Each year, we project the Medicaid financial eligibility criteria in advance of the official release by the Centers for Medicare & Medicaid Services. CMS typically releases their numbers in mid-late November. However, given that the Medicaid planning and application process takes an average of 6 months, it is helpful for families and care providers to know next year’s financial eligibility criteria for Medicaid long-term care as soon as possible.
Summary
• Federal Benefit Rate (FBR) Income Limits – The majority of states use 300% of the FBR as their income limit. The FBR for 2025 was released on 10/10/24, and therefore, these figures are final and not projected. Effective Jan. 1, 2025, the FBR will be $967 / month for an individual and $1,450 / month for a couple. For states using 300% of the FBR as the income limit, a single applicant will be limited to $2,901 / month, and a married couple (with both spouses as applicants) will be limited to $5,802 / month.
• Federal Poverty Level (FPL) Income Limits – Some states use a percentage of the Federal Poverty Level (FPL) as their income limit. While we do not have projected FPL limits for 2025, these figures are generally released and effective mid-late January.
• Asset Limits – We project that most states will not change their asset limits for single or married applicants for 2025. California is the only state with no asset limit (effective 1/1/24). See current state-specific asset limits here.
• Minimum Monthly Maintenance Needs Allowance – For states that use a Min. MMNA, it will remain $2,555 / month until July 1, 2025. We currently have no projection for the new figure.
• Maximum Monthly Maintenance Needs Allowance – For states that use a Max. MMNA, we project it to be $3,948 / month effective Jan. 1, 2025.
• Minimum Community Spouse Resource Allowance – For states that use a Min. CSRA, it is projected to be $31,584 effective Jan. 1, 2025.
• Maximum Community Spouse Resource Allowance – For states that use a Max. CSRA, it is projected to be $157,920 effective Jan. 1, 2025.
• Home Equity Limits – For states that use $713,000 or $1,071,000 in 2024, the projected 2025 limits are $730,000 and $1,097,000, respectively. California has no home equity limit. ID, ME, and WI are addressed below.
Federal Benefit Rate Income Limits
The federal government caps the income limit for Institutional Medicaid and HCBS Waivers at 300% of the Federal Benefit Rate (FBR) for an individual. While states can set a lower monthly income limit, most states elect to use 300% of the FBR.
In 2024, the FBR is $943 / month for an individual, and 300% of the FBR for an individual is $2,829 / month. When both spouses of a married couple are applicants, the income of each spouse is limited to $2,829 / month ($5,658 / month as a couple). For married couples with just one spouse as an applicant, the applicant spouse is limited to $2,829 / month in income, and the non-applicant spouse’s income is disregarded. Furthermore, spousal impoverishment rules apply. For income, it is the monthly maintenance needs allowance that is relevant.
Effective Jan. 1, 2025, the FBR will be $967 / month for an individual, and 300% of the FBR for an individual will be $2,901 / month. When both spouses of a married couple are applicants, the income of each spouse will be limited to $2,901 / month ($5,802 / month as a couple). For married couples with just one spouse as an applicant, the applicant spouse will be limited to $2,901 / month in income. The non-applicant spouse’s income will be disregarded. Additionally, spousal impoverishment rules apply, and it is the monthly maintenance needs allowance that is relevant to the discussion of income.
State Groups
We break the states that use the FBR as income limits into two groups 1) Those that use 300% of the FBR 2) Exceptions.
Group 1 – States that use the income limits of $2,901 / month for an individual and $5,802 / month for a couple (with both spouses as applicants) effective Jan. 1, 2025: Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, District of Columbia, Florida, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Nevada, New Hampshire, New Jersey, New Mexico, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming. While most of these states use 300% of the FBR for their income limit for both Institutional Medicaid and HCBS Waivers, some states may use this figure for only one of these programs. This means that one of the programs may have an income limit based on the FBR while the other program has an income limit based on the Federal Poverty Level (FPL).
Group 2 – Delaware uses 250% of the FBR as their income limit. Effective Jan. 1, 2025, DE’s income limit will be $2,417.50 / month for an individual and $4,835 / month for a couple (with both spouses as applicants). Missouri uses a FBR percentage of approximately 175% for one of their programs, while another program is based on the FPL.
