Professionals and advocates have a great opportunity in 2024 to highlight the various changes to the Medicare Part D Extra Help and Limited Income Newly Eligible Transition programs—also known as LIS and LINET—in their outreach to potential LIS enrollees.
What are LIS and LINET and how have they recently changed?
Lower-income Medicare Part D beneficiaries may be eligible for the Part D Extra Help program, also known as the Low-Income Subsidy (LIS). Thanks to the Inflation Reduction Act, every person who qualifies for Extra Help beginning in January 2024 receives the full subsidy. NCOA provides these resources regarding the program:
- An introduction to the Part D Extra Help program
- A guide to coverage and eligibility
- A visualization tool that maps how many letters are sent to each state, county, and ZIP code, so counselors can better target outreach in those areas
- A study of Part D Extra Help enrollment rates
The Limited Income Newly Eligible Transition (LINET) program provides low-income Part D beneficiaries with subsidies until their LIS is effective. Beginning in 2024, thanks to the Inflation Reduction Act, the LINET program has become permanent.
The Centers for Medicare and Medicaid Services is directing advocates and professionals to direct potential LIS enrollees to call 1-800-MEDICARE to see if they qualify.
What do we know about the sizes of the enrolled vs. not enrolled populations of LIS-eligible beneficiaries?
Before the January 2024 expansion of the full LIS benefit to individuals whose incomes are at 150% of the federal poverty level (FPL), the most recent data on the LIS population showed that 90% of people eligible for the full LIS subsidy in September 2023 were not enrolled in the program. Individuals enrolled in the partial Part D Extra Help subsidy were relatively low in number when compared to those enrolled in the full subsidy. For every two people enrolled in the partial subsidy in September 2023, five were enrolled in the full subsidy.
When comparing recent Extra Help enrollment and eligibility data, it’s clear that the number of full- and partial-subsidy enrollees increased in the late-2010s, but declined between 2020 and 2022.
A couple of COVID-19 pandemic-related factors may have decreased the number of enrollees from 2020 and 2022. Among the possible explanations could be that the pandemic took the lives of a disproportionate number of the lowest-income older adults.1, 2 Many full-subsidy LIS enrollees are automatically enrolled, for instance, due to their pre-existing Medicaid entitlement.3 The lowest-income older adults automatically enrolled into LIS were affected not only by the COVID-19 pandemic, but by some of the operational challenges states, the federal government, and the aging network (e.g. community-based organizations) faced such as those related to enrolling individuals on a mostly virtual basis.
The opposite was true for the population of eligible-but-not-enrolled population in that automatic enrollment due to eligibility in another low-income program did not apply; this population grew because of the administrative challenges of manually enrolling individuals during this trying time; and this population was less likely to die from COVID-19.4
What are the characteristics of the LIS population?
Using data on the demographic characteristics of the LIS population made public for the first time in June 2023, it’s likely that full-subsidy LIS enrollees in 2021 were more likely to be under the age of 65 than partial-LIS recipients and Medicare beneficiaries not eligible for LIS.
Full-subsidy LIS enrollees were in 2021 more likely to be younger and receive Medicare (and likely other low-income assistance programs such as Medicaid) due to their having a disability or having very limited incomes and assets. On the other hand, Medicare beneficiaries deemed ineligible for Extra Help due to their having incomes or assets that are too high are more likely to be between the ages of 65 and 75.
The 2021 Extra Help demographic data provided strong evidence showing that full-subsidy enrollees are more likely to be Black non-Hispanic, Hispanic, or belong to some other race/ethnicity than Medicare beneficiaries who do not qualify for LIS.
LIS beneficiaries of color are more likely to qualify for the subsidy due to a toxic intersection of factors such as a lack of access to quality health care, a lack of economic opportunities, a greater likelihood of having a chronic disease and/or disability, low-income status, and experiencing prejudice throughout a lifetime (through individuals and systems).5, 6 Given the greater likelihood for LIS eligibility, professionals may wish to work with community partners to provide outreach and enrollment to communities of color.
