SR 17-03 Dated 09/17

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION – Division of Family Assistance (DFA)

 

FROM OFFICE OF THE DIRECTOR, DFA:

Terry R. Smith

DFA SIGNATURE DATE:

September 15, 2017

FROM OFFICE OF THE DIRECTOR, OMBP:

Deborah Fournier Esq.

OMBP SIGNATURE DATE:

September 18, 2017

AT (OFFICE):

Division of Family Assistance (DFA)

TO:

District Office Supervisors

SUBJECT:

Asset Verification System (AVS) for electronically verifying resources available to applicants/recipients of medical assistance based on age, blindness, or disability including Old Age Assistance, Aid to the Needy Blind, Aid to the Permanently and Totally Disabled, Medicaid for Employed Adults with Disabilities, Qualified Medicare Beneficiary, and Specified Low-Income Medicare Beneficiary; Asset Verification System (AVS) for electronically compiling information regarding assets for determination of whether asset transfers occurred in 5 years prior to applications for Nursing Facility or Home and Community Based Care.

EFFECTIVE DATE:

September 15, 2017

 

SUMMARY

 

This SR releases policy regarding the Asset Verification System (AVS) for electronically verifying resources available to applicants/recipients of medical assistance based on age blindness or disability including Old Age Assistance (OAA), Aid to the Needy Blind (ANB), Aid to the Permanently and Totally Disabled (APTD), Medicaid for Employed Adults with Disabilities (MEAD), Qualified Medicare Beneficiary (QMB), Specified Low-Income Beneficiary (SLM/SLMB135), Nursing Facility (NF), and Home and Community Based Care (HCBC).

 

FORMER POLICY

NEW POLICY

Applicants and Recipients of categories of medical assistance which have a resource test were required to submit third party paper verification of the applicants’ or recipients’ resources e.g. bank statements.

A new Asset Verification System is in place to electronically verify resources available to applicants or recipients of OAA/ANB/APTD

MEAD/QMB/SLMB/SLMB135/NF/HCBC categories of medical assistance. The electronic information will be used to verify an applicant or recipient’s resource eligibility as long as it indicates the applicant or recipient is below the resource limit and reported all the resources in the applicant or recipient’s possession. For an applicant or recipient whose resources cannot be electronically verified paper verification of resources will be requested and verification of resources will follow existing policy

 

All other categories of medical assistance are unaffected by this change because no other category has a resource test.

Applicants for NF and HCBC services were required to submit 60 months of financial records to verify that there were no asset transfers for less than Fair Market Value

When an applicant applies for NF or HCBC services, AVS will request 60 months of financial records from Financial Institutions. Workers will use the electronic data returned by AVS to determine if assets were transferred for less than Fair Market Value. Whenever AVS responses show possible transfers for less than Fair Market Value, paper verification of all resources and transfers for the past 60 months will be requested.

 

BACKGROUND

 

The Supplemental Appropriations Act of 2008 requires states to implement a program to electronically verify resources owned by applicants or recipients of OAA/ANB/APTD/MEAD/QMB/SLMB/SLMB135/NF/HCBC and held in financial institutions when determining eligibility for medical assistance based on age, blindness, or disability. DHHS has contracted with Accuity to provide an Asset Verification System (AVS) for applicable categories of medical assistance. New HEIGHTS will automatically request AVS at application or redetermination for applicable categories. Once Accuity receives an AVS request, Accuity will call Financial Institutions (FI) that the applicant or recipient had disclosed and other FIs determined by an algorithm to detect undisclosed resources. Accuity will provide lists of an applicant or recipients electronically verified resources within 15 days of the AVS request. New HEIGHTS will save and display the AVS responses.

 

POLICY

 

The AVS is used to verify resources that an applicant or recipient discloses and to conduct a random search for undisclosed resources owned by the applicant or recipient of OAA/ANB/APTD/MEAD/QMB/SLMB/SLMB135/NF/HCBC categories of medical assistance.

 

AVS requests will be automatically sent out at:

●

Initial eligibility determinations; and

●

Subsequent redeterminations.

 

Workers will need to manually request AVS verification of an applicant or recipient’s resources when:

●

Conflicting information is discovered; or

●

An applicant or recipient reports a change that would affect whose resources would count for eligibility. (For example a recipient could report that the recipient is now living with a spouse and that spouse’s resources could count towards the recipient’s continued eligibility).

 

AVS responses will be received from the vendor within 15 days of the AVS request.

