​The purpose of this memo is to inform AIDS Drug Assistance Program (ADAP) and Pre-Exposure Prophylaxis Assistance Program (PrEP-AP) Enrollment Workers (EW) about policy updates regarding Medi-Cal eligibility.

Ages 26 through 49 Adult Expansion

Beginning January 1, 2024, a new law in California will allow adults ages 26 through 49 to qualify for full-scope modified adjusted gross income (MAGI) Medi-Cal, regardless of immigration status. All other Medi-Cal eligibility rules, including income limits, still apply.

This expansion, called the “Ages 26 through 49 Adult Expansion," is modeled after the “Young Adult Expansion," which provided full scope Medi-Cal to young adults 19 through 25, and the “Older Adult Expansion," which provided full scope Medi-Cal to adults 50 years of age or older. 

Medi-Cal will automatically transfer current restricted scope Medi-Cal beneficiaries ages 26 through 49 to full scope coverage.

Elimination of Asset Test

Beginning January 1, 2024, the asset test for Non-Modified Adjusted Gross Income (Non-MAGI) Medi-Cal programs will be eliminated. Non-MAGI programs – sometimes referred to as Traditional Medi-Cal – generally provide health care for seniors 65+, people with disabilities, individuals who are in nursing facilities, as well as some other specialty groups.

Individuals who may be affected include Medi-Cal applicants who were previously determined ineligible for Non-MAGI Medi-Cal programs prior to January 1, 2024, due to countable assets over the current asset limit of $130,000 per individual or $65,000 for each additional household member. This change also impacts all Non-MAGI beneficiaries who, before January 2024, were required to report and prove their assets were below the limits.

Current Medi-Cal beneficiaries who are enrolled in coverage will remain unaffected and will no longer be subject to an asset limit. These changes apply to all Non-MAGI programs requiring an asset test.

ADAP and PrEP-AP Policy Update

All new or re-enrolling clients aged 18 and over, with income under 138% of the FPL, must be referred to apply for Medi-Cal at the time of their initial enrollment or re-enrollment as adults ages 26 through 49 may now qualify for Medi-Cal, regardless of immigration status. Clients who decline to apply to Medi-Cal due to public charge concerns should be strongly encouraged to apply to Medi-Cal by Enrollment Workers as outlined in the Health Coverage tab in the ADAP Enrollment System (AES).  Clients should be reminded that Medi-Cal offers full comprehensive health coverage which can protect clients from high costs of illness or injury compared to ADAP's medication formulary coverage.

In addition, all clients with unearned income and who are over age 65, disabled, or were previously ineligible for Non-MAGI Medi-Cal due to asset limits, should be referred to apply to Medi-Cal. Unearned income are funds received from sources for which no paid work activity is performed. This includes, but is not limited to: disability benefits such as Social Security Disability Insurance (SSDI), Supplemental Security Income (SSI), short-term disability insurance, and long-term disability insurance; Veterans Affairs (VA) benefits, etc.

Screening for Medi-Cal

EWs will screen all ADAP and PrEP-AP applicants for potential Medi-Cal eligibility at the time of their initial ADAP/PrEP-AP enrollment or re-enrollment. ADAP and PrEP-AP will not send a separate outreach to clients who are potentially eligible for Medi-Cal.

If an ADAP/PrEP-AP client is found to be enrolled in full scope Medi-Cal during secondary review, the ADAP/PrEP-AP advisor will place the client on a Temporary Access Period (TAP) and reach out to the assigned EW to confirm that the client has been successfully enrolled in Medi-Cal prior to disenrolling the client from ADAP/PrEP-AP.

The U.S. Department of Homeland Security and U.S. Citizenship and Immigration Services does not consider receipt of health, food, and housing benefits as part of the public charge determination. Therefore, using Medi-Cal benefits (except for residential nursing home or mental health institution care) will not hurt an individual's immigration status. To learn more about public charge, please review Understanding the Public Charge Evaluation on the EW SharePoint (PDF)​.

Scenari​os

Please review the scenarios below.

Scenario 1: A new undocumented individual, ages 26–​49 , with income below 138% federal poverty level (FPL), applies for ADAP/PrEP-AP.

• The EW must refer the indivdiual to Medi-Cal. While awaiting Medi-Cal determination, the new client is placed on a Temporary Access Period (TAP) and receives ADAP/PrEP-AP benefits. If the determination exceeds the 30-day TAP, please submit a Medi-Cal Eligibility Exception Request (MEER).

Scenario 2: An existing undocumented client, ages 26–​​49, with income below 138% FPL, re-enrolls in ADAP/PrEP-AP.

• The EW must refer the client to Medi-Cal. While awaiting Medi-Cal determination, the existing client is placed on a TAP and continues receiving ADAP/PrEP-AP benefits. If the determination exceeds the 30-day TAP, please submit a MEER.

Scenario 3: A new client ages 26–​​49, legally present, with income below 138% of the FPL, applies for ADAP/PrEP-AP.

• The EW must refer the client to Medi-Cal. While awaiting Medi-Cal determination, the client is placed on a TAP and receives ADAP/PrEP-AP benefits. If the determination exceeds the 30-day TAP, please submit a MEER.

Scenario 4: An existing client ages 26–​​​​​​49, legally present, with income below 138% of the FPL, re-enrolls in ADAP/PrEP-AP.

• The EW must refer the client to Medi-Cal. While awaiting Medi-Cal determination, the existing client is placed on a TAP and continues receiving ADAP/PrEP-AP benefits. If the determination exceeds the 30-day TAP, please submit a MEER.

Scenario 5: A new or existing undocumented client is enrolling in ADAP/PrEP-AP is potentially eligible for Medi-Cal, but refuses to apply or enroll in Medi-Cal due to concerns about public charge.

• State-funded programs such as Medi-Cal are not subject to public charge rules. EWs should refer to the “AIDS Drug Assistance Program Answers to Frequently Asked Questions on the 2019 U.S. Citizenship and Immigration Services' Final Public Charge Rule" (English (PDF))/Spanish (PDF)​) document to address client concerns.

The EW will screen the client for comprehensive health coverage in the AES. The EW will need to enter a case note indicating the client refuses to apply for Medi-Cal. Below are two examples:

Option 1: Client has been screened for comprehensive health coverage and refuses to apply to Medi-Cal or other coverage.

Option 2: Legal counsel advises client not to a​​pply to Medi-Cal.

Scenario 6: A new or existing client, age 65 and older, household size of one, with unearned income and $150,000 in their bank account applies for or reenrolls into ADAP/PrEP-AP.

• The EW must refer the client to Non-MAGI Medi-Cal. While awaiting Medi-Cal determination, the client is placed on a TAP and receives ADAP/PrEP-AP benefits.

Scenario 7: A new or existing client, age 65 and older, household size of two, with unearned income and $200,000 in their bank account applies for or reenrolls into ADAP/PrEP-AP.

• The EW must refer the client to Non-MAGI Medi-Cal. While awaiting Medi-Cal determination, the client is placed on a TAP and receives ADAP/PrEP-AP benefits.

Department of Healthcare Services - Medi-Cal Resources

For more information regarding the upcoming change to Medi-Cal, please review​​
Medi-Cal's Age 26–​​​49 Adult Expansion Eligibility and Enrollment Plan (PDF).

If you have any questions regarding the information provided in this memo, please contact your OA Advisor​.

Thank you,