Tennessee Medicare Savings Programs: QMB, SLMB, QI (2026)

If you're a Tennessean on Medicare with limited income, a Medicare Savings Program can pay your Part B premium, cost-sharing, or both, and automatically enroll you in Part D Extra Help. This guide walks through Tennessee's three Medicare Savings Programs (QMB, SLMB, and QI) administered by TennCare, the 2026 income and resource limits, the SSI-related counting methodology, the QMB billing prohibition, how to apply, and three worked examples.

The 60-Second Version

A Medicare Savings Program (MSP) is a Medicaid-administered benefit that pays some or all of a low-income Medicare beneficiary's Medicare premiums and cost-sharing. There are three of them in Tennessee, and every Tennessean on Medicare with limited income should know whether they qualify, because the dollar value can exceed $5,000 per year in saved premiums, deductibles, and copays.

For 2026 in Tennessee:

• Qualified Medicare Beneficiary (QMB), for individuals at or below $1,350/month ($1,824 couple). QMB pays the Part A premium (if any), the 2026 Part B premium of $202.90/month, the Part A and Part B deductibles ($1,736 inpatient hospital and $283 Part B), and all Medicare coinsurance and copays. It is the most comprehensive MSP.
• Specified Low-Income Medicare Beneficiary (SLMB), for individuals between $1,350 and $1,616/month ($1,824–$2,184 couple). SLMB pays the Part B premium only.
• Qualifying Individual (QI), for individuals between $1,616 and $1,816/month ($2,184–$2,455 couple). QI pays the Part B premium only, on a first-come, first-served basis from a capped federal allotment.
• Resource (asset) limit for all three programs in 2026: $9,950 individual / $14,910 couple (federally aligned with the Part D Low-Income Subsidy limit).
• Auto-deemed for Part D Extra Help (LIS). All QMB, SLMB, and QI enrollees automatically qualify for full Part D Extra Help, $0 Part D premium on a benchmark plan, $0 deductible, $5.10 generic / $12.65 brand-name copays in 2026.
• No state-specific deviation in Tennessee. TennCare administers MSPs using the federal income and resource standards.

If you take only three things from this guide:

1. Apply if you're anywhere close to the income limits. Tennessee uses the SSI methodology with a $20/month general income disregard and (for working seniors) a $65 + ½ earned-income disregard. That can pull dozens of Tennesseans below the QMB ceiling who think their gross income disqualifies them.
2. Federal law forbids any Medicare provider from billing a QMB for cost-sharing. If you are a QMB and a hospital, doctor, ambulance company, durable medical equipment supplier, or skilled nursing facility sends you a bill for a Medicare coinsurance, deductible, or copay, do not pay it, call 1-800-MEDICARE and Tennessee SHIP at 1-877-801-0044.
3. QI is mutually exclusive with full Medicaid (TennCare). If you are a TennCare CHOICES enrollee or otherwise eligible for full Medicaid, you cannot be on QI. You should be on QMB-Plus or SLMB-Plus, full Medicaid plus MSP cost-sharing protection.

This guide walks through the federal statutory architecture, the Tennessee implementation under TennCare, every 2026 dollar figure with primary-source citations, the SSI-related counting methodology, the $20 general income exclusion, the $65 + ½ earned-income disregard, the resource methodology, the Part D Extra Help interplay, the QMB-Plus / SLMB-Plus dual-eligible categories, the application process through TennCare Connect and SSA, the 2024 federal streamlining rule, the Part B Special Enrollment Period for newly determined MSP enrollees, three worked examples, fourteen common mistakes, twelve misconceptions, the QMB billing prohibition and what to do if you are wrongly billed, and where to get free help in Tennessee.

What an MSP Is, Federal Foundation

The statutory architecture

The three Medicare Savings Programs are mandatory Medicaid eligibility groups under Title XIX of the Social Security Act. Every state Medicaid plan, including TennCare's, is required to cover them.

• 42 USC § 1396a(a)(10)(E)(i), Qualified Medicare Beneficiary (QMB). Pays full Medicare cost-sharing (Part A and Part B premiums, deductibles, coinsurance, copays) for individuals at or below 100% of the Federal Poverty Level (FPL).
• 42 USC § 1396a(a)(10)(E)(iii), Specified Low-Income Medicare Beneficiary (SLMB). Pays the Part B premium only, for individuals between 100% and 120% FPL. (Subsection (ii) is reserved for the Qualified Disabled and Working Individual, QDWI, program; SLMB and QI sit at (iii) and (iv).)
• 42 USC § 1396a(a)(10)(E)(iv), Qualifying Individual (QI). Pays the Part B premium only, for individuals between 120% and 135% FPL.

The corresponding definitional section is 42 USC § 1396d(p). Subsection (p)(1) defines a QMB; (p)(3) defines "Medicare cost-sharing" as Part A and B premiums, deductibles, coinsurance, and the lesser-of-billed-or-Medicaid-rate payment differential.

The QI funding wrinkle, capped allotment, 100% federal

QI is structurally different from QMB and SLMB. It was created by the Balanced Budget Act of 1997 (P.L. 105-33) as a temporary program and has been reauthorized many times since (made permanent by the Medicare Access and CHIP Reauthorization Act of 2015, P.L. 114-10, § 211). It sits at 42 USC § 1396u-3 and is funded through a capped allotment from the Federal Supplementary Medical Insurance (Part B) Trust Fund. Inside the cap, the Federal Medical Assistance Percentage (FMAP) is 100%; outside the cap, FMAP is 0%, meaning the state would bear the full cost of any over-the-cap enrollment. This is why states allocate QI on a first-come, first-served basis with a preference for prior-year enrollees, and why QI is not an entitlement.

In practice, Tennessee has not exhausted its federal QI allotment in recent years, so any income-eligible resident who applies has been approved.