 

AVS responses are adequate verification of an applicant or recipient’s resources when:

●

The AVS responses indicate the applicant and recipient is within the resource limit for the category they are applying; and

●

The applicant or recipient disclosed all the resources that appeared in the AVS responses. The value the applicant or recipient indicated at application or interview need not match the AVS response exactly. Example: An applicant or recipient who discloses that they have a Bank of America checking account with $250 and the AVS responses indicate the applicant or recipient has a Bank of America checking account with $230. The applicant or recipient would be considered to have disclosed all the resources that appeared in the AVS responses.

 

Workers will request paper verification of an applicant or recipient’s resources when the applicant or recipient:

●

Did not disclose all the resources the AVS responses contained, for example if AVS responses indicated the applicant or recipient has a savings account that was not mentioned at application; or

●

Has more resources than the resource limit for any program of assistance the applicant or recipient is applying for or receiving.

 

Cases Receiving Assistance From Other Programs

 

When an AVS response is received for an AG that has applied for or received OAA/ANB/APTD/QMB/SLMB/MEAD the AVS response will verify the AG’s resources for other programs as well if the AG is below applicable resource limits. Generate a letter to request paper verification of resources if the AVS report indicates an AG is above a resource limit for any of the programs of assistance the AG applied for. Applicants and recipients cannot be denied eligibility for any program based solely on the AVS response.

 

Example: A person already receiving SSDI and Medicare applies for QMB/SLMB medical assistance and Food Stamps. An AVS request is generated to verify the person’s resources because they applied for QMB/SLMB. The AVS response indicates that the person has $3,750 in resources. Even though the person is below the QMB/SLMB resource limit of $7,390, paper verification of the person’s resources must be requested because the AVS response indicates the applicant is over the Food Stamp resource limit of $3,250.

 

Transfer of Assets for Less Than Fair Market Value

 

LTC Workers will use AVS responses to examine whether an applicant for NH or HCBC transferred assets for less than Fair Market Value. For Long Term Care – AVS will provide the worker with monthly balances on all accounts as of the 3rd of each month for the 60 months prior to the application. The workers will review the account balances and determine if there are any questionable transfers based on the balances each month. If there appears to be a questionable transfer the worker would generate a letter requesting paper verification for the 60 month period.

 

Note: AVS will not do a lookback for trusts if the trust has a separate Employer Identification Number (EIN).

 

NEW HEIGHTS SYSTEMS PROCEDURES AND IMPLEMENTATION

 

Liquid Resource Screen

 

The Liquid Resource Screen now allows workers to lookup existing Financial Institutions (FI) from the list of FIs that AVS requests from. Workers click the Find button and use the Bank Search pop-up to scroll and select the FI that the applicant or recipient indicates (the state defaults to New Hampshire but another can be selected). A portion of the bank name can also be entered in the pop-up. If the FI indicated by the applicant or recipient is not in the AVS system the worker will select the Bank Not Found button, which will save the text entered into the bank search pop-up.

 

Dashboard Update

 

Workers and Supervisors will now see the number of AVS responses that have been received on the Dashboard. A Checkbox next to the AVS responses received will allow workers to navigate to the new Asset Verification screen from the Dashboard.

 

Asset Verification Screen

 

A new Asset Verification screen under the Data Exchange menu will be used to display responses received from the AVS. Workers will be able to navigate to this screen directly from the AVS responses on the Dashboard or through the Data Exchange menu.

 

The summary tab will display a row of information for each FI that returned information for an applicant or recipient. The information includes the date the response was received, the FI name, the date AVS was requested and received, and the name of the account holder. The details tab will display the account balances for the period of time requested. For individuals applying for AVS categories other than NF or HCBC care, AVS will request the most recent 3 months of resource information. The details tab will also contain account numbers, account balances, account types (e.g. checking), and whether an account is jointly held, and the names of all account holders.

 

From the details tab workers will be able to select a Data Entry button. The Data Entry button will open the liquid resources screen and allow workers to compare the information returned by AVS with the information the applicant or recipient reported. Workers will need to select Verified through Data Exchange checkbox on the liquid resources screen unless paper verification of the resources are requested.

 

The details tab contains a Mail Letter button. The mail letter button is used when an applicant or recipient’s resources cannot be verified by AVS responses, either because AVS responses indicate that the applicant or recipient is above the resource limit or the applicant or recipient has resources the applicant or recipient did not disclose. When a worker selects this button a letter for the applicant or recipient will be generated. Workers can select online print which will open a PDF of the letter in the worker’s browser or batch which will generate and mail the letter in the daily batch process.

