SR 21-24 Dated 5/20

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION – BUREAU of family assistance (BFA)

FROM OFFICE OF THE ADMINISTRATOR IV, BUREAU OF FAMILY ASSISTANCE (BFA):			Debra E. Sorli
BFA SIGNATURE DATE:			8/13/21
FROM OFFICE OF THE DIRECTOR, DIVISION OF MEDICAID SERVICES (DMS):			Henry Lipman
DMS SIGNATURE DATE:			8/12/21
AT (OFFICE):			Division of Economic and Housing Stability (DEHS)
			District Office Supervisors
SUBJECT:	Simplified Application Process for Non-MAGI Categories of Medical Assistance and Passive Redetermination Policy for Non-MAGI Categories of Medical Assistance
SIMPLIFIED APPLICATION PROCESS EFFECTIVE DATE:		March 31, 2020
PASSIVE REDETERMINATION EFFECTIVE DATE:		May 6, 2020

This SR releases:

Simplified application process for non-MAGI (Modified Adjusted Gross Income) categories of medical assistance (MA) that do not require a disability determination and for non-MAGI re-applications that require a disability determination but a previous approval has a future review date or no review date; and
A “passive” redetermination process for non-MAGI categories of MA for assistance groups when all eligibility factors can be electronically verified.

1. Simplified application process for non-MAGI categories with no medical or disability determination (or a previous medical or disability determination that remains valid):

The application process for non-MAGI categories of MA with no medical or disability determination (or a previous medical or disability determination that remains valid) has been simplified:

Verification relies primarily on electronic crossmatches with various data resources and on self-attestation for certain information; paper verification, if required, is provided post-eligibility;
No interview is required; and
Eligibility is based upon self-attestation. Workers will use self-attestation rules to process applications.

Exception: If any non-MAGI assistance group reports having a trust or annuity, an interview is required and the application cannot be run as a simplified application process.

Post-eligibility paper verification is required for discrepancies in any electronic crossmatches and for certain self-attestations made by the client at application. Specifically:

At the time of application and based on the information provided by the applicant, electronic verification will occur for: income, date of birth (DOB), Social Security number (SSN), citizenship/immigration status, receipt of Medicare, and incarceration status;
Citizenship/immigration status verification remains unchanged: if electronic verification cannot confirm citizenship/immigration status, the applicant is given a reasonable opportunity to provide proof;
If income that was reported by the applicant is found to be within 10% of the verified amount via electronic crossmatching, or if the difference in income exceeds 10% but the difference would not affect eligibility in any way, the information is considered reasonably compatible, and the information is immediately used in the eligibility determination process with no further verification required;
Self-attestation at the time of application with no further proof required will occur for residency, household composition, pregnancy, and application for other benefits; and
Post-application paper verification is required for discrepancies that occur during electronic crossmatching for income (such as wages and unemployment compensation benefits [UCB]), DOB, receipt of Medicare, citizenship/immigration status, and SSN.

Re-application with a previous disability or medical determination: Re-application for a non-MAGI category or service that has a previous valid disability or medical determination with a future review date or no review date is based upon self-attestation. Workers will use self-attestation rules to process re-applications.

Spenddown: For In and Out MA, if the electronic crossmatch for earned income is any amount below the self-attested amount, or up to 10% over the self-attested amount, then the self-attested amount is considered verified and will be used to calculate the spenddown. If the electronic crossmatch amount is more than 10% over the self-attested amount, a verification request will be generated to the casehead.

All changes that may impact eligibility must still be reported within 10 calendar days of the change occurring, per current policy.

2. Passive redetermination process for non-MAGI categories of MA:

The non-MAGI categories of MA included in the passive redetermination process are:

APTD (Aid to the Permanently and Totally Disabled)

ANB (Aid to the Needy Blind)

OAA (Old Age Assistance)

MEAD (Medicaid for Employed Adults with Disabilities)

MOAD (Medicaid for Employed Older Adults with Disabilities—following the 9/1/20 start of this eligibility category)

Extended MA (also called 12-month EMA)

HC-CSD (Home Care for Children with Severe Disabilities)

NHEP Med Needy and NHEP In and Out (also called Parent Caretaker Relative Medically Needy and Parent Caretaker Relative In and Out)

LTC (long-term care) services:

NF (Nursing Facility)

HCBC (Home and Community-Based Care):

HCBC-CFI (Choices for Independence)

HCBC-IHS (In-Home Supports)

HCBC-DD (Developmentally Disabled)

HCBC-ABD (Acquired Brain Disorder)

MSPs (Medicare Savings Programs):

QMB (Qualified Medicare Beneficiary)

SLMB and SLMB135 (Specified Low-Income Medicare Beneficiary)

QDWI (Qualified Disabled Working Individual)

The non-MAGI categories of MA excluded from the passive redetermination process are:

