SMD Letter on TANF - 12/04/2000  
December 4, 2000  
Dear State Medicaid Director:  
During the course of our review of State Medicaid programs nationwide, we identified several 
areas where State Medicaid and Temporary Assistance to Needy Families eligibility and enrollment 
processes presented barriers to applicants and recipients or resulted in erroneous Medicaid denials 
and terminations. One area that we have identified is cases that are terminated when families move 
from one county to another county within their State of residence.  
We have learned that, in some States, counties terminate Medicaid when a family moves from 
one county to another within the State and require the family to reapply in the new county of 
residence. These terminations are not permitted under Federal law. Section 1902(a)(1) of the 
Social Security Act requires that a State plan for Medicaid must provide that it shall be in effect 
in all political subdivisions of the State. This means that, in the absence of a Section 1115 waiver, 
the State plan must be in effect statewide and all counties within the State must comply with the 
State plan provisions.  
In a county-administered Medicaid program, when a family moves within the State, the State and 
the counties are responsible for transferring the case record from the old county of residence to the 
new county of residence so that Medicaid can continue without interruption. The State cannot 
require the family to reapply for Medicaid or comply with a Medicaid redetermination solely 
based upon a move to a new county.  
We recognize that often a move connotes a change in circumstances, for example, a parent obtains 
a new job, and the county may need to reevaluate eligibility in light of these changes. If there is a 
basis for conducting a redetermination due to changed circumstances (beyond just a move to a new 
county) that might affect eligibility, the county must first perform an ex parte redetermination to 
determine whether Medicaid eligibility continues. If the State does not have sufficient information 
based on the ex parte review it must request information from the family that is directly related to 
the changed circumstances. If a family does not comply with the request after a reasonable amount 
of time, Medicaid can be terminated since the family has a responsibility to cooperate during a 
redetermination.  
We request that you review your official policies and procedures regarding Medicaid denials and 
terminations and redeterminations to ensure compliance with Federal requirements at 42 CFR 
435.916 and 435.930. Also, since it is possible that counties may be terminating Medicaid when 
families move  
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within the State even though your State's official policies and procedures comply with 
Federal requirements, we are requesting that you review your counties' actions to verify 
that:     no county in your State terminates Medicaid when families move out of that county to 
another county within the State;  
  no county requires families who move within your State to reapply for Medicaid in their new 
county of residence;  
  when families move, counties transfer case records in a timely manner and Medicaid is 
continued uninterrupted; and,  
  all written policies and procedures comply with Federal requirements for redetermining 
Medicaid eligibility.  
 
If you find that your State is not in compliance with these Federal rules, please contact your HCFA 
regional office immediately to establish a plan for coming into compliance within the next 90 days. 
Your regional office can also answer any questions you may have. Thank you for your attention to 
this matter as part of our ongoing partnership to ensure that eligible individuals and families receive 
the Medicaid services to which they are entitled.  
Sincerely,  
/s/  
Timothy W. 
Westmoreland 
Director  
cc: HCFA Regional Administrators HCFA Associate Regional Administrators for Medicaid and 
State Operations Lee Partridge, Director, Health Policy Unit - American Public Human Services 
Association Joy Wilson, Director, Health Committee - National Conference of State Legislatures 
Matt Salo, Director of Health Legislation - National Governors' Association Brent Ewig, 
Association of State and Territorial Health Officials  
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