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Page 9 – CMCS Informational Bulletin based and non-MAGI-based Medicaid beneficiaries.12 Section 1917(f)(1) of the Act currently sets the minimum and maximum home equity limits at $500,000 and $750,000, respectively, and, per section 1917(f)(1)(C) of the Act, these figures have increased since 2011, from year to year, based on the percentage increase in the consumer price index for all urban consumers (CPI-U).13 In 2025, the minimum and maximum home equity limits are, respectively, $730,000 and $1,097,000.14 A state may elect to set its home equity limit between these minimum and maximum thresholds.15 Section 71108 amends section 1917(f)(1) of the Act, beginning January 1, 2028, to cap the maximum home equity limit at $1,000,000, except that this limit will not apply to homes on land zoned for agricultural use.16 States will continue to have the option to impose a limit between the applicable minimum and maximum amounts, and this option will apply to both homes that are on land zoned for agricultural use and homes that are not. For non-agricultural homes, the minimum and maximum limits will be, respectively, the amount described in section 1917(f)(1)(A) of the Act, adjusted by CPI-U increases per section 1917(f)(1)(C) of the Act (which, as described above, equals $730,000 in 2025) and $1,000,000. The minimum home equity limit will continue to increase based on CPI-U increases until it reaches $1,000,000. For homes on land zoned for agricultural use, the same minimum limit imposed for non agricultural homes and described in section 1917(f)(1)(A) of the Act will apply and will continue to increase based on CPI-U increases until it reaches $1,000,000. However, states will be permitted to elect a maximum limit for homes on land zoned for agricultural use that is effectively the current maximum limit ($1,097,000 for 2025, as described above, and subject to CPI-U increases year to year), and this maximum limit will continue to increase based on CPI-U increases in lieu of the $1,000,000 cap that will apply to non-agricultural homes. Section 71108 also amends sections 1902(e)(14)(D)(iv) and 1902(r)(2) of the Act to prohibit states from using a methodology to determine home equity value that effectively raises the limits above those mandated by section 1917(f)(1). Section 1917(f)(1) of the Act, as amended by section 71108, is applicable to all states, the District of Columbia, and the territories. 12 CMS State Medicaid Director Letter #14-001, “Application of Liens, Adjustments and Recoveries, Transfer of Asset Rules and Post-Eligibility Income Rules to MAGI Individuals,” page 5, available at https://www.medicaid.gov/federal-policy-guidance/downloads/SMD-14-001.pdf 13 See U.S. Bureau of Labor Statistics, available at https://www.bls.gov/cpi/ 14 CMCS Informational Bulletin, November 15, 2024, “2025 SSI, Spousal Impoverishment, and Medicare Savings Program Resource Standards,” available at https://www.medicaid.gov/federal-policy-guidance/downloads/cib11152024.pdf 15 Section 1917(f)(1)(B) of the Act. 16 Note that Section 71108 creates new and different home equity-related treatment for homes on land zoned for agricultural use and homes that are not.