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Permanently reinstating 3-mo retro: What you can do & MassHealth updates

1.      Two opportunities to regain 3-months retroactive MassHealth coverage for all MassHealth members


MassHealth's 1115 Demonstration has waived Medicaid’s 3-months retroactive coverage requirement for people under 65  since 1997 and allowed  them only 10 days retro.  (Three months retro  has been temporarily reinstated during the COVID pandemic, and MassHealth is proposing to make it permanent for pregnant women and children). The extension of the 1115 Demo for another 5 years and pending legislation create two chances to make the case for restoring 3 months retroactive coverage for all MassHealth members.

MassHealth 1115 Demonstration Comments Due Today Sept 20, 2021 by 5 pm

Today at 5 pm is the deadline to submit written comments on MassHealth’s proposed extension of its 1115 Demonstration.MassHealth is proposing to permanently reinstate 3 months retro for pregnant women and children, but not for other adults under 65. Written comments can be submitted by email until 5 pm today. Written comments may be delivered by email or mail. By email, please send comments to and include “Comments on 1115 Demonstration Extension Request” in the subject line. Details here.

Sept 28, 2021  Joint Health Care Finance Committee Hearing Public Hearing 

Next week the HCF Committee will be hearing several MassHealth bills including bills to reinstate 3-months retroactive coverage called “An Act to restore the effective date of MassHealth coverage for new applicants.” H. 3873 and S. 737 (Lead Sponsors Rep. Carolyn C. Dykema and Sen. Joseph Boncore). Written testimony may be submitted to the Joint Committee on Health Care Financing via E-mail to the House and Senate Chairs at and as well as the Committee Director at timothy.oneill@mahouse.govDetails here.

Why should 3 months retroactive coverage be restored?

·         Retroactive coverage is required by the Medicaid Act but waived in MassHealth for people under 65. It pays medical bills for people who were eligible for Medicaid/MassHealth but did not apply for assistance until after they received care. There are many reasons this may happen: People mistakenly think they are still insured at the time they received care but are not; the sudden nature of their illness prevented completing an application, or they didn’t know about available MassHealth coverage. MassHealth allows only a 10 day retroactive window to complete an application.

·         Without 3 months retroactive coverage, more low-income MassHealth members are burdened by medical debt, more participating MassHealth health care providers go unpaid, and more federal dollars are left on the table.  

·         Medical debt is a significant problem for low income families in Massachusetts. The 2019 Massachusetts Health Insurance shows that in 2019, 18% of families income-eligible for MassHealth reported problems paying medical bills and these rates were higher for people who were Black or Hispanic (20% and 19.6%).

·         In 1997, eliminating retroactive coverage for people under 65 was offset by raising income limits to 133% of poverty, eliminating an asset test, and providing coverage to some single adults under 65. But under the ACA all these features are now part of the Medicaid expansion and reimbursed with a 90% federal match. Massachusetts is now in company with the reddest of red states in using an 1115 waiver to deny 3-months retroactive coverage to people under 65.


  • Add your own examples of clients/patients who benefited from 3-months retro during its temporary restoration during the COVID pandemic or who missed out earlier and were harmed.



2.      Other MassHealth Updates

MassHealth is continuing to accept verfification by self-attestation until further notice. Earlier MassHealth announced it would end the more liberal use of self-attestation to verify income, assets, residence and disability on Sept 15, 2021. BUT it has now announced it will continue to accept self-attestation until further notice.

MassHealth will not count any of the three IRS stimulus payments as assets during PHE. Earlier guidance suggested that the asset exclusion would only be for 12 months after receipt of the payments, but on Aug 13, 2021 MassHealth clarified the exclusion will last at least as long as the federal public health emergency. This will exclude the 1st round payment of $1200 which many received in April 2020. People completing applications or renewals asking for current bank statement to verify assets can still use self-attestation to verify amounts of all unspent stimulus payments.