SR 19-04 Dated 06/19

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION – BUREAU OF FAMILY ASSISTANCE (BFA)

SUMMARY

This SR releases more policy regarding the requirement that non-exempt Granite Advantage recipients complete 100 hours of community engagement activities per month including:

• What activities count towards the community engagement requirement;

• Good causes for not meeting the community engagement requirement; and

• Reasonable modification of the community engagement requirement.

This SR builds upon existing Granite Advantage community engagement policy released in BFA SR 19-03. SR 19-15 will be released in June with policy regarding curing non-compliance with the community engagement requirement, suspension of Granite Advantage benefits for failure to comply with the community engagement requirement, termination of Granite Advantage benefits for failure to comply with the community engagement requirement, and reactivation of benefits after suspension.

BACKGROUND

The Affordable Care Act (ACA) and implementing regulations at 42 CFR 435.119 mandated Medicaid-funded health coverage for a new adult group of non-disabled, non-pregnant individuals who were between the ages of 19-64 and were not eligible for Medicare. A Supreme Court decision made coverage of the newly eligible adult group optional for states. New Hampshire decided to cover the newly eligible adult group and called the group the New Hampshire Health Protection Program (NHHPP/NHHPP-M).

New Hampshire has replaced NHHPP with the Granite Advantage Health Care Program (Granite Advantage). Granite Advantage will cover newly eligible adults aged 19-64 who are not eligible for Medicare like NHHPP, but will be subject to additional requirements described in this SR, SR 19-03 which was released in February, and SR 19-15 which will be released in June.

POLICY

Immediate Family Member

Immediate Family Member is a spouse, child, mother-in-law, father-in-law, parent, step-parent, step-children, step-siblings, grandparents, grandchildren, siblings, legal guardians, daughter-in law, son-in-law, brother-in-law, sister-in-law, or foster child.

Community Engagement Activities

Recipients must complete the community engagement requirement by doing 100 hours of any of the following activities in a calendar month:

• Basic Education;

• Caregiving;

• College;

• Community or Public Service;

• Employment;

• Job Search/Job Training;

• Job Skills Training Related to Employment;

• Education Related to Employment;

• Participation in TANF, SNAP, or ORR Work Requirements;

• Self-Employment;

• Substance Use Disorder Treatment;

• Vocational Education.

Recipients must report completion of community activities by the 7^th of the month following the month in which the activities were completed. For example, a recipient must report 100 hours of community engagement activities done in June by July 7^th.

Basic Education

Basic Education is any education that is considered secondary education leading to a high school diploma or equivalent certificate including but not limited to the following:

• general educational development (GED) programs;

• remedial or adult basic education programs;

• high school diploma programs;

• alternative educational high schools; and

• Special programs for learning disabled individuals.

Recipients must verify enrollment in a basic education course. Acceptable documentation would include any documentation from the school showing the recipient is enrolled in a basic education program. Recipients can report basic education by submitting BFA Form 321, Reporting Education Participation for Community Engagement.

Recipients enrolled in basic education will automatically be credited with 100 hours per month of community engagement activities for every month they are attending the basic education program.

Caregiving

Caregiving is caring for any disabled person who is not an immediate family member that the recipient lives with. Recipients must verify hours spent caring for a disabled person by submitting the information on NH EASY or using BFA Form 320, Reporting Monthly Participation in Community Engagement Activities. The documentation must include self-attestation of the hours of care provided and the name and contact information of the person needing care. If a recipient reports caring for a disabled immediate family member that resides in the recipient’s household, the recipient can request an exemption from the community engagement requirement or good cause for not meeting the community engagement requirement.

College or University

A recipient will receive credit for community engagement when the recipient is enrolled at an accredited college or university. For college courses to count towards community engagement a college must be accredited. See https://www.neche.org/institutions/nh/ for a list of accredited colleges and universities in New Hampshire. See https://ope.ed.gov/dapip/#/home for a database of all accredited colleges and universities. The recipient does not need to be attending classes in person. Recipient can report attending a college or university by submitting BFA Form 321, Reporting Education Participation for Community Engagement.

