Medicaid Renewals Playbook

Wage matching

Description

Wage matching is the process in which an person’s income is compared against external data sources for verification. This process includes using the reasonable compatibility test, and incorporates any reasonable compatibility threshold the state is using.

While the regulations and guidance are fairly clear around reasonable compatibility, states may be taking an unnecessarily strict stance. The process should be:

Within in this process, there are flexibilities. Some states may choose to ignore the stored income completely; this is a reasonable implementation choice because the stored income will always be below the threshold anyway (since they qualified previously).

However, some states may be taking overly-restrictive strategies like:

What this looks like

The following signs may indicate a wage match issue:

Potential solutions

The first step in diagnosing a wage match issue is to ask the state to describe in detail how their wage match process is implemented. Ask the following questions:

Describe to the state how best-in-class income verification processes do wage matching in the simplest way possible. Question and challenge any logic that strays outside of these bounds. Cite the October CMS guidance indicating best practices, and the regulations for definitions of technical terms.

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