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DPSS ePolicy

MEDI-CAL

Sneede v. Kizer

Release Date
01/13/2025

Section Heading

Purpose

  • To convert existing policy to the new webpage – No content changes
  • To revise existing policy and/or form(s)
     

What changed?

  1. Effective January 1, 2024, assets are no longer counted to determine eligibility under Non-Modified Adjusted Gross Income (Non-MAGI) Medi-Cal.  Any references to assets/property were removed from this document.
  2. Included the updated Sneede v. Kizer Prorated Maintenance Need Income Levels (MNIL) Standard Chart.
  3. Included the updated versions of the MC 175-4 (10/23), Sneede v. Kizer Mini-Budget Units and MC 176 W.1 (01/24), Sneede v. Kizer Mini-Budget Units Share of Cost Determinations forms.
  4. All references to the LEADER Replacement System (LRS) have been changed to the California Statewide Automated Welfare System (CalSAWS).
     

Policy

Sneede v. Kizer is a method of determining Medi-Cal eligibility and Share-of-Cost (SOC) for a household containing a Sneede class member.  The methodology used in determining eligibility restricts financial responsibility to spouse-for-spouse and parent-for-child.  It also requires an equal allocation of income.  This means that the income of a parent or spouse may only be used in determining Medi-Cal eligibility and SOC for themselves, their spouse, and their natural and/or adopted child(ren).  

An entire Medi-Cal Family Budget Unit (MFBU) may initially be determined ineligible to Non-MAGI Medi-Cal with a SOC.  However, once Sneede rules are applied, some family members may have no SOC while others have a SOC. 

Sneede rules do not apply to MAGI Medi-Cal cases nor Non-MAGI Medi-Cal cases consisting of one person (this is because there is no one for the person to allocate income to or from).

Sneede v. Kizer Criteria

To be eligible for a Sneede evaluation, the Non-MAGI MFBU must have a SOC and contain a “Sneede class member.”  

Sneede Class Members

A Sneede class member consists of the following:

  • Stepparents;
  • An unmarried couple with a mutual child(ren);
  • A child with their own nonexempt income; or
  • A non-parent caretaker relative(s) in the same MFBU with the child(ren) for whom care is provided.

Sneede v. Kizer Income Rules

The income rules applied in a Sneede v. Kizer evaluation are as follows:

  • A stepparent’s income cannot be used in determining Medi-Cal eligibility for their stepchild(ren).
  • An unmarried couple’s income cannot be used in determining Medi-Cal eligibility for each other, or for the other partner’s separate child(ren).
  • Income belonging to a child can only be used in determining Medi-Cal eligibility for that child.
  • Income belonging to a caretaker relative can only be used in determining the caretaker’s Medi-Cal eligibility.

Mini-Budget Units (MBUs)

A Sneede v. Kizer evaluation requires that the household be divided into MBUs according to the case composition to properly apply the income rules.  A family may have multiple MBUs.

The detailed Policy and Procedures in this document are only for the Medi-Cal Program only.


Background

Sneede v. Kizer was a lawsuit that changed how income and property (for evaluations prior to the January 1, 2024, asset requirement elimination) is considered when determining eligibility for certain families. 

A later lawsuit, Gamma v. Belshe, changed the method of computing an MFBU’s SOC and required a Parental/Spousal Needs Allocation be granted before the parent/spouse allocates income to their child/spouse. 


Definitions

Terms and Descriptions


Medi-Cal Family Budget Unit (MFBU)

Consists of the persons who will be included in the Medi-Cal eligibility and SOC determination; also known as the household.

Mini-Budget Units (MBUs)

Refers to the new family sub-units derived from the initial MFBU composition.  These sub-units are used to prevent improper co-mingling of income when determining SOC and eligibility.

Public Assistance (PA) Recipient

An individual who is in receipt of California Work Opportunity and Responsibility to Kids (CalWORKs), Foster Care (FC), or Supplemental Security Income/State Supplementary Payment (SSI/SSP) benefits.

Responsible Relative

Consists of financial responsibility of spouse-for-spouse and parent-for-child.


Requirements

Sneede v. Kizer Screening

Sneede v. Kizer must be evaluated if the individual exceeds the MAGI Medi-Cal income limit and the MFBU contains both: 

  • A Sneede class member; and
  • A SOC. 

Federal Poverty Level (FPL) Evaluation for Pregnant Persons and Child(ren) 

With the implementation of Health Care Reform:

  • FPL programs for pregnant persons and child(ren) are only available through the MAGI Medi-Cal program. 
  • An FPL evaluation is not required under Sneede.

Parental/Spousal Needs Allocation

A sufficient amount of the responsible relative's income must be allocated to themselves to meet their needs before allocating any income to their spouse/child(ren).


Verification Docs

N/A


Attachments

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Index

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