Recipients must verify enrollment at an accredited college or university by providing a copy of the recipient’s class schedule that includes the total credit hours, the semester start date, and the semester end date. Community engagement credit is based on the number of credit hours the recipient is enrolled in not the total number of hours the recipient spends in class or studying. Recipients will get credit for community engagement for the month equal to the recipient’s total number of credit hours multiplied by 4.33.

Community, Public, or Volunteer Service

Volunteer community or public service work that can be tracked and reported counts as an activity. Volunteer work for political organizations or campaigns does not count towards the community engagement requirement. Community or public service does not need to be done for an organization. For example, a recipient who rakes his or her neighbor’s leaves can get credit for community or public service. A recipient must self-attest to verify community, public, or volunteer service which can be done electronically on NH EASY or by providing BFA Form 320 Reporting Monthly Participation in Community Engagement Activities Granite Advantage Health Care Program, which must include the name of the agency the recipient volunteered for, the name of a contact person for the volunteer agency, the hours that the recipient volunteered for, and the recipient’s signature.

Employment

Employment includes subsidized work, unsubsidized work, and on-the-job training. Recipients must report any employment income and average hours worked at application and redetermination. For any recipient that reports being employed at application or redetermination, the recipient will get community engagement credit equal to the average number of hours the recipient reports working per month.

Additional Employment

Recipients that experience a change in income must report the change within 10 days. Recipients that work more than the recipient’s normal schedule without a change in income may report additional hours worked. Recipients can only report additional employment hours for two consecutive months. Recipients that report additional employment hours for 3 consecutive months must report a change in employment.

Self-Employment

Self-employment is when a recipient owns their own business (e.g. sole proprietor) or works independently (e.g. driving for Uber or Lyft). Unlike traditional employment, those who are self-employed will  not receive a W-2. Recipients must report all income at application and redetermination. Self-employment income only includes profit, which is revenue minus business expenses. The system will credit the recipient with community engagement hours equal to their reported monthly self-employment income divided by the federal minimum wage of $7.25/hour. Recipients do not need to provide additional documentation beyond what is required at application or redetermination.

Additional Self-Employment

Recipients can report additional hours above the average and verify the additional hours through self-attestation. Recipients can self attest to additional hours if or when their hours are more than what is calculated based on their net profit. For example, this may be the case for someone who is starting a new business. Recipients that have a change in self-employment income must report the change within 10 days.  

Job Search/Job Readiness

Job Search or Job Readiness is participating in job search or job trainings offered through the New Hampshire Employment Security, Granite Workforce, Work Ready New Hampshire, or other job readiness assistance programs such as the Workforce Innovation and Opportunity Act (WIOA). Recipients can report job search or job readiness by submitting BFA Form 320, Reporting Monthly Participation in Community Engagement Activities.

Job Skills Training Related to Employment

Job skills training related directly to employment counts towards the community engagement requirement. Recipients that report doing job skills training related to employment must provide documentation of enrollment in the job skills training program. Recipients can report job skills training related to employment by submitting BFA Form 321, Reporting Education for Community Engagement.

Education Related to Employment

Education related directly to employment counts towards the community engagement requirement. Only recipients without a high school diploma or equivalent will have education related to employment counted towards the community engagement requirement. Recipients that report doing education related to employment must provide documentation of enrollment in the education program. Recipients can report education related to employment by submitting BFA Form 321, Reporting Education for Community Engagement.

Participation in TANF, SNAP, or ORR Work Requirements

Meeting TANF, SNAP, or refugee assistance work requirements counts towards the community engagement requirement. Recipients who meet TANF, SNAP, or refugee assistance work requirements during a month will get credit for 100 hours of community engagement activity participation. Participation in refugee assistance will count towards the community engagement requirement for 12 months after a refugee is admitted into the United States. For refugees who have been in the United States for more than 12 months, participation in an refugee assistance work requirement will not count towards the Granite Advantage community engagement requirement. Refugees that have been in the United States for more than 12 months can still be credited 100 hours of community engagement if they are meeting a SNAP or TANF work requirement.