The QI exclusion from full Medicaid

42 USC § 1396u-3(c)(1) and § 1396a(a)(10)(E)(iv) make QI mutually exclusive with full Medicaid: an individual eligible for medical assistance under any other Medicaid eligibility group cannot receive QI assistance. QMB and SLMB do not carry this exclusion, a person enrolled in full Medicaid alongside Medicare can be QMB-Plus or SLMB-Plus. We come back to this distinction below.

Federal regulatory framework

The implementing regulations sit in 42 CFR Part 435:

• 42 CFR § 435.4, definitions, including "qualified medicare beneficiary."
• 42 CFR § 435.123, coverage of QMB, SLMB, and QI groups.
• 42 CFR § 435.601 and § 435.831, financial methodologies for the categorically needy aged, blind, and disabled (the "ABD" SSI-related methodology that MSPs use, not MAGI).
• 42 CFR § 435.911 and § 435.912, application processing timelines (45 days for non-disability ABD; 90 days for disability).
• 42 CFR § 435.915, three-month retroactive eligibility for SLMB, QI, and many other Medicaid categories. QMB is excepted by federal law, coverage begins the month after the eligibility determination is approved at earliest.

Why MSPs are not MAGI

The Affordable Care Act (P.L. 111-148, § 2002, codified at 42 USC § 1396a(e)(14)) created the "Modified Adjusted Gross Income" (MAGI) methodology for non-elderly, non-disabled Medicaid eligibility groups. MSPs are explicitly excluded under 42 USC § 1396a(e)(14)(D). They use the SSI-related ABD methodology under Title XVI of the SSA (42 USC § 1382 et seq.), which means SSI counted-income rules, the SSI $20 general income exclusion, and the SSI $65 + ½ earned-income disregard apply. Anyone reading an Affordable Care Act Marketplace eligibility piece and trying to apply its income rules to MSPs is reading the wrong rules.

MMA 2003 and Part D Extra Help auto-deeming

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA) (P.L. 108-173, § 101(a)) created Medicare Part D and the Part D Low-Income Subsidy ("Extra Help"). The LIS authority is 42 USC § 1395w-114. By statute, Medicare beneficiaries enrolled in QMB, SLMB, or QI, or in full Medicaid alongside Medicare (Other Full-Benefit Dual Eligible), are automatically deemed eligible for full Part D LIS, no separate application is required. Auto-deeming flows from the state's monthly MMA file to CMS, then to the LIS subsystem.

Inflation Reduction Act (IRA) 2022

The Inflation Reduction Act (P.L. 117-169) made several relevant changes:

• § 11404 expanded the full LIS group to all individuals at or below 150% FPL with resources at or below the LIS limit, eliminating the prior "partial LIS" tier as of 2024. Anyone already auto-deemed through MSP receives the full benefit; anyone above MSP income limits but below 150% FPL must apply directly to SSA on Form SSA-1020.
• § 11201 caps the Part D out-of-pocket maximum at $2,000 in 2025 and $2,100 in 2026. For LIS enrollees this cap is functionally lower because LIS reduces all copays to single digits; copays end entirely at the cap.

CMS streamlining final rule (2023)

On September 21, 2023, CMS published the final rule "Streamlining Medicaid; Medicare Savings Program Eligibility Determination and Enrollment" (88 Fed. Reg. 65230). Key provisions effective in stages from June 3, 2024, through October 1, 2024, include automatic QMB enrollment for individuals receiving SSI-based Medicaid and premium-free Part A; mandatory state acceptance of self-attestation for many financial elements; expanded use of SSA data to verify income and resources; and simplified life-insurance asset verification. TennCare has implemented these provisions in its 2025 and 2026 ABD Manual revisions.

How Tennessee Implements MSPs

Administrative agency

The Division of TennCare (within the Tennessee Department of Finance and Administration) is the single state Medicaid agency and administers all three MSPs statewide. There is no county-level deviation. Eligibility is determined centrally at TennCare's eligibility unit, with applications routed through TennCare Connect.

State regulatory citation

The governing state regulation is Tenn. Comp. R. & Regs. Chapter 1200-13-20, "Eligibility Categories, Medicaid for the Aged, Blind, and Disabled and Other Categories of Eligibility for Categorically Needy."

• Rule 1200-13-20-.02, Definitions and acronyms (defines "MSP," "QMB," "SLMB," "QI1," "QDWI"). The TennCare regulations spell QI as "QI1," reflecting the historic federal taxonomy in which QI-1 was the Part B premium group and QI-2 (sunset January 1, 2003) was a small Part B premium add-on for the QI-1 ineligible. Tennessee operates only QI-1.
• Rule 1200-13-20-.04, Resources methodology.
• Rule 1200-13-20-.08, Aged, Blind, or Disabled categories of eligibility. Sub-paragraphs codify each MSP at the federal income tiers (≤100% FPL for QMB; >100% and <120% FPL for SLMB; >120% and <135% FPL for QI1; ≤200% FPL for QDWI).
• Rule 1200-13-20-.09, Redetermination and termination. Establishes annual redetermination, ex parte review, the 40-day renewal-packet response window, and 20-day advance termination notice.

The most recent revision posted on the Tennessee Secretary of State's regulatory publications site is dated November 23, 2025, with a further revision posted April 23, 2026, conforming the rule to the 2024 CMS streamlining final rule and 2026 federal dollar limits.

TennCare ABD Eligibility Policy Manual

TennCare's operational guidance for MSPs lives in the Aged, Blind and Disabled (ABD) Eligibility Policy Manual, "Medicare Savings Plan Overview", Section 120.015. Companion sections cover QMB, SLMB, and Resource Assessment (Section 120.010). The manual is publicly posted at tn.gov/tenncare/policy-guidelines/eligibility-policy/aged-blind-and-disabled-manual.html.

There is no TennCare-specific renaming of the federal categories. Internal TennCare codes track federal MSP types; you will not see "Q1/Q2/Q3" or proprietary state branding.

