Introduction

Medicaid, including long-term care Medicaid through which Home and Community Based Services (HCBS) and nursing facility care is provided, is for persons with limited financial means. Seniors (65+ years old) and persons with disabilities qualify for Medicaid via non-MAGI (Modified Adjusted Gross Income) eligibility pathways. These pathways generally have income and asset limits, and for long-term care, a functional need requirement.

There is only one mandatory non-MAGI pathway to Medicaid eligibility. It is the Supplemental Security Income (SSI) Pathway. The other pathways to Medicaid eligibility are optional, and therefore, not all states offer all pathways. Relevant to seniors, these pathways are the Federal Poverty Level Pathway, Special Income Rule Pathway, and the Medically Needy Pathway. All states offer at least one optional pathway to Medicaid eligibility. The eligibility criteria varies based on the pathway, and therefore, if one is ineligible for Medicaid via one pathway, they may be eligible via another.

Note: Not all eligibility pathways are relevant for all types of Medicaid. For example, the Special Income Rule is limited to persons who require Nursing Home Medicaid or long-term services and supports via Home and Community Based Services (HCBS) Medicaid Waivers.

The SSI Pathway to Medicaid Eligibility

The Supplemental Security Income (SSI) Pathway is the only mandatory (required) pathway to Medicaid eligibility for seniors and persons with disabilities. Every state is required to offer this pathway, which extends Medicaid coverage to persons who receive SSI.

SSI is a federal benefit program administered by the Social Security Administration (SSA) that provides monthly cash assistance for persons who are aged (65+ years old), blind, or disabled and have limited income and assets. The income limit is equivalent to the SSI maximum benefit rate. In 2025, this is $967 / month for an individual and $1,450 / month for a couple. The asset limit is $2,000 for an individual and $3,000 for a couple.

1634 States
In US states known as “1634 States”, persons who are determined eligible for SSI are automatically approved for Medicaid. In other words, there is no separate application for Medicaid determination. These states include the following: Alabama, Arizona, Arkansas, California, Colorado, Delaware, District of Columbia, Florida, Georgia, Indiana, Iowa, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Mississippi, Montana, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Vermont, Washington, West Virginia, Wisconsin, and Wyoming.

SSI Criteria States
SSI Criteria States use the same eligibility criteria for Medicaid as with SSI, but approval for Medicaid is not automatic. Instead, one must fill out an application for Medicaid separately from SSI. These states are Alaska, Idaho, Kansas, Nebraska, Nevada, Oklahoma, Oregon, and Utah.

209(b) States
In states known as “209(b) States”, at least one of the Medicaid eligibility criterion is more restrictive than current SSI eligibility criteria (but no more restrictive than when the SSI program began in 1972). These states are Connecticut, Hawaii, Illinois, Minnesota, Missouri, New Hampshire, North Dakota, Virginia.

The Federal Poverty Level Pathway to Medicaid Eligibility

The Federal Poverty Level Pathway is an optional pathway to Medicaid eligibility. It allows states to extend eligibility to seniors and persons with disabilities who have income over SSI’s limit by setting an income limit up to 100% of Federal Poverty Level (FPL). The FPL is released each year in January, and in 2025, it is $1,304.17 / month for an individual and $1,762.50 / month for a couple. States may use these exact figures or they may round them up or down.

Approximately half of the states utilize this pathway to Medicaid eligibility. Many of these states follow, along with the percentage of the FPL used as the income limit in parenthesis: Arizona (100%), Arkansas (80%), District of Columbia (100%), Florida (88%), Hawaii (100% – specific to HI), Illinois (100%), Indiana (100%), Maine (100%), Massachusetts (100%), Michigan (100%), Minnesota (100%), Missouri (85%), Nebraska (100%), New Jersey (100%), North Carolina (100%), Oklahoma (100%), Rhode Island (100%), South Carolina (100%), Utah (100%), and Virginia (80%). Furthermore, California and New York are exceptions and set the income limit at 138% of the FPL.

Generally speaking, the asset limit is $2,000 for an individual and $3,000 for a couple. However exceptions exist. California has no asset limit (eff. 1/1/24), and in 2025, Illinois has an asset limit of $17,500 for an individual, as well as a couple, and New York’s asset limit is $32,396 for an individual and $43,781 for a couple.

The Medically Needy Pathway to Medicaid Eligibility

The Medically Needy Pathway to Medicaid eligibility is an optional pathway for seniors who have high medical expenses. Via this pathway, a senior deducts medical expenses and long-term care costs, like doctor visits and nursing home care, from their income until they reach their state’s medically needy income limit. States that utilize this pathway set a budget period (i.e., 1 month, 3 months, 6 months) during which one must “spend down” their income to qualify for Medicaid benefits. Therefore, one may be eligible for Medicaid during some budget periods, but not others, based on their medical expenses / long-term care costs.