Substance Use Disorder Treatment

Participation in ASAM Level 1 outpatient substance use disorder services, including medication assisted treatment, and recovery supports, counts towards the community engagement requirement. Recipients must report the number of hours participated in these services up to 40 hours per month. Note that if the recipient is participating in more than 40 hours a month of outpatient substance abuse disorder treatment they may qualify for an exemption due to receiving more intensive treatment than ASAM Level 1 services. Recipients can report substance use disorder treatment by submitting BFA Form 321, Reporting Monthly Participation in Community Engagement Activities.

Vocational Education

Vocational Training means instruction conducted at an institutional or worksite setting to provide or upgrade the technical skills required to perform a specific job or group of jobs by a participant, including:

• Job Specific competency training;

• Job Specific School-to-Work programs;

• On-Site industry specific training;

• Customized training;

• Entrepreneurial training;

• Cooperative education; or

• Professional and Vocational Education.

Vocational Training can only count towards a recipient’s community engagement requirement for a maximum of 12 months. Vocational Training does not count towards the 100-hour community engagement requirement for any recipient who has had Vocational Training count towards the monthly community engagement requirement for 12 or more months. Recipients can report vocational education by submitting BFA Form 321, Reporting Education Participation for Community Engagement.

Good Cause for not Complying with the Community Engagement Requirement

Recipients that cannot meet the community engagement requirement because of circumstances beyond their control may request a good cause to have hours credited towards their community engagement requirement. Recipients can also request a good cause to have hours credited towards curing a failure to comply with the community engagement requirement or reinstating Granite Advantage benefits after suspension. The following are good causes:

• Birth or Death of a Family Member;

• Disability;

• Disability of an Immediate Family Member;

• Family Emergency;

• Family or Domestic Violence;

• Homelessness or Unstable Housing;

• Hospitalization;

• Hospitalization or Illness of a Family Member;

• Inclement Weather;

• Lack of Child Care; and

• Other Circumstances Beyond the Recipient’s Control.

All recipients may request a good cause by completing BFA Form 340 Good Cause Request Form Granite Advantage Program. The form can be found online on the DHHS and NH EASY websites, by calling DHHS Customer Service or by asking in person at a district office.  The form can be submitted online, by mail, fax, or dropping it off at the local district office. The number of hours credited, whether a third party documentation is required, and what information needs to be included will vary based on the type of good cause requested.

Birth or Death of a Family Member

Recipients that experience the birth or death of a family member can request a good cause for not meeting the community engagement requirement. The recipient can verify the good cause by self-attesting to the birth or death. The documentation must include the name of the family member, the date of the birth or death, the familial relationship to the recipient, and the number of days the birth or death prevented the recipient from participating. The recipient will be credited 8 hours of community engagement activity for each day the recipient was unable to participate.

Disability

Recipients who are disabled but have not requested an exemption from the community engagement requirement may request a good cause for not meeting the community engagement requirement whenever the recipient’s disability prevents the recipient from meeting the community engagement requirement. Recipients that request a good cause due to disability must submit documentation from a licensed medical provider that the recipient could not participate due to the disability. The documentation should include the days the disability prevented the recipient from participating. If the documentation does include specific days, the recipient will be credited 8 hours of community engagement activities for each day they were prevented from participating. If the documentation does not contain specific days the recipient was prevented from meeting the community engagement requirement, the recipient will be assumed to have been unable to participate for the entire month and will be credited for 100 hours of community engagement activities for the month.