The 2021 data also highlight the point that full-LIS-subsidy enrollees are more likely to have one or more disabilities than their Medicare counterparts who do not qualify for LIS (see Diagram 5). Also, individuals who received the full subsidy were more likely to have two or more disabilities than those who received the partial one.
In 2021, 42,000 LIS enrollees had two or more disabilities. Given how disability status qualifies an individual for Medicaid or Medicare (for those under the age of 65), it’s possible that individuals with a disability are more likely to automatically receive the Part D subsidy. Also, having multiple disabilities might mean that Medicaid entitlement (and thus auto-enrollment into the full LIS program) is more likely. Also, an individual with multiple disabilities may qualify for LIS based on their having a lower income, which can be driven by living with such things as high medical costs or the challenges of working a full-time job.7 Furthermore, the data concerning the eligible-but-not-enrolled, full subsidy population reveals that there are opportunities to increase outreach to enroll individuals with disabilities into Extra Help. In 2021, there were about 22,000 individuals with one disability enrolled in the full subsidy, but 26,000 individuals with one disability who could receive the full subsidy were not enrolled.
NCOA’s push for better LIS demographic data
On Feb. 7, 2023, the National Council on Aging (NCOA) and the PAN Foundation sent a letter to the Centers for Medicare and Medicaid Services (CMS) highlighting the need for better demographic data on the Part D Extra Help population.
We asked for demographic data on the population receiving the full LIS subsidy—the partial subsidy that existed until 2024—as well as the population of LIS eligibles not enrolled in the program. On March 10, 2023, NCOA and the PAN Foundation met with CMS leaders to highlight the importance of this data. During the first week of June that year, CMS released the demographic data we had been requesting.
Sources
1. Betzaida Tejada-Vera, M.S., and Ellen A. Kramarow, Ph.D. COVID-19 Mortality in Adults Aged 65 and Over: United States, 2020. NCHS Data Brief. Number 446. October 2022. Found on the internet at https://www.cdc.gov/nchs/data/databriefs/db446.pdf.
2. Centers for Disease Control and Prevention. COVID-19 Risks and Information for Older Adults. Found on the internet at https://www.cdc.gov/aging/covid19/index.html
3. Centers for Medicare and Medicaid Services. Auto-Enrollment Notice. Jan.11, 2024. Found on the internet at https://www.medicare.gov/basics/forms-publications-mailings/mailings/help-with-costs/extra-help-auto-enrollment-future-coverage.
4. Poor People’s Campaign. A Poor People’s Pandemic Report: Mapping the Intersections of Poverty, Race and COVID-19. April 2022. Found on the internet at https://www.poorpeoplescampaign.org/wp-content/uploads/2022/04/PoorPeoplesPandemicReport-Executive-Summary-April2022.pdf
5. In an April 2022 study, NCOA found that “people of color are more likely to experience higher treatment costs and greater lost wages due to chronic disease.” The NCOA authors found that the costliest chronic diseases for older adults were Alzheimer’s/Dementia at $48,701 per person; cancer at $30,028 per person; and diabetes with $20,137 per person. Susan Silberman. “The Inequities in the Cost of Chronic Disease: Why It Matters for Older Adults.” NCOA. 21 April 2022. 11 January 2024. https://www.ncoa.org/article/the-inequities-in-the-cost-of-chronic-disease-why-it-matters-for-older-adults.
6. Justin M. Feldman and Mary T. Bassett. Variation in COVID-19 Mortality in the US by Race and Ethnicity and Educational Attainment. Nov. 23, 2021. JAMA Network Open. Found on the internet at https://jamanetwork.com/journals/jamanetworkopen/article-abstract/2786466
7. Aislinn Kinsella. Yale researchers investigate the pandemic’s impact on people with disabilities. Feb. 11, 2022. 11 January 2024. Found on the internet at https://yaledailynews.com/blog/2022/02/11/yale-researchers-investigate-the-pandemics-impact-on-people-with-disabilities/