Federal Poverty Level Income Limits
A handful of states use a percentage of the Federal Poverty Level (FPL) as their income limits. Many of these states use 100% of the FPL, which in 2024, is $1,255 / month for a household of one and $1,703 / month for a household of two. For married couples, with just one spouse as an applicant, the applicant is limited to $1,255 / month in income. When both spouses of a married couple are applicants, the couples’ combined income is limited to $1,703 / month. For married couples with just one spouse as an applicant, the applicant spouse is limited to $1,255 / month in income and the non-applicant spouse’s income is disregarded. Furthermore, spousal impoverishment rules apply. For income, it is the monthly maintenance needs allowance that is relevant.
While we do not have projections for the 2025 FPLs, we expect the figures to be released mid-late January. When a state chooses to implement the new income limits is state-specific. Some states implement their new limits immediately, while others wait until later in the year. For example, California and Illinois change their income limits in April.
State Groups
We break the states that use the FPL as income limits into two groups 1) Those that use 100% of the FPL 2) Exceptions.
Group 1 – States that use 100% of the FPL: Illinois, Minnesota, Nebraska, North Carolina, and Utah. Hawaii also uses 100% of the FPL, but the FPL for Hawaii differs from the rest of the states. In 2024, 100% of the FPL in Hawaii is $1,443 / month for an individual.
Group 2 – States that use the FPL as their income limit, but do not use 100%. We include the FPL percentage that is used as the income limit in parenthesis following a state’s name. Missouri (85%), North Dakota (90%), California (138%), and New York (138%).
States may use the FPL income limit for both Institutional Medicaid and HCBS Waivers or for just one of the programs. This means that one of the programs may have an income limit based on the FPL while the other program has an income limit based on the Federal Benefit Rate (FBR).
Asset Limits
Medicaid asset limits typically do not change from year to year. When they do change, it is based on state rules rather than federal rules. In 2024, the asset limit in most states is $2,000 for an individual and $3,000 for a married couple (with both spouses as applicants). Note that some states use $4,000 as the asset limit for couples with both spouses as applicants ($2,000 / spouse). For married couples with just one spouse as an applicant, the applicant spouse is limited to $2,000 in assets, which the non-applicant spouse is allocated a larger amount of the couple’s assets. This is a spousal impoverishment rule called the community spouse resource allowance.
State Exceptions
There are a couple of significant exceptions to the asset limits mentioned above. In 2024, New York has an asset limit of $31,175 for an individual and $42,312 for a couple (with both spouses as applicants). Illinois’ raised their asset limit on 5/12/23 to $17,500 for an individual and $17,500 for a couple (with both spouses as applicants). It is anticipated that New York will increase their asset limit in 2025, but Illinois will not. California is yet another exception; the state eliminated their asset limit effective 1/1/24.
Min & Max Monthly Maintenance Needs Allowance
The monthly maintenance needs allowance (MMNA) allows an applicant spouse to transfer a portion of their income, or in some cases, all of their income, to their non-applicant spouse as a spousal income allowance to prevent spousal impoverishment. Currently, the federally set minimum MMNA is $2,555 and the maximum MMNA is $3,853.50. The minimum MMNA increases annually effective July 1, and we currently have no projection for this figure for July 1, 2025. The maximum MMNA increases each year effective Jan. 1. This amount is determined based on the Consumer Price Index (CPI) and we project it to be $3,948 for 2025 based on September’s CPI. All states fall into one of three groups 1) Those that use the federally set minimum and maximum MMNAs 2) Those that use only the maximum MMNA 3) Exceptions.
State Groups
Group 1 – States projected to use $2,555 as the minimum MMNA and $3,948 as the maximum MMNA effective Jan. 1, 2025: Arizona, Arkansas, Colorado, Connecticut, Delaware, District of Columbia, Florida, Idaho, Indiana, Kansas, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New Mexico, North Carolina, Ohio, Oregon, Pennsylvania, Rhode Island, South Dakota, Tennessee, Utah, Vermont, Virginia, Washington, and West Virginia (only applies to Institutional Medicaid).
Group 2 – States projected to use only the maximum MMNA of $3,948 effective Jan. 1, 2025: Alaska, California, District of Columbia, Georgia, Hawaii, Illinois, Iowa, Louisiana, Mississippi, Nevada, New York, Oklahoma, South Carolina, Texas, and Wyoming.