Disability of a Relative

Recipients who are caring for a disabled immediate family member they live with may request a good cause for not meeting the community engagement requirement when the disability of the immediate family member prevents the recipient from meeting the community engagement requirement. Recipients that request a good cause due to the disability of an immediate family member must submit documentation from a licensed medical provider that the recipient could not participate due to the immediate family member’s disability. The documentation should include the days the recipient was prevented from participating. If the documentation does contain specific days, the recipient was prevented from participating the recipient will be credited 8 hours of community engagement activities for each day the recipient was unable to participate. If the documentation does not contain specific days the recipient was prevented from participating, the recipient will be assumed to have been unable to participate for the entire month and will be credited for 100 hours of community engagement for the month.

Family Emergency

Recipients that experience a family emergency, such as a divorce, can request a good cause for not meeting the community engagement requirement. The recipient can verify the good cause by self-attesting to the family emergency. The documentation must include a description of the family emergency and the number of days the family emergency prevented the recipient from participating. The recipient will be credited 8 hours of community engagement activity for each day the recipient was unable to participate.

Family or Domestic Violence

Recipients that experience family or domestic violence may request a good cause for not meeting the community engagement requirement. The recipient can verify the good cause by self-attesting to the family or domestic violence or submitting a court order. The documentation must include the number of days the recipient was prevented from meeting the community engagement requirement. The recipient will be credited 8 hours of community engagement activity for each day the recipient was unable to participate.

Homelessness or Unstable Housing

Recipients that experience homelessness or unstable housing may request a good cause for not meeting the community engagement requirement. The recipient must verify the homelessness or unstable housing through self-attestation. The documentation must include the number of days the recipient was prevented from meeting the community engagement requirement. The recipient will be credited 8 hours of community engagement activity for each day the recipient was unable to participate.

Hospitalization

Recipients that experience an inpatient hospitalization can request a good cause for not meeting the community engagement requirement. The recipient must verify the hospitalization with third party documentation. Any recipient that experiences an inpatient hospitalization will be credited 100 hours of community engagement activity for any month(s) in which the recipient is hospitalized.

Hospitalization or Illness of an Immediate Family Member

Recipients who live with an immediate family member that experience an inpatient hospitalization or illness can request a good cause for not meeting the community engagement requirement. The recipient must verify the hospitalization with third party documentation. The request for good cause must include how many days the recipient was prevented from participating. The recipient will be credited 8 hours of community engagement activities per day the recipient was unable to participate.

Inclement Weather

Recipients who experience inclement weather including natural disaster can request a good cause for not meeting the community engagement requirement. The good cause applies even if the inclement weather did not prevent transportation to a worksite. For example, if a golf course tells an employee not to come in because of rain the employee would be able to claim an inclement weather good cause even if the recipient could have traveled to the golf course. The recipient must verify the good cause through self-attestation. The documentation must include the dates the recipient was prevented from participating. The recipient will be credited 8 hours for each day the recipient was unable to participate.

Lack of Child Care

Recipients who are parents or caretakers of children aged 6-12 who are unable to obtain child care can request a good cause for not meeting the community engagement requirement. The recipient must verify the good cause through self-attestation. The documentation must include the number of days the recipient was prevented from participating. The recipient will be credited 8 hours of community engagement activities per day the recipient was prevented from working. Recipients who are parents of a child younger than 6 or a child older than 12 with a developmental disability can request an exemption from the community engagement requirement.

Other Circumstances Beyond the Recipient’s Control

Recipients who experience circumstances outside their control that prevent them from meeting the community engagement requirement can request a good cause. For example, a recipient who is unable to get transportation to meet the community engagement requirement can request a good cause for circumstances beyond the recipient’s control. Recipients can also request good cause when an illness or outpatient hospitalization prevents them from participating. The recipient must verify the good cause through self-attestation. The documentation must include the number of days the recipient was prevented from participating. The recipient will be credited 8 hours for each day the recipient was unable to participate.

Reasonable Modification of Community Engagement Requirement

Recipients with a disability can request reasonable modification of the community engagement requirement. Reasonable modifications include a reduction in the 100-hour monthly community engagement requirement. All reasonable modifications must be approved by a supervisor.