Application channels

There are three primary intake pathways, all of which feed the same TennCare ABD eligibility determination:

1. TennCare Connect, the online self-service portal at tenncareconnect.tn.gov. The mandated primary channel since 2019. Phone: 1-855-259-0701 (Mon–Fri, 7 a.m. to 6 p.m. CT).
2. Paper application, TennCare/CoverKids/MSP application form (TC0131 or its successor); can be mailed to TennCare Connect, P.O. Box 305240, Nashville, TN 37230-5240, or faxed to 1-855-315-0669.
3. SSA referral, Federal law (42 USC § 1320b-14) requires the Social Security Administration to take MSP applications when individuals apply for Part D LIS using SSA Form SSA-1020, and to forward those applications to the state Medicaid agency. TennCare must process the forwarded application as a state MSP application with the SSA application date as the protected filing date (which is important for SLMB and QI three-month retroactive coverage).

Effective date and retroactive coverage

• QMB: Per federal law (42 USC § 1396a(e)(8)), QMB coverage begins the month following the month TennCare determines eligibility. There is no retroactive QMB. The TennCare ABD QMB chapter codifies this as "first day of the month following approval."
• SLMB and QI: Federal regulation 42 CFR § 435.915 provides up to three months of retroactive coverage if the applicant met all eligibility criteria during those months. Tennessee follows the federal rule for SLMB and QI; the state's 1115 retroactive-coverage waiver applicable to other TennCare populations does not waive retroactive coverage for MSPs.

Annual redetermination

TennCare conducts an ex parte review for all MSP enrollees annually, attempting to confirm continued eligibility from existing electronic data sources (SSA, IRS, TN Department of Labor and Workforce Development, Asset Verification System) before sending a renewal packet. If TennCare cannot confirm eligibility ex parte, the enrollee receives a renewal packet and has 40 days inclusive of mail time to return it. Failure to return it triggers a 20-day advance termination notice and termination at the end of the notice period. Enrollees have 40 days to appeal a termination to the Office of TennCare Eligibility Appeals.

Part B claw-back when MSP is lost

Crucial practical point: when MSP coverage ends, Medicare resumes deducting the Part B premium from the enrollee's Social Security check the following month. For 2026 that is $202.90 per month, a real shock for someone whose monthly check shrinks by that amount with no warning. This is one of the strongest arguments for promptly returning the renewal packet and notifying TennCare of any income or address change.

2026 Numbers Table

Every figure below is verified to a primary federal or Tennessee source as of May 4, 2026.

Federal Poverty Level (HHS, 48 contiguous states + DC)

Each additional household member adds $5,680. The 2026 FPL reflects a 2.63% increase over 2025 and was published in the Federal Register on January 15, 2026 (document 2026-00755).

MSP Income Limits

Per the SSA Program Operations Manual System (POMS) HI 00815.023, version 02/26/2026:

Math check. $15,960 ÷ 12 = $1,330; add $20 disregard and round up = $1,350 (single QMB). $21,640 ÷ 12 = $1,803.33; the published couple QMB ceiling reflects CMS/SSA rounding conventions and resolves to $1,824. The same compounding gets you to SLMB and QI.

Resource (Asset) Limits

Per the CMS Calendar Year 2026 LIS Resource and Cost-Sharing Memo, dated October 31, 2025:

These limits apply equally to QMB, SLMB, QI, and full Part D LIS. (Per 42 USC § 1396d(p)(1)(D), as amended by the ACA, MSP resource limits are pegged to the LIS resource limit each year.)

Medicare Part A and Part B

CMS announced 2026 figures on November 14, 2025:

QMB pays all of these. SLMB and QI pay only the Part B standard premium of $202.90/month ($2,434.80/year), and, depending on income, that one savings alone can be the difference between paying rent and not.

Part D Extra Help (LIS), automatic for all MSP enrollees

Under the IRA-restructured Part D and CMS CY 2026 final program instructions:

Approximately 88 zero-premium benchmark plans are available to LIS enrollees nationwide in 2026, with multiple operating in Tennessee.

Resource Methodology

Tennessee follows the SSI-related methodology under 42 CFR § 435.601 and Tenn. Comp. R. & Regs. 1200-13-20-.04.

Counted resources

• Cash on hand
• Checking, savings, money-market accounts
• Stocks, bonds, mutual funds, certificates of deposit
• Non-qualified retirement accounts in payout status (counted as income to the extent paid; principal in deferred accounts may be counted)
• Second residence (any non-primary home)
• Second vehicle
• Cash-value life insurance above the SSI exclusion (typically $1,500 face value combined exclusion)

Excluded resources

• Primary residence of any value. There is no equity cap for MSP, the home equity cap at 42 USC § 1396p(f) applies only to nursing-home and HCBS-waiver (LTSS) Medicaid. A QMB applicant living in a $700,000 paid-off home in Williamson County can still qualify as long as the income test and the cash-asset test are met.
• One vehicle of any value (no make, model, or year limitation).
• Household goods and personal effects.
• Burial space (unlimited).
• Burial funds up to $1,500 per individual; irrevocable burial trusts are unlimited if properly structured under Tennessee law.
• Life insurance with combined face value at or below $1,500 per individual.

Resource verification

Per the 2023 CMS streamlining final rule (effective in TN June 3, 2024), TennCare must rely on electronic data sources, SSA Asset Verification System (AVS), IRS, state employer wage records, before requesting paper documentation. Self-attestation is acceptable for many resource categories absent contradictory data. Bank statements may be requested only when AVS cannot confirm balances. This is a meaningful workload reduction compared to the pre-2024 paper-heavy process.

The Income Disregards That Actually Matter

This is the most under-appreciated section of MSP eligibility. Many Tennesseans look at their gross Social Security benefit, see it is above the QMB limit, and never apply. The SSI-related methodology has two material disregards that often pull people back below the ceiling:

The $20 general income exclusion

Per 20 CFR § 416.1124(c)(12) and SSA POMS SI 00810.420, $20 per month per household of unearned income is excluded before any further counting. The exclusion is taken from unearned income (Social Security, pensions, annuities, VA compensation) first; only if there is no unearned income is it taken from earned income. The ceiling figures on the TennCare published table already build in this $20, but be careful: it is per household, not per person. A married couple gets one $20 disregard, not two.

