SR 02-03 Dated 04/02

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION

SIGNATURE DATE:	March 29, 2002
FROM:	OFFICE OF THE DIRECTOR Mary Anne Broshek
AT (OFFICE):	Division of Family Assistance
TO:	DFA Supervisors Managers of Administration
SUBJECT:	Revised Verification Requirements and Additional Good Cause Waiver Reasons for Prior Insurance Coverage in the Healthy Kids-Silver and Children Up to Age 19 Programs
EFFECTIVE DATE:	April 1, 2002

BACKGROUND

The Department of Health and Human Services (DHHS) hosted a conference in November 2000 to reduce enrollment barriers in the NH Healthy Kids Programs.

The policy revisions described in this SR were developed over the ensuing months with the input and collaboration of the Executive Director of the Healthy New Hampshire Foundation, the Commissioner of DHHS, the Directors of the Office of Community Public Health (OCPH) and Division of Family Assistance (DFA), as well as representatives from Covering Kids-Foundation for Healthy Communities, the Bureau of Maternal and Child Health, the Office of the Medicaid Management Information System (OMMIS), and the New Hampshire Healthy Kids Corporation (NHHKC).

SUMMARY

This SR releases the following policy revisions and clarifications in the Healthy Kids-Silver and Children Up to Age 19 Programs (HKG-300, HKG-185, HKG-CH):

· a verbal declaration now satisfies verification requirements for child support income, child care expenses, and legal wage garnishments;

· a photo ID is not required when verifying identity;

· the types of documentation that can be used to verify age and NH residency have been clarified; and

· the list of good cause reasons for having had prior insurance coverage has been supplemented with five additional waivers.

POLICY

Verification

In the Healthy Kids-Silver and Children Up to Age 19 Programs (HKG-300, HKG-185, HKG-CH), a verbal declaration now satisfies verification requirements for child support income, child care expenses, and legal wage garnishments. In addition, clarifications have been made regarding what constitutes acceptable documentation when verifying age, residency, and identification. However, District Offices retain the ability to request additional documentation whenever conflicting information is discovered or if the documentation provided is questionable.

The following chart summarizes the changes:

	FORMER POLICY	REVISED POLICY
Child Support Income	Requires documentation	Verbal declaration is sufficient for the amount of child support received.
Child Care Expenses	Requires documentation	Verbal declaration is sufficient for the amount paid for child care.
Legal Wage Garnishments	Requires documentation	Verbal declaration is sufficient.
Identification	Requires any document that reasonably establishes the individual’s identity	Clarification Only: Photo ID’s are not required.
NH Residency	Requires documentation (e.g., utility receipt/phone bill, lease/rental statement, mortgage records, city/town statement)	Clarification Only (documentation is still required): Any document that reasonably establishes the individual’s residency is sufficient (e.g. correspondence, a letter from school, bills, car registration, etc.).
Child’s Age	Requires documentation (e.g., birth certificate, vital records, baptismal record w/DOB, Hospital records, Adoption/Naturalization papers)	Clarification Only (documentation is still required): Any document that establishes the child’s age, including a third-party statement, is sufficient (e.g., statement from physician, school etc.).

In a Director’s Memo dated 5/30/00, subject line "Verification of Birth and Citizenship," it was explained that at one time individuals applying for assistance who did not have a Social Security number would complete the Form SS-5, Application for a Social Security Card, at the District Office. The Form SS-5 mandated certain proofs from applicants. In March of 1998, however, the Social Security Administration (SSA) determined that District Offices could no longer complete this form with applicants. Following this change in Social Security number enumeration policy, DHHS verification requirements were made less restrictive.

Current policy states that District Office staff must verify the identity of members of the assistance group using any document that reasonably establishes the individual’s identity (see FAM 301.01, Application, and FAM 301.07, How to Verify). When verifying age, NH residency, or identity during applications for HKG and HKS medical coverage groups, it is the age, NH residency, and identity of the children in the assistance group that must be verified; guardians are not also required to provide corresponding proof of age, residency, and identity (see FAM 219.03, Required Verification, and FAM 220.03, Eligibility Requirements).

Certified copies of the children’s birth certificates and picture ID’s from the children are not required as proof. In accordance with current policy, if no formal document is available, using a collateral contact is acceptable.

