendments/Downloads/LA/LA-14-04.pdf
• Ohio: https://codes.ohio.gov/ohio-administrative-code/rule-5160:1-3-02.4 and https://codes.ohio.gov/ohio-administrative-code/rule-5160:1-3-03.5
• Oregon: https://ch461rules.odhs.oregon.gov/rules/461-155-0250.pdf
• Washington: https://app.leg.wa.gov/wac/default.aspx?cite=182-512-0010 and https://app.leg.wa.gov/wac/default.aspx?cite=182-512-0100