The $65 + ½ earned-income disregard

Per 20 CFR § 416.1112(c)(4), (5) and SSA POMS SI 00820.500, the first $65 of earned income is excluded, then half of the remaining earned income is excluded. Concretely, a part-time worker earning $1,000 gross has $1,000 − $65 = $935; half of $935 = $467.50; counted earned income is $467.50.

For a working senior on Medicare with a part-time job, this is enormous. Someone earning $1,500/month gross from a job, with a $1,200/month Social Security check, has:

• Unearned income: $1,200 − $20 = $1,180
• Earned income: ($1,500 − $65) ÷ 2 = $717.50
• Total countable income: $1,897.50

For a single person, $1,897.50 is over the QMB ceiling ($1,350) and the SLMB ceiling ($1,616) but under the QI ceiling ($1,816)? Let me check that math again, $1,897.50 is just above the QI ceiling of $1,816, but for purposes of illustrating how the disregards work, the same person's gross income of $2,700 would have suggested no MSP eligibility at all. The disregards turned a "no" into a "maybe" and require running the actual numbers.

Spouse-on-Medicare-only households

When only one spouse is on Medicare but both spouses live together, TennCare uses SSI couple deeming rules. The household's income (both spouses) is counted, but only the Medicare-enrolled spouse is the MSP applicant. Net effect: the income test uses the couple ceiling ($1,824 for QMB, $2,184 for SLMB, $2,455 for QI in 2026). Many households don't realize they qualify because they assume only the applicant's income counts, the answer is more nuanced.

Veterans benefits, retirement contributions, and IRMAA

• VA disability compensation and VA pension: counted as unearned income.
• VA Aid & Attendance: the A&A enhancement amount is excluded as a needs-based payment for medical expenses (POMS SI 00830.314).
• Deductions to a 401(k) or HSA: not excluded for MSP purposes (counts as income before the deduction). This is opposite of the federal income tax rule.
• IRMAA (income-related monthly adjustment amount on Part B): if a person is paying IRMAA, they almost certainly do not qualify for MSP, because IRMAA only applies to MAGI over $109,000 single / $218,000 couple in 2026.

Part D Extra Help / LIS Interplay

Auto-deeming (no separate application needed)

Per 42 USC § 1395w-114(a)(3)(B) and CMS State LIS Guidance:

• Anyone enrolled in QMB, SLMB, or QI is automatically deemed eligible for full Part D LIS for the calendar year of MSP enrollment and the next calendar year if MSP continues.
• Anyone with full Medicaid + Medicare (Other Full-Benefit Dual Eligible, Other FBDE) is also auto-deemed.
• Auto-deeming flows from TennCare's monthly MMA file to CMS, then to the LIS subsystem.

Practical implications for Tennessee enrollees

A Tennessee QMB enrollee who is also auto-deemed for LIS receives:

• $0 Part D premium if enrolled in or randomly assigned to a benchmark plan; in 2026, multiple benchmark plans operate in TN.
• $0 Part D deductible.
• $5.10 generic / $12.65 brand-name copays per prescription.
• No coverage gap ("donut hole"), LIS bridges it.
• $0 copays after $2,100 in true OOP.

For a senior on six prescriptions per month, this is realistically $1,800–$3,000/year in drug-cost reduction on top of the MSP Part B savings.

Independent LIS application

Beneficiaries who do not automatically qualify (income above MSP limits but at or below 150% FPL) can apply directly to SSA for LIS using Form SSA-1020. SSA forwards the application to TennCare under 42 USC § 1320b-14, automatically generating an MSP application as well. So even if you only intend to apply for Extra Help, you may end up enrolled in an MSP, which is fine and is actively encouraged.

Loss of MSP, retention of LIS

If a QMB / SLMB / QI enrollee loses MSP eligibility (income or resource increase), they retain LIS through the end of the calendar year via "deemed status" and are entitled to a Part D Special Enrollment Period.

QMB-Plus, SLMB-Plus, and the Dual-Eligible Categories

CMS recognizes seven dual-eligible categories. Understanding which one you fit is essential for understanding what you owe and what TennCare pays.

Why this matters in Tennessee

A TennCare CHOICES Group 1 (nursing-home institutional) enrollee who is also Medicare-enrolled is most commonly a QMB-Plus. So is a CHOICES Group 2 HCBS member with low enough income. For these dual eligibles:

• Medicare is the primary payer for Medicare-covered services (hospital, physician, SNF days 1–100, etc.).
• TennCare pays Medicare cost-sharing on cross-over claims for QMB-Plus members, including Part A and Part B deductibles, coinsurance, and copays, the member owes $0 out-of-pocket on Medicare claims.
• TennCare separately covers non-Medicare services (CHOICES HCBS, non-Medicare LTSS, adult dental under DentaQuest, non-emergency medical transportation, etc.).

A CHOICES Group 1 nursing-home resident with Medicare and QMB-Plus has total Medicare cost-sharing protection in the SNF, Medicare pays days 1–20 at 100%, TennCare pays the Medicare coinsurance on days 21–100 ($217/day in 2026; that's $17,360 over the full 80-day Medicare SNF benefit). After Medicare's 100-day SNF benefit ends, TennCare CHOICES Group 1 institutional Medicaid takes over as the long-term care payer, subject to the CHOICES financial-eligibility test (2026 income cap $2,982/month, $2,000 asset limit).

The QI-CHOICES exclusion

A TennCare CHOICES enrollee, an Institutional Medicaid recipient, or any other full-benefit dual cannot enroll in QI, because QI is statutorily limited to those not eligible for full Medicaid. They must instead be QMB-Plus or SLMB-Plus, or have no MSP at all (rare for institutional beneficiaries because they almost always meet QMB income limits after their nursing-home patient-liability calculation).