NEW HEIGHTS & NH EASY SYSTEMS PROCEDURES AND IMPLEMENTATION

The New HEIGHTS and NH EASY changes described below are in addition to changes described in SR 19-03.

On the last day of each month the New HEIGHTS System will run a batch process to determine if Granite Advantage recipients who are mandatory or voluntary for community engagement are completing any activities the system can verify without additional information from the recipient. The New HEIGHTS system will display the calculated hours for the following activities on the first of the month. New HEIGHTS will automatically check for:

• Employment;

• Self-employment;

• SNAP/TANF/Refugee work program participation; and

• Education (Note: The New HEIGHTS system does not check for entered on the Education screen; the system only checks for education that the client has reported and verified using BFA Form 321).

All other activities will require recipients to submit documentation of hours worked during the month. Hours for the system verified activities will automatically appear on the new Activity Tracking screen without worker intervention.

A new Activity Tracking Screen will be accessible under the Granite Advantage header in the work program menu. The Activity Tracking Screen can be accessed from the Customer Service Dashboard under Work Programs. The page will display a 12-month timeline at the top of the screen that will show whether for each month the recipient complied with the community engagement requirement, cured a non-compliance, is considered non-compliant for that month, was suspended for that month, is currently reporting for that month, or if tracking wasn’t required for the month i.e. during a notice period, exemption, or a month before community engagement had started. On June 1, this 12 month time line will show August through May as N/A and June will say reporting. After July 7, June will be marked compliant or turn orange and say non-compliant. Workers will be able to use the screen to add new activities/good cause the recipient reports, see existing activities/good cause details, such as hours completed and contact information for documentation and add hours to an existing activity/good cause.

NH EASY has been updated with an activity tracking function that will allow users to add and edit activities for the current month and the previous month if within the first 7 days of the month. NH EASY users will also be able to request forms for activity reporting, good cause, or exemption request. NH EASY will also allow users to self-attest to any activity or good cause exemption that can be verified through self-attestation.

DESCRIPTION OF NEW FORMS

Activity Documentation Form

New BFA Form 320, Reporting Monthly Participation in Community Engagement Activities, is a one-page single-sided form that recipients will use to verify the hours they have completed in a monthly community activity, such as volunteer work, caregiving, Substance Use Disorder treatment, additional self-employment hours, or Job Search activities. The form has been formatted with a bar code that allows the form to be read by an OCR machine. The barcode will contain “9999999999” or the recipient’s MID number. Forms that can be read by the OCR machine will have the information automatically updated into the New HEIGHTS system. Forms that are unreadable by the OCR machine will be sent to the worker’s inbox and the worker will have to manually input information from the form.

Education Participation Documentation Form

New BFA Form 321, Reporting Education Participation for Community Engagement, is a one-page single-sided form that recipients will use to provide information regarding ongoing community engagement activities, such as vocational training, college, high school or other basic education activity. The form has been formatted with a bar code that allows the form to be read by an OCR machine. The barcode will contain “99999999999” or the recipient’s MID number. Forms that can be read by the OCR machine will have the information automatically updated into the New HEIGHTS system. Forms that are unreadable by the OCR machine will be sent to the worker’s inbox and the worker will have to manually input information from the form.

Good Cause Request Form

New BFA Form 340, Good Cause Request Form Granite Advantage Health Care Program, is a three-page double sided form that recipients will uses to request and verify a good cause for not meeting the community engagement requirement. Both sides of the first page are used by the recipient to request a good cause and verify the good cause if the good cause only requires self-attestation for documentation. The second page can be completed by a medical provider to verify good cause related to a recipient or recipient’s family member’s disability. The last page contains descriptions of the various types of good causes. The form has been formatted with a bar code that allows the form to be read by an OCR machine. The barcode will contain “99999999999” or the recipient’s MID number. Forms that can be read by the OCR machine will have the information automatically updated into the New HEIGHTS system. Forms that are unreadable by the OCR machine will be sent to the worker’s inbox and the worker will have to manually input information from the form.