The following states permit the Medically Needy Pathway to eligibility for seniors: Arkansas, California, Connecticut, District of Columbia, Florida, Georgia, Hawaii, Illinois, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan Minnesota, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New York, North Carolina, North Dakota, Pennsylvania, Rhode Island, Utah, Vermont, Virginia, Washington, West Virginia, and Wisconsin.

Medically needy income limits (MNILs) are state-specific and tend to be very low. For instance, in 2025, the MNIL in Florida is $180 / month for an individual and $241 / month for a couple, and in Kentucky, it is $235 / month for an individual and $291 / month for a couple. Some states, like Illinois and Michigan, use a higher limit, which is set at 100% of the Federal Poverty Level ($1,304.17 / month for an individual and $1,762.50 / month for a couple). Furthermore, MNILs do not change annually in all the states, and in fact, some states have utilized the same limit for many years. For instance, Iowa’s MNIL of $483 / month (for individuals and couples) has remained the same since 1996, and Montana’s limit of $525 / month (for individuals and couples) has been the same since 2001.

The medically needy asset limit is generally $2,000 for an individual and $3,000 for a couple. Exceptions exist. California eliminated their asset limit eff. 1/1/24, and in 2025, Illinois has an asset limit of $17,500 (for individuals and couples) and New York has an asset limit of $32,396 for an individual and $43,781 for a couple.

Note: While states may use the Medically Needy Pathway for seniors to qualify for Regular Medicaid, Home and Community Based Services via a Medicaid Waiver, and Nursing Home Medicaid, some states use it only for Regular Medicaid. Furthermore, Missouri is unusual in that the state offers this pathway for Regular Medicaid and Nursing Home Medicaid, but not for HCBS Medicaid Waivers.

Learn more about the Medically Needy Pathway to Medicaid eligibility and see state-specific medically needy income and asset limits.

The Special Income Rule Pathway to Medicaid Eligibility

The Special Income Rule Pathway to Medicaid eligibility allows persons who require a Nursing Facility Level of Care (NFLOC) to qualify for long-term care Medicaid with income up to 300% of the SSI Federal Benefit Rate. States utilize this pathway for seniors and persons with disabilities to qualify for Institutional Medicaid (i.e., nursing home care), as well as Home and Community Based Services (HCBS) via a Medicaid Waiver.

In 2025, the income limit for this pathway to eligibility is $2,901 / month for an individual. Generally speaking, the asset limit is $2,000. For couples with only one spouse as an applicant, the applicant spouse is limited to $2,901 / month. The income of the non-applicant spouse is disregarded and is not factored into their spouse’s income eligibility. That said, the non-applicant spouse could be entitled to a Monthly Maintenance Needs Allowance from their applicant spouse. Assets, however, are considered jointly owned. The applicant spouse is generally limited to $2,000 in assets and the non-applicant spouse is entitled to a greater portion of the couple’s assets as a Community Spouse Resource Allowance.

The following states utilize the Special Income Rule as a pathway to Medicaid eligibility: Alabama, Alaska, Arizona, Arkansas, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Idaho, Indiana, Iowa, 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. Note: While Delaware utilizes the Special Income Rule, the state sets the income limit at 250% of the FBR. In 2025, this is $2,417.50 / month. Additionally, not all of the states utilize this pathway for both Nursing Home Medicaid and Home and Community Based Services via Medicaid Waivers. As an example, Massachusetts utilizes this pathway only for HCBS.

What if One Still Does Not Qualify?

Some states permit seniors who require Medicaid-funded nursing home care or Home and Community Based Services via Medicaid Waivers and have income over 300% of the SSI Federal Benefit Rate ($2,901 / month in 2025) to become income-eligible by depositing “excess” income into a Qualified Income Trust (QIT). Also called a Miller Trust, income deposited into this type of trust is not counted towards income eligibility.

The following states permit QITs: Alabama, Alaska, Arizona, Arkansas, Colorado, Delaware, Florida, Georgia, Idaho, Indiana, Iowa, Kentucky, Mississippi, Missouri (limited to HCBS Waivers), Nevada, New Jersey, New Mexico, Ohio, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee, Texas, and Wyoming. Note: Delaware is an exception and allows persons with income over 250% of the SSI FBR to become income-eligible by utilizing a Miller Trust.

For persons with “excess” assets, or in other words, assets over Medicaid’s asset limit, there are a variety of planning strategies available. For instance, one may “spend down” assets by paying for long-term care, making home upgrades (i.e., heating, plumbing), or purchasing an Irrevocable Funeral Trust (IFT). Seniors can also purchase a Medicaid Compliant Annuity, turning assets into a stream of income, or deposit assets into a Medicaid Asset Protection Trust. Some of these strategies violate Medicaid’s Look-Back Period, and therefore, should only be implemented with careful consideration and planning. Medicaid Planners can be extremely instrumental in assisting persons over the income and / or asset limits and ensuring strategies are implemented without violating Medicaid eligibility. Find a Certified Medicaid Planner.