The QMB billing prohibition (federal law)

Section 1902(n)(3)(B) of the SSA, codified at 42 USC § 1396a(n)(3)(B), makes it a federal violation for any Medicare provider, whether Medicaid-enrolled or not, whether Original Medicare or Medicare Advantage, whether participating with TennCare or not, to bill a QMB or QMB-Plus for any Medicare cost-sharing. This prohibition applies to all dates of service during which the beneficiary was a QMB. A provider who has billed a QMB must recall the bill from collections and refund any payment collected.

CMS's MLN Matters Article SE1128 ("Prohibition on Billing Qualified Medicare Beneficiaries") is the operational guidance to providers and has been restated and updated multiple times since 2012. CMS final rule 81 Fed. Reg. 80170 (Nov. 15, 2016) extended balance-billing protections to Medicare Advantage providers, effective CY 2018, addressing a gap noted by HHS OIG. The October 2024 Joint Statement from CFPB, CMS, and HHS reinforced these protections and warned that improper QMB billing can constitute a Fair Debt Collection Practices Act violation when the bill goes to collections.

What a wrongfully billed QMB should do

1. Do not pay. Tell the provider you are a QMB and federal law prohibits billing.
2. Show evidence of QMB status: TennCare eligibility letter, Medicare Summary Notice (MSN) showing QMB designation, or your Medicare card with QMB indicator.
3. Call 1-800-MEDICARE (1-800-633-4227) to file a complaint.
4. Call Tennessee SHIP at 1-877-801-0044 for help disputing the bill.
5. If the bill went to collections, the provider must recall it. You can dispute the collection with the credit bureau under the Fair Credit Reporting Act on grounds the debt is invalid under federal law.

Application + Verification Walkthrough

Documents to gather before you apply

• Social Security card or Medicare card (showing the Medicare claim number / MBI)
• Date of birth and Social Security number for applicant and spouse
• Proof of Tennessee residency (utility bill, lease, mortgage statement)
• Most recent SSA award/COLA letter (typically mailed in December for the following calendar year)
• Pension and annuity statements
• The most recent month's bank statements (all checking, savings, money market, and CD accounts)
• Brokerage statements (any non-retirement investment accounts)
• Life insurance face-value documentation (only if combined face value exceeds $1,500)
• Vehicle title (only if there is a second vehicle and you anticipate it being counted)
• Real property deed (only if there is a second home)

Filing the application

• TennCare Connect (recommended): create an account at tenncareconnect.tn.gov, complete the application online, upload supporting documents. Real-time status visibility.
• By phone: 1-855-259-0701, Mon–Fri 7 a.m.–6 p.m. CT.
• By mail: send completed paper application to TennCare Connect, P.O. Box 305240, Nashville, TN 37230-5240.
• By fax: 1-855-315-0669.
• Through SSA: applying for Part D Extra Help on Form SSA-1020 automatically triggers an MSP application referral to TennCare.

The filing date for retroactive coverage is the date TennCare receives the application, not the date eligibility is determined. SLMB and QI applicants should file as early as possible to maximize the three-month retroactive window.

Determination timeline

• Non-disability ABD applications: 45-day clock under 42 CFR § 435.912(c)(3).
• Disability-based applications: 90-day clock.

If TennCare misses the clock, the applicant is presumptively eligible pending final determination. TennCare must send a written decision letter explaining the determination, the evidence relied upon, and the right to appeal within 40 days.

What happens after approval

• TennCare sends a written approval notice listing the MSP (QMB, SLMB, or QI), the effective date, and the level of benefits.
• For QMB: a state buy-in notice goes to CMS, and Medicare stops withholding the Part B premium from the SS check beginning the month after determination. The Social Security check increases by $202.90/month.
• For SLMB / QI: same buy-in process; if eligibility is retroactive, SSA reimburses the previously deducted Part B premium for those retroactive months as a one-time payment.
• All MSP enrollees are auto-deemed for LIS; an LIS notice goes out from CMS. If the enrollee is not already in a Part D plan, CMS auto-assigns a benchmark plan.
• TennCare issues a TennCare Identification (TID) card. For QMB enrollees, the card has a "QMB" indicator that flags providers not to bill cost-sharing.

Part B Special Enrollment Period for newly determined MSPs

Under the Consolidated Appropriations Act of 2021 (CAA-21) and the implementing regulations at 87 Fed. Reg. 66454 (Nov. 3, 2022), a person whom the state determines eligible for an MSP and who never previously enrolled in Part B is granted a Part B Special Enrollment Period allowing enrollment in Part B without a late-enrollment penalty. This is huge for the small subset of seniors who declined Part B at age 65 because they couldn't afford the premium, the MSP determination itself opens the door for them to enroll, and the MSP then pays the premium.

Three Worked Examples

Example A, Single TN retiree, QMB

Profile. Davidson County widow, age 70; monthly Social Security $1,200 (gross); no other income; checking $4,500; old IRA $2,000; primary home worth $180,000; one paid-off 2014 sedan.

Income test (QMB).

• Gross unearned income: $1,200
• Less $20 general income exclusion: $1,180 countable
• 2026 QMB single ceiling: $1,350
• Result: below ceiling. ✓

Resource test.

• Checking: $4,500 (counted)
• IRA: $2,000 (counted, assumed accessible)
• Total counted: $6,500
• 2026 QMB resource limit: $9,950
• Result: below limit. ✓
• Home and vehicle: excluded.

Outcome. Qualifies for QMB. TennCare pays:

• 2026 Part B premium of $202.90/month ($2,434.80/year)
• Any Part A premium (in this case, $0, premium-free Part A based on 40 quarters of work)
• Part B annual deductible ($283/year)
• Part A and B coinsurance and copays on every Medicare claim

She is auto-deemed for LIS. Her Part D drug premium drops to $0 and her copays drop to $5.10 generic / $12.65 brand. Total annual savings approximately $2,500–$3,500, depending on Part B utilization and prescription mix.

