DCFS Medical Coverage: Disregarding Income

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Policy Memo


  • Introduces Medicaid authorizations by Department of Children and Family Services (DCFS) to the Cash, SNAP and Medical policy manual;
  • Clarifies financial eligibility for children/youth receiving DCFS services (category 98); and
  • Clarifies non-financial eligibility for children/youth receiving DCFS services.

Financial eligibility is clarified for individuals receiving services for foster care, KinGap and adoption assistance through Department of Children and Family Services. Section 2001(b) of the Affordable Care Act (ACA) along with Sections 1902(a)(74) and 1902(gg) of the Social Security Act contain the Medicaid Maintenance of Effort (MOE) provision. The Medicaid MOE provision for children requires that eligibility standards, methods and procedures in effect March 23, 2010 remain in place until the end of federal fiscal year 2019 as a condition of continued federal funding.

For the Integrated Eligibility System (IES) phase 2 implementation, DCFS staff will be using the Application-Registration module to authorize and maintain their "category 98" cases. In anticipation of this change, DCFS eligibility policy will be added to the Cash, SNAP and Medical Manual. The DCFS policy will be kept in a separate section of the manual to minimize confusion with medical coverage for other children.

Note: This memorandum applies only to children/youth receiving medical coverage under a category 98 medical card.  DCFS staff are responsible for authorizing and maintaining medical coverage. DHS and HFS caseworkers may not process eligibility for these children.

Medical coverage for DCFS children/youth is through one of the five following categories:

  • Foster Care;
  • KinGap (subsidized guardianship);
  • Adoption Assistance;
  • Child of Ward (child of a ward-parent who is receiving foster care); and
  • Child/youth released by Department of Juvenile Justice (referred to as Department of Corrections or DOC cases) to a foster care home.

All children/youth served by DCFS receive a medical card through an interagency agreement between Healthcare and Family Services (HFS) and DCFS. However, for medical services to qualify for Federal Financial participation (FFP), DCFS staff must determine eligibility for Medicaid for these children.

Medicaid Determination

There is no application for DCFS medical benefits. Medical eligibility is added to MMIS through an administrative transaction via IPACS which will shift to IES when phase 2 is implemented.

DCFS staff determine Medicaid eligibility after taking a child into protective custody and redetermine eligibility for the child at least once a year. DCFS children/youth who are not Medicaid eligible receive state funded medical coverage. The eligibility requirements described below are used to determine whether the medical services are federally claimable.

Financial Eligibility

Effective immediately, all income and resources are disregarded for category 98 DCFS children/youth.  This policy does not apply to All Kids or Moms & Babies medical under Family Health Plans.

Non-Financial Eligibility 

To qualify for FFP, a DCFS child/youth must meet the following non-financial eligibility requirements:

  • Be an Illinois resident as described in PM 03-02-00;
  • Is under age 21 (applicable only to children/youth receiving DCFS services);
  • Has a valid Social Security Number or proof of application for a Social Security Number as described in PM 03-11-00;
  • Is a U.S. citizen or meets immigration (including lawful presence) requirements for non-citizens as described in PM 03-01-00; and
  • Does not live in a state or federal correctional facility.

 Legacy Terminology: Category 98

The category 98 description is used to clarify which types of DCFS cases are referenced in this memorandum and whose role it is to maintain them. DCFS eligibility staff who authorize category 98 medical cases in the legacy system are solely responsible for the authorization of the DCFS medical cases in IES phase 2. Eventually references to category 98 will be dropped from the cash, SNAP and medical manual.

Contact the HFS Bureau of Medical Eligibility Policy at 217-557-7158 if there are any questions.

[signed copy on file]

James T. Dimas

Secretary, Illinois Department of Human Services

Felicia F. Norwood

Director, Illinois Department of HealthCare and Family Services