 

Manual Requests

 

Workers will now be able to manually request AVS responses from the existing DX Manual Request Screen. Workers will need to use this request if there is a change reported that would affect whose resources affect an applicant or recipient’s eligibility for medical assistance. Workers will be able to request verifications of an applicant or recipient’s resources for the past 1 month, 3 months, or 60 months. Manual requests will only be available for individuals applying for or receiving medical assistance. Manual requests should only be used for individuals applying for or receiving OAA/ANB/APTD/MEAD/QMB/SLMB/SLMB135/NF/HCBC categories of medical assistance. The 60 month resource verification request should only be used for individuals applying for or receiving NF/HCBC.

 

DESCRIPTION OF REVISIONS MADE TO FORMS

 

DFA Forms 800 and 800R were revised to include changes to implement a new Food Stamp Internet Standard Utility Allowance in addition to implementing the Asset Verification System. See SR 17-05 for more information regarding the Internet SUA. DFA Form 800 and 800R do not appear in the Forms Manual Posting Instructions because the revised versions of those forms were released through SR 17-05.

 

DFA Form 800, Application for Assistance, was revised as follows:

●

Internet (including mobile) was added to section G on page 4 along with checkboxes for yes or no;

●

In the Social Security Number section on page 1 language was added to say DHHS will share SSNs to verify other benefits received by an individual;

●

Giving us an SSN is optional for persons who are not applying for assistance. Giving us an SSN can save you time and money getting needed verifications. was added to the SSN section on page 1 to explain that DHHS using an individual’s SSN to obtain verifications could be faster and cheaper than the individual providing necessary paper verifications;

●

The possible EBT card statuses in the Agency Use Only section on page 4 was updated to reflect the EBT card statuses that a worker might see when checking EBT EDGE; and

●

The statements of understanding were updated to have the applicant acknowledge that DHHS may have a contracted third party obtain necessary verifications.

 

DFA Form 800Q, Assisted Application for Help with Medicare Costs Through the Medicare Savings Program, was revised to include that SSNs will be shared with contracted third parties.

 

DFA Form 800R, Application for Continued Eligibility for Financial, Medical, Child Care, and Food Stamp Benefits, was revised as follows:

●

Internet (including mobile data) was added to the Special Food Stamp Income Deductions section of the Checklist of Required proof on page 2;

●

A box for individuals to report internet expenses was added to section 7 on page 4; and

●

A statement of understanding that DHHS may share SSNs with contracted third parties was added to the list of statements of understanding on page 6.

 

DFA Form 771A, Nursing Facility Care Renewal, was revised to remove requirement that recipients include resource verification and add a statement of understanding that DHHS will share SSNs with contracted third parties to verify income and resource eligibility.

 

All forms identified in this SR are available in the DHHS Warehouse and can be ordered using current forms reordering procedures, via the Quarterly Forms Order (QFO). The forms are also available electronically, for Department staff only, in the Family Services Folder on the N Drive.

 

POLICY MANUAL REVISIONS

 

Revised Medical Assistance Manual Topics

 

PART 409                                       VERIFICATION

 

IMPLEMENTATION

 

All policies in this SR are effective September 15, 2017.

 

All forms identified in this SR are available in the DHHS Warehouse and can be ordered using current forms reordering procedures, via the Quarterly Forms Order (QFO). The forms are also available electronically, for Department staff only, in the Family Services Folder on the N Drive.

 

CLIENT NOTIFICATION

 

No special client notification is planned or needed.

 

TRAINING

 

The DCS Training Unit conducted a webinar for workers on the Asset Verification System, Disability Determination Unit enhancements, and real time eligibility on September 8, 2017.

 

FORMS MANUAL POSTING INSTRUCTIONS

 

Remove and Destroy

 

Insert

Forms Manual

 

  

DFA Form 771A,
Nursing Facility Care Renewal,
DFA SR 07-12/April, 2007
3 back-to-back sheets

DFA Form 771A,
Nursing Facility Care Renewal,
DFA SR 17-03/September, 2017
3 back-to-back sheets

DFA Form 800Q,
Assisted Application For Help With Medicare Costs Through The Medicare Savings Program,
DFA SR 11-40/October, 2011
2 back-to-back sheets

DFA Form 800Q,
Assisted Application For Help With Medicare Costs Through The Medicare Savings Program,
DFA SR 17-03/September, 2017
2 back-to-back sheets

 

DISPOSITION

 

This SR may be destroyed or deleted after its contents have been noted and 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 DFA 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 www.dhhs.nh.gov/DFA/publications.htm, effective October 30, 2017. Additionally, this SR, and printed pages with posting instructions, will be distributed under separate cover to all internal hard copy holders of the Medical Assistance, and Forms Manuals.

 

DFA/BDC:s