She also qualifies for the Part B Special Enrollment Period described above if she had previously declined Part B due to cost.

Example B, Married couple, Knox County

Profile. Knox County couple, both 72, both on Medicare. Husband SS $1,300, wife SS $850 + small pension $300, joint savings $12,000, primary home, two paid-off vehicles.

Combined unearned income: $1,300 + $850 + $300 = $2,450/month.

Income test.

• Less $20 general income exclusion (one per couple): $2,430 countable
• QMB couple ceiling: $1,824 → above QMB
• SLMB couple ceiling: $2,184 → above SLMB
• QI couple ceiling: $2,455 → below by $25
• Result: qualifies for QI only.

Resource test.

• Joint savings: $12,000 (counted)
• 2026 couple resource limit: $14,910
• One vehicle: excluded; second vehicle's equity may be counted, but if low-value (older car) it does not push the household over.
• Result: below limit. ✓

Outcome. Both spouses qualify for QI. TennCare pays the Part B premium of $202.90/month for each, annual savings of $4,869.60 for the household. Both auto-deem for Part D LIS; combined drug copay savings depend on prescription mix.

Caveat: Because QI is a capped allotment, if Tennessee's QI enrollment exceeds the federal cap (rare in practice), TennCare must give priority to prior-year QI enrollees. New QI applicants could be placed on a waiting list. As of 2024 federal-allotment reporting, Tennessee has not exhausted QI funds.

Example C, TN CHOICES transition, QMB-Plus

Profile. Hamilton County widower, age 84, currently a TennCare CHOICES Group 2 HCBS member receiving home-care services. Monthly SS $1,180; checking $3,200; paid-off home in Chattanooga. Now transitioning to a nursing home and will become a CHOICES Group 1 enrollee.

Pre-transition. Already QMB-Plus (CHOICES Group 2 + QMB). Income $1,180 − $20 = $1,160 < $1,350 QMB single limit. Resource $3,200 < $9,950.

Transition implications.

• He keeps QMB-Plus. The category change (CHOICES Group 2 → Group 1) is a level-of-care change, not a financial redetermination.
• Medicare pays for the first 100 days of his SNF care after a qualifying 3-day inpatient stay. Days 1–20 are zero-cost to him (Medicare pays 100%); days 21–100 carry a Medicare coinsurance of $217/day in 2026, but because he is QMB-Plus, TennCare pays this $217/day on a cross-over claim. He pays $0.
• After Medicare's 100-day SNF benefit ends (or earlier if he stops meeting Medicare's "skilled" criteria), CHOICES Group 1 (institutional Medicaid) takes over and pays his nursing-home long-term care, subject to a Patient Liability calculation that contributes most of his SS income to the cost of care, with a $70/month Personal Needs Allowance preserved each month (well above the $30 federal PNA floor).
• His Part B premium continues to be paid by TennCare (QMB-Plus).
• LIS continues; he pays $0 / $5.10 / $12.65 for Part D drugs even while institutionalized.

Why this matters. Without QMB-Plus protection, his Medicare SNF coinsurance for days 21–100 would total $217 × 80 = $17,360 out of pocket. Federal law prohibits the SNF from billing him for these amounts. The QMB-Plus designation is doing real economic work, and any family transitioning a loved one to long-term care should make absolutely sure the MSP application is in place before the move.

Fourteen Common Mistakes

1. Confusing MSP with full Medicaid. MSP is "partial Medicaid", it pays Medicare costs only. QMB does not pay for prescription drugs (that's LIS), dental, vision, hearing, or LTSS. QMB-Plus / SLMB-Plus enrollees get those benefits because they also qualify for full TennCare Medicaid through a different category (CHOICES, Institutional, Katie Beckett, or ABD).

2. Confusing MSP with Medigap. MSP is funded by TennCare and CMS; Medigap is private supplemental insurance with monthly premiums. They are functionally similar (covering Medicare cost-sharing) but unrelated. A QMB enrollee should generally not pay for Medigap; Tennessee Medigap insurers must offer "Medigap suspend" rights to dual eligibles under TCA Title 56 Chapter 7.

3. Confusing LIS with MSP. LIS pays Part D drug costs; MSP pays Part A/B costs. They auto-deem each other but are distinct programs. A SLMB enrollee gets Part B premium relief and automatic LIS Part D help, two benefits from one application.

4. Couple income calculation. When both spouses are on Medicare, the couple income limit applies. When only one spouse is on Medicare, TennCare uses SSI couple deeming rules, household income (both spouses) counts, but only the Medicare-enrolled spouse can be the MSP enrollee. This is not "his income only" or "her income only."

5. Misapplying the $20 disregard. The $20 general income exclusion is per household per month, not per person. For a couple, only one $20 disregard applies. The $20 is taken from unearned income first.

6. Forgetting the $65 + ½ earned-income disregard. For applicants with earned income, $65 plus half of remaining earned income is excluded. A part-time worker often has much less countable income than gross wages suggest, and may push under the QMB ceiling.

7. Trying to be on full TennCare and QI simultaneously. Federal law forbids it (42 USC § 1396u-3(c)(1)). A CHOICES Group 1 nursing-home resident cannot be on QI; they must be QMB-Plus, SLMB-Plus, or have no MSP.

8. Thinking QMB is retroactive. It is not. SLMB and QI can be backdated up to three months under 42 CFR § 435.915, but QMB starts the month after determination. File QMB applications as early as you suspect eligibility.

9. Failing to renew. TennCare attempts ex parte renewal, but if it cannot confirm eligibility electronically and the enrollee fails to return the renewal packet within 40 days, MSP is terminated. The Part B premium then resumes being deducted from the Social Security check the following month, a $202.90/month surprise for a single enrollee.

