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Comment: Medicaid Residency Requirements Rulemaking

Policy Director Sharra Greer, on behalf of Children’s Law Center, submitted comments to the District’s Department of Health Care Finance (DHCF) regarding residency criteria for Medicaid for certain out-of-District individuals. The purpose of the rulemaking is to define when an individual, who is temporarily absent from the District, may satisfy residency criteria for Medicaid and identifies the conditions under which otherwise eligible foster care individuals placed outside of the District may satisfy eligibility criteria for Medicaid.

In her comments, Sharra provided many recommendations, including:

  • Removing the proposed 90-day limit upon the allowed duration of “temporary absence;”
  • Revising the good-cause exception for “school attendance” to include students up through the age of 22; and
  • Consulting with the individual’s Guardian ad Litem and other relevant parties in making the best-interests determination contemplated in the proposed rulemaking, among others.


Click below to read her full comments.