Proposed Regulations, Gaps in Coverage for Homeless Youth

written by Lisa Stand
February 7, 2013

Some 15 percent of vulnerable homeless people were in foster care at some time in their lives, by at least one estimate. That’s what the 100,000 Homes Campaign finds in communities where the campaign is engaged in housing the most vulnerable people. This data point squares with what the Alliance has seen and what child welfare experts find. Youth aging out of foster care are more likely to have mental health problems, histories of trauma, and other potentially disabling conditions, compared to the same age group in the overall population.

So it is disconcerting that the the Centers for Medicare and Medicaid Services (CMS), which is responsible for implementing health care reform wants to limit Medicaid eligibility under one of the more promising Affordable Care Act provisions for youth. In short, starting in 2014 the ACA allows  former foster youth to remain in Medicaid until they are 26 years old. (Age of emancipation varies by state, from 18 to 21). For access to health care, this policy puts them on the same footing as others in their age group, for whom the ACA guarantees continued coverage under a parent’s private health insurance policy.

Under regulations proposed by the CMS, former foster youth could encounter trouble when they find themselves in need of service outside the state where the foster care ended. There is no certainty that Medicaid will continue to pay for their services in another state. Rather than making Medicaid coverage portable from state to state, CMS proposes to give states an option whether to cover people from another states.

The public comment period ends on February 21 for this and a number of other regulatory proposals regarding the implementation of the ACA. For suggestions on how to advocate for Medicaid portability for former foster youth, contact before COB February 18.

Among the most vulnerable youth, who reach adulthood with housing difficulties, they run the risk of becoming homeless frequently or for long periods of time. A growing body of research tells us that these homeless youth need services and supports along with access to housing where they can stabilize their lives and avoid the label “chronically homeless.”

Homeless youth are more likely to move around, pursuing jobs, education, and community. That means they are more likely to find themselves in other states. So CMS’s approach makes for significant service gaps when former foster youth are homeless.

Early success in supportive housing and in life may depend upon access to Medicaid supports, wherever they eventually access housing and community aid. And for the agencies reaching out to help them, the uncertainty of Medicaid coverage strains resources and hampers planning to address homelessness.

For former foster youth, Medicaid can be critical. Medicaid allows them to stay in treatment for physical and behavioral health conditions, funds medications that help them function, gives them the opportunity to visit a doctor and learn to manage their own health care as they juggle other practical demands of young adulthood. It was good news when the ACA granted those few extra years of Medicaid to former foster youth.