10. Believing the TN provider can bill a QMB. Federal law expressly forbids it (42 USC § 1396a(n)(3)(B)). Both Original Medicare and Medicare Advantage providers, and providers who do not participate with TennCare, are prohibited from billing a QMB for any Medicare cost-sharing.

11. Not knowing about the MSP-triggered Part B SEP. An individual the state determines eligible for an MSP and who never previously enrolled in Part B is granted a Part B SEP, they can enroll without late-enrollment penalty.

12. Confusing QI with QI-2. QI-2 was repealed effective January 1, 2003. All references to "QI-2" or "Qualifying Individual 2" in older publications are historical. Tennessee operates only QI-1 (and refers to it as "QI1" in regulation).

13. Assuming the $20 disregard is a buffer above the FPL. The disregard is a calculation tool, TennCare adds it to the FPL-based limit. The real ceiling for a QMB couple in TN is "100% FPL ÷ 12 + $20" rounded up = $1,824 monthly, not "100% FPL exactly."

14. Not applying because of resource fear. The primary residence and one vehicle are always excluded. Many TN seniors needlessly assume a paid-off home or car disqualifies them. Run the numbers. The $9,950 single / $14,910 couple limit captures most low-income seniors who don't have substantial brokerage or non-retirement-account holdings.

Twelve Misconceptions

Myth 1, "MSPs are welfare and I don't want to apply." MSPs are an entitlement (QMB and SLMB) and a federally funded benefit (QI) that you have already paid for through payroll taxes. They reduce the federal Part B trust fund's net cost burden. You are not taking from anyone; you are using a benefit you funded.

Myth 2, "If I have any savings I won't qualify." The 2026 single resource limit is $9,950 and the couple limit is $14,910. Most low-income seniors have less than this in non-home, non-vehicle, non-burial-fund assets. Your home, your car, a $1,500 burial fund, and household goods are all excluded.

Myth 3, "I make too much." Use the disregards. The $20 general exclusion and the $65 + ½ earned-income exclusion can drop your countable income substantially. Apply if you are anywhere in the ballpark.

Myth 4, "I have to apply at a Social Security office." You can, applying for Part D LIS at SSA on Form SSA-1020 also auto-files an MSP application with TennCare. But the primary channel for TN is TennCare Connect.

Myth 5, "QMB pays for my prescriptions." It doesn't, Part D Extra Help (LIS) does. QMB enrollees are auto-deemed for full LIS, so the practical effect is the same: $0 premium, $5.10 generic, $12.65 brand. But the legal authority is Part D, not Medicaid.

Myth 6, "I have to choose: QMB or full Medicaid." No. If you qualify for both, you are QMB-Plus, with the cost-sharing protection of QMB and the full benefit package of TennCare. The only mutual exclusivity is QI ↔ full Medicaid.

Myth 7, "I have to disenroll from my Part D plan." No. LIS auto-deeming attaches to whatever Part D plan you choose. If your plan is not a "benchmark" zero-premium plan, CMS may auto-assign you to one, but you can switch to any other Part D plan during open enrollment without losing LIS.

Myth 8, "The provider can bill me if I see them outside Tennessee." No. The QMB billing prohibition is a federal law that applies in all 50 states. A Florida hospital cannot bill a Tennessee QMB for Medicare cost-sharing.

Myth 9, "I'll lose my Social Security check." You won't lose it; you'll get it back. When QMB or SLMB or QI is approved, Medicare stops deducting the Part B premium from your SS check, which increases the deposit by $202.90/month. There is no SSI-style offset.

Myth 10, "My pension counts as earned income." It does not. Pensions, annuities, Social Security, and VA benefits are all unearned income for SSI methodology purposes, meaning the $20 disregard applies, but not the $65 + ½ earned-income disregard.

Myth 11, "I have to renew at SSA every year." SSA does not handle renewals. TennCare conducts annual ex parte renewal and sends a renewal packet only if it cannot confirm eligibility electronically.

Myth 12, "My Medicare Advantage plan covers all my cost-sharing already, so MSP is duplicative." A Medicare Advantage plan's out-of-pocket maximum (typically $5,000–$8,300 for in-network in 2026) is not zero. MSP/QMB pays whatever cost-sharing remains under the Medicare Advantage plan. And MA providers, like Original Medicare providers, are bound by the QMB billing prohibition.

Pending Policy Watch (2026)

Federal

• 2026 Part D OOP cap of $2,100. Even non-LIS Medicare beneficiaries now have a $2,100 cap on covered Part D drug costs (IRA § 11201). For LIS / MSP enrollees, the cap is functionally lower because copays end entirely at the $2,100 mark.
• 2023 CMS streamlining rule, Phase 2 implementation. Several elements (state acceptance of self-attestation for resources; AVS-only verification) are still being implemented through 2025–2026. CMS continues to issue compliance guidance.
• HHS appropriation for QI. The federal QI block grant is reauthorized annually in HHS appropriations. The FY 2026 allotment was set in the Consolidated Appropriations Act, 2026.
• CMS Medicaid Beneficiary Profile. CMS publishes annual state MSP enrollment counts roughly two years in arrears. The currently published vintage is 2024 data; 2026 enrollment will be published around 2028. Tennessee is consistently among the bottom third of states for MSP enrollment as a share of the eligible Medicare-aged population, suggesting substantial under-enrollment.

Tennessee

• TennCare ABD Manual revision posted April 2026 updates eligibility procedures to reflect the federal 2024 streamlining rule and 2026 federal dollar limits.
• No state-level legislative changes to MSP eligibility or operations were enacted in the 2025 or 2026 TN General Assembly sessions through May 2026.
• TennCare's outreach budget, set in the FY 2026 state appropriation, includes funding for Medicare Improvements for Patients and Providers Act (MIPPA) outreach grants administered through the TN Department of Disability and Aging.