Although formal documentation such as a passport or certified birth certificate continues to be acceptable forms of proof, the following chart provides examples of other types of documentation that also satisfy the requirement for proof of the child’s age, NH residency, and identity:

Acceptable proofs could include, but are not limited to, any of the following:

Age

· the guardian’s copy of the birth certificate

· third-party statement

· immunization records

· note from an attending physician, midwife, or individual present at the birth

· an entry in the family bible

Residency

· third-party statement

· note from a physician or school

· library card or car registration

· correspondence or bill bearing the name of the client

Identity

· library card

· note from a physician or school

· third-party statement

· documentation submitted as proof of age or citizenship

· correspondence bearing the name of the client

Good Cause Waivers

Children are not eligible for assistance from the HKG-300 and HKS medical coverage groups if they are currently insured or were covered within the 6 calendar months prior to the month of application by private or public health insurance, other than Medicaid or coverage that is currently available through the New Hampshire Healthy Kids Corporation (NHHKC), unless at least one of the following good cause reasons exists:

· the health insurance was terminated due to involuntary loss of employment;

· the health insurance was terminated due to voluntary quit of employment, and the voluntary quit occurred for a good cause reason (per policy);

· change of employment to an employer who does not provide dependent coverage;

· death of the subscriber parent of the insurance policy;

· discontinuation of coverage to all employees by the employer;

· discontinuation of COBRA benefits after 18 months for job termination or 24 months after the death of the subscriber;

· the insurer closes its operation in New Hampshire; or

· an involuntary reduction in work hours that no longer allows the subscriber parent to enroll the parent’s children under the employer’s health plan.

Effective April 1, 2002, the above list of good cause reasons for having had prior insurance coverage has been supplemented with the following additional waivers:

· temporary coverage has ended;

· the subscriber parent met other good cause reasons prior to accepting COBRA or temporary coverage;

· the subscriber parent experiences loss of coverage or an inability to use current coverage due to family/domestic violence;

· the subscriber parent has left employment to become the primary caretaker for their children who are 5 years of age or under; and

· the health insurance was terminated by a non-custodial parent and the loss of insurance was beyond the control of the custodial parent.

SYSTEMS CHANGES

As of April 1, 2002, New HEIGHTS will have added the additional good cause reasons for prior insurance coverage to the tab entitled "Covered Individuals" on the "TPL/Medical Insurance Coverage" screen, under the "Non-Financial" Function. There were no changes needed for the verification clarifications released by this SR, as the functions in New HEIGHTS are policy-driven.

FORMS REVISIONS

Form 800P, Application for NH Healthy Kids Medical Insurance or Medical Coverage for Pregnant Women, will be revised and new Form 800PR, Review For Continued Eligibility For NH Healthy Kids Medical Insurance and Medical Coverage for Pregnant Women, is being developed to incorporate the changes released by this SR. These forms will be released at a later date under separate cover.

POLICY MANUAL REVISIONS

Revised Family Assistance Manual Topics

Section 207.13 Verification

Section 219.03 Required Verification

Section 220.03 Eligibility Requirements

Section 301.07 How to Verify

Section 303.05 How to Verify Residence

Section 315.03 Good Cause for Voluntary Quit

PART 509 VERIFICATION

Section 603.05 Child/Dependent Care Deduction

Section 603.09 Other Allowable Deductions: Garnishments

Section 603.11 Verification of Deductions

IMPLEMENTATION

The changes identified in this SR will be implemented statewide beginning April 1, 2002 for current cases, and will apply to any new cases processed on or after that date.

CLIENT NOTIFICATION

No special notification is necessary. Individuals will be advised of the revised policy upon request, on an individual as needed basis, or when Healthy Kids-Gold or Healthy Kids-Silver medical coverage group benefits are requested or redetermined.

TRAINING

No special training is planned.

DISPOSITION

Please retain this SR until May 31, 2002 when the revised manual topics released by this SR have been posted to the On-Line Manuals.

DISTRIBUTION

This SR will be distributed according to the electronic distribution list for Division of Family Assistance policy releases. This SR, and revised On-Line Manuals, will be available for agency staff in the On-Line Manual Library, and for public access on the Internet at http://www.dhhs.state.nh.us/PMIndex.htm, effective May 31, 2002.

This SR, and printed pages with posting instructions, will be distributed under separate cover to all hard copy holders of the Family Assistance Manual. A copy will also be sent to New Hampshire Healthy Kids Corporation.

DFA/JBV:s