The forms are available electronically, for Department staff only, in the Family Services Folder on the N Drive. Anyone may access the form on NH EASY even without an EASY account at https://nheasy.nh.gov/#/granite-advantage/resources/notices.

POLICY MANUAL REVISIONS

Revised Medical Assistance Manual Topics

Section 230.09    Community Engagement Activities

Section 230.09    Community Engagement Activities: Basic Education

Section 230.09    Community Engagement Activities: Caregiving

Section 230.09    Community Engagement Activities: College

Section 230.09    Community Engagement Activities: Community or Public Service

Section 230.09    Community Engagement Activities: Education Related to Employment

Section 230.09    Community Engagement Activities: Employment

Section 230.09    Community Engagement Activities: Job Search

Section 230.09    Community Engagement Activities: Job Training Related to Employment

Section 230.09    Community Engagement Activities: Participation in TANF, SNAP or ORR Work Requirements

Section 230.09    Community Engagement Activities: Self-Employment

Section 230.09    Community Engagement Activities: Substance Use Disorder (SUD) Treatment

Section 230.09    Community Engagement Activities: Vocational Education

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Birth or Death of a Family Member

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Disability

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Disability of an Immediate Family Member

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Family Emergency

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Family or Domestic Violence

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Homelessness or Unstable Housing

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Hospitalization

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Hospitalization of a Family Member

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Inclement Weather

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Lack of Child Care

Section 230.11    Good Cause for Not Complying with Community Engagement Requirement: Other Circumstances Beyond the Recipient’s Control

Section 230.17    Reasonable Modification of Community Engagement Requirement

GLOSSARY         Glossary I-Words

IMPLEMENTATION

All policies mentioned in this SR are effective June 1, 2019.

The forms are available electronically, for Department staff only, in the Family Services Folder on the N Drive. Recipient may access the forms through NH EASY.

RECIPIENT NOTIFICATION

At the end of September, all NHHPP/NHHPP-M recipients were sent a one page notice that NHHPP would be transitioning to Granite Advantage. The notice explained that Granite Advantage would have care delivered through Managed Care Organization instead of Qualified Health Plans. The notice also warned that Granite Advantage would have a community engagement requirement beginning in April with basic information on exemptions and activities. In January, Granite Advantage recipients were sent another letter informing them the Granite Advantage community engagement requirement had been postponed to March and would begin, after a notice period, in June.

In March, each recipient currently enrolled in Granite Advantage was sent an initial mailing with a letter and various forms depending on the recipient’s community engagement status. Recipients determined mandatory for community engagement, meaning the system could not verify an exemption automatically, were sent a letter explaining mandatory status and how to request exemptions, BFA Form 310 Things You Need to Know, and BFA Form 330 Exemption Request Form. Recipients determined mandatory for community engagement and were previously designated as medically frail in NHHPP-M were sent a letter explaining mandatory status and how to request exemptions with additional language on how to verify medical frailty, BFA Form 310 Things You Need to Know, BFA Form 320A, Recipient Authorization for Release of Protected Health Information, and BFA Form 331, Licensed Medical Provider Certification of Medical Frailty.

The Department held a series of public forums on Granite Advantage at various locations in the state throughout the months of November through January.

For several months the home webpage for DHHS has had a link to information on Granite Advantage. https://www.dhhs.nh.gov/medicaid/granite/index.htm

The Department has contracted with a customer service firm to make outgoing customer service calls to all NHHPP and Granite Advantage recipients to inform recipients about Granite Advantage program changes.

TRAINING

The Training Unit is planning a series of trainings regarding policy contained within this SR at all District Offices for the last two weeks of May.

FORMS MANUAL POSTING INSTRUCTIONS

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 BFA 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 June 3, 2019. 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.

BFA/BDC:s