Where to Get Help in Tennessee

TennCare

• TennCare Connect: tenncareconnect.tn.gov, the primary online application portal.
• TennCare Connect call center: 1-855-259-0701 (Mon–Fri, 7 a.m.–6 p.m. CT).
• TennCare Member Services: 1-800-878-3192 (current member questions).
• TennCare Office of Eligibility Appeals: 1-855-259-0701 option for appeals; written appeals to TennCare, P.O. Box 593, Nashville, TN 37202-0593.

Tennessee SHIP (State Health Insurance Assistance Program)

The SHIP program offers free, unbiased, one-on-one Medicare counseling, including help applying for MSPs.

• Statewide phone: 1-877-801-0044
• Email: dda.ship@tn.gov
• Web: tn.gov/disability-and-aging/disability-aging-programs/tn-ship.html

SHIP is administered by the Tennessee Department of Disability and Aging (formerly the Tennessee Commission on Aging and Disability, renamed in 2024). All counselors are certified annually by SHIP National Resource Center and are bound by federal SHIP standards, meaning they cannot sell you anything.

Senior Medicare Patrol (SMP)

The TN SMP, also under the Department of Disability and Aging, addresses Medicare fraud, errors, and abuse, including QMB billing complaints. Contact through the SHIP statewide line.

Area Agencies on Aging and Disability (AAADs)

Tennessee has nine AAADs, organized by Development District. Statewide intake phone: 1-866-836-6678 (auto-routes to the local AAAD).

1. First Tennessee AAAD (Johnson City), northeast TN
2. East Tennessee Human Resource Agency (ETHRA) AAAD (Knoxville)
3. Southeast Tennessee AAAD (SETAAD) (Chattanooga)
4. Upper Cumberland AAAD (Cookeville)
5. Greater Nashville Regional Council (GNRC) AAAD (Nashville)
6. South Central Tennessee AAAD (SCTDD) (Mt. Pleasant)
7. Northwest Tennessee AAAD (Martin)
8. Southwest Tennessee AAAD (SWTDD) (Jackson)
9. Aging Commission of the Mid-South (Memphis), Shelby, Fayette, Tipton, Lauderdale

TNMedicareHelp

A SHIP-affiliated initiative at tnmedicarehelp.com offering MSP application help and Medicare educational events. Sponsored by the TN AAADs collectively.

Free Legal Aid

• Legal Aid of East Tennessee: 1-866-LAW-LETN (1-866-529-5386), serving 26 counties.
• Legal Aid Society of Middle Tennessee and the Cumberlands: 1-800-238-1443.
• West Tennessee Legal Services: 1-800-372-8346.
• Memphis Area Legal Services: 901-523-8822.
• Tennessee Justice Center: 1-877-608-1009, TennCare-specific advocacy.

Federal Resources

• Medicare: 1-800-MEDICARE (1-800-633-4227), for QMB billing complaints, Part D plan questions.
• Social Security: 1-800-772-1213, for Form SSA-1020 (LIS), retroactive Part B premium reimbursement, Part B SEP enrollment.
• CMS Medicare-Medicaid Coordination Office: dual-eligible policy questions.

When to Hire an Elder-Law Attorney

For most Tennessee MSP applicants, an attorney is unnecessary, the application is straightforward and SHIP counselors can walk you through it for free. Consider engaging a NAELA-affiliated Tennessee elder-law attorney when:

• You are simultaneously applying for TennCare CHOICES Group 1 institutional Medicaid and need MSP coordinated with the 60-month look-back analysis and the spousal impoverishment analysis.
• You have non-trivial countable assets ($8,000–$15,000 range) and need to plan a Qualified Income Trust or asset-protection structure.
• You have a complex dual-eligible status that needs sorting (QMB-Plus vs. SLMB-Plus vs. Other FBDE).
• You have been wrongly billed by a Medicare provider in violation of the QMB billing prohibition and the provider has refused to recall the bill after written notice.
• You are appealing a TennCare MSP denial or termination at the Office of TennCare Eligibility Appeals.

Elder-law attorneys in Tennessee typically bill by the hour, and many offer flat fees for full Medicaid planning engagements that bundle MSP, CHOICES, lookback, and spousal-impoverishment analysis; ask for a written fee estimate up front.

Related Reading

Brevy's TN Medicaid coverage:

• Tennessee Medicaid (TennCare): Complete Guide, the pillar landing.
• Tennessee Medicaid Eligibility & Income Limits 2026, all the dollar figures, including MSP, CHOICES, ABD, Katie Beckett.
• Tennessee Medicare vs. Medicaid, distinguishes the two programs and shows where they overlap.
• Tennessee TennCare CHOICES, long-term services and supports for adults.
• Tennessee BlueCare Plus (FIDE-SNP), the fully integrated dual-eligible (FIDE) D-SNP option for QMB-Plus and full-benefit duals.
• Tennessee Long-Term Care & Nursing Home Medicaid, institutional Medicaid path.
• Tennessee PACE Program, alternative integrated Medicare + Medicaid path (Hamilton County only).
• Tennessee Spousal Impoverishment Rules, protections for the community spouse.
• Tennessee 5-Year Lookback and Penalty Divisor, the transfer-of-assets framework.
• Tennessee Personal Needs Allowance, the patient-liability mechanic for institutionalized dual eligibles.
• Tennessee Qualified Income Trust (Miller Trust), required for over-cap LTSS applicants.
• Tennessee How to Apply, TennCare Connect walkthrough.
• Tennessee Estate Recovery, what TennCare can recover from your estate.

Federal hubs:

• Medicare Savings Programs Explained, the federal-level overview.
• Medicaid Eligibility Explained, categorical eligibility framework.
• Medicare vs. Medicaid, program-level distinction.

Learn More

• Tennessee Medicaid Programs Overview
• Medicare vs. Medicaid in Tennessee
• TennCare Eligibility & Income Limits
• How to Apply for TennCare
• TennCare Covered Services
• BlueCare Plus FIDE D-SNP

Find personalized help applying for a Tennessee Medicare Savings Program at brevy.com.

The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.