Group 3 – Wisconsin currently uses a minimum MMNA of $3,406.66 and a maximum MMNA of $3,853.50. We project the maximum MMNA to become $3,948 effective Jan. 1, 2025. Both Alabama and North Dakota currently use only the minimum MMNA of $2,555. While this will increase effective July 1, 2025, we have no current projection for the new figure.
Min & Max Community Spouse Resource Allowance
The community spouse resource allowance (CSRA) allows a non-applicant spouse to keep a greater amount of a couple’s assets to prevent spousal impoverishment. (All assets of a married couple are considered to be jointly owned). In 2024, the federally set minimum CSRA is $30,828 and the maximum CSRA is $154,140. CSRAs increase each year effective January 1. The amounts are determined based on the Consumer Price Index (CPI) and we project the minimum CSRA to be $31,584 and the maximum CSRA to be $157,920 for 2025 based on September’s CPI. All states fall into one of four groups 1) Those that use the federally set minimum and maximum CSRAs 2) Those that use minimum and maximum CSRAs, but the minimum differs from the federally set amount 3) Those that use only the federally set maximum CSRA 4) Those that use a standard figure between the federally set minimum and maximum CSRAs.
State Groups
Group 1 – States projected to use $31,584 as the minimum CSRA and $157,920 as the maximum CSRA effective Jan. 1, 2025: Alabama, Arizona, Arkansas, Delaware, District of Columbia, Idaho, Indiana, Iowa, Kansas, Kentucky, Maryland, Massachusetts, Michigan, Missouri, Montana, Nebraska, New Hampshire, New Jersey, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Dakota, Tennessee, Texas, Utah, Virginia, and West Virginia.
Group 2 – States projected to use $157,920 as the maximum CSRA effective Jan. 1, 2025. These states use a minimum CSRA greater than the federally set minimum CSRA. However, we anticipate New Mexico’s minimum CSRA will increase 1/1/25, as the state’s current figure is lower than the projected minimum CSRA for 2025. We also expect Washington’s figure to increase, but not until 7/1/25. We are unsure if any of the other figures will change. We include 2024 minimum CSRAs in parenthesis following a state’s name for states that fall under this group: Connecticut ($50,000), New Mexico ($31,290), New York ($74,820), Washington ($68,301), and Wisconsin ($50,000).
Group 3 – States projected to use $157,920 as the standard CSRA figure effective Jan. 1, 2025: Alaska, Colorado, Florida, Georgia, Hawaii, Louisiana, Maine, Minnesota, Mississippi, Nevada, Vermont, and Wyoming. To be clear, these states do not use a minimum and maximum CSRA; they use only one standard figure.
Group 4 – Illinois uses a standard CSRA of $129,084, and South Carolina uses a standard CSRA of $66,480. In Washington, a standard figure of $68,301 is used for HCBS Waivers. While we do not know if Illinois or South Carolina will change their figures in 2025, we do anticipate that Washington will increase their figure eff. 7/1/25.
Home Equity Limits
The home equity limit is the limit on the current value of one’s home after subtracting any outstanding debt against it. In 2024, the federally set minimum home equity limit is $713,000 and the maximum home equity limit is $1,071,000. Home equity limits increase annually effective Jan. 1. The amounts are determined based on the Consumer Price Index (CPI) and we project them to be $730,000 and $1,097,000 for 2025 based on September’s CPI. All states fall into one of three groups 1) Those using the minimum home equity limit 2) Those using the maximum home equity limit and 3) Those using neither limits.
State Groups
Group 1 – States projected to use $730,000 as the home equity limit in 2025: Alabama, Alaska, Arizona, Arkansas, Delaware, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, West Virginia, and Wyoming.
Group 2 – States projected to use $1,097,000 as the home equity limit in 2025: Colorado, Connecticut, District of Columbia, Hawaii, Massachusetts, New Jersey, New York, and Washington.
Group 3 – California does not have a home equity limit. Idaho, Maine, and Wisconsin all use a home equity limit between the minimum and maximum home equity limits set by the federal government. In 2024, they all have a home equity limit of $750,000. It is unknown if this will change in 2025.