BCCP (Breast and Cervical Cancer Program)

Foster Care and Adoption Subsidy (received through the Division for Children, Youth and Families [DCYF])

Non-MAGI categories of MA will now have a “passive renewal” process similar to MAGI categories of MA if all eligibility factors can be verified by an electronic crossmatch:

If all eligibility factors for the non-MAGI case can be verified through electronic crossmatching at the regularly scheduled redetermination, and if all eligibility criteria are met, the redetermination period will be automatically advanced another 12 months:

- Notification of the new renewal date, via New HEIGHTS-generated CS0006, Rede Letter, or CS0030, Online Rede Letter, will be generated to the casehead, along with the case information that DHHS used to renew eligibility; and

- The CS0006/CS0030 includes a request that the casehead contact DHHS to report any corrections that need to be made to the information DHHS used to renew eligibility, but this information is assumed to be correct and it is not expected that corrections will be returned. A return of information is not required for the renewal process. The eligibility worker should never close any recipient for failure to return this information.

If all eligibility factors for the non-MAGI case cannot be verified through electronic crossmatching, the regularly scheduled renewal period will not be automatically advanced 12 months:

- Eligibility factors that cannot be verified through electronic crossmatching include:

§ Reported wages, unearned income, or liquid resources for which there is no crossmatch (for example, because no crossmatch is available, which may happen for wages from small employers or for liquid resources in out-of-state banks; or no response is received in the crossmatch process);

§ Reported wages or unearned income when the response from the crossmatch is not within the 10% threshold;

§ Self-employment income; and

§ Trusts, annuities, or other resources that cannot be verified by the Asset Verification System (AVS).

- Notification that eligibility could not be automatically renewed will be generated to the casehead via the CS0006/CS0027. In the CS0006/CS0027, the casehead is provided with 1) a list of required proofs and 2) the information that DHHS used to determine that eligibility could not be automatically renewed:

§ The proofs listed in the CS0006/CS0027 must be provided to DHHS by the 15^th day of the month following the date on the CS0006/CS0027. Failure to provide the requested proofs within timeframes results in termination of MA;

§ The CS0027 includes a request that the casehead review the information that DHHS used to determine that eligibility could not be renewed, and return it if corrections are needed. Non-passive MA renewal cases must correct the case information in the CS0027, sign and date the information, and return or electronically submit this packet of information, along with all required verifications, as a condition of continued eligibility for MA. Failure to return or electronically submit the signed and dated information along with all required verifications within MA renewal timeframes results in a termination of the MA case.

Spenddown: For In and Out MA, if the electronic crossmatch for income is any amount below the self-attested amount, or up to 10% over the self-attested amount, then the self-attested amount is considered verified and will be used to calculate the spenddown. If the electronic crossmatch amount is more than 10% over the self-attested amount, notification that eligibility could not be automatically renewed will be generated to the casehead via the CS0027.

If the regularly scheduled redetermination/recertification date for other programs of assistance (cash, SNAP, or NH Child Care Scholarship) aligns with the regularly scheduled renewal date for the MA case:

The notification associated with the type of redetermination/recertification scheduled for cash, SNAP, or NH Child Care Scholarship will be generated: New HEIGHTS-generated CS0001, Rede Interview, is generated if the case is scheduled for an interview; New HEIGHTS-generated CS0005, Mail-In Rede Letter, is generated if the case is eligible for a paper redetermination/recertification; New HEIGHTS-generated CS0027, Online Rede Letter, is generated if the case is eligible to complete the redetermination online;
If all eligibility factors for non-MAGI can be verified through electronic crossmatching, the regularly scheduled renewal period will be automatically advanced 12 months with no action required by the eligibility worker or the recipient; and
If all eligibility factors for non-MAGI cannot be verified through electronic crossmatching, the regularly scheduled renewal period will not be automatically advanced 12 months, and this group will additionally receive the CS0006/CS0030 requesting the specific proof needed to renew MA eligibility.

If the regularly scheduled redetermination/recertification date for cash, SNAP, or NH Child Care Scholarship does not align with the regularly scheduled MA renewal date, the MA renewal date is not impacted at all and remains unchanged.

1. Simplified application process for non-MAGI categories with no medical or disability determination (or a previous medical or disability determination that remains valid):

FORMER POLICY

NEW POLICY

For non-MAGI categories of MA, online or mail-in redeterminations were required. If a non-MAGI case failed to complete a redetermination, assistance would be terminated.

For non-MAGI categories that do not require a medical or disability determination and when the assistance group does not report having self-employment income, an annuity, or a trust:

• The application process has been streamlined and interviews are no longer required;

• Verification relies primarily on electronic crossmatching and on self-attestation for certain information; paper verification, if required, is provided post-eligibility;

• Eligibility is based upon self-attestation; eligibility workers will use self-attestation rules to process applications; and

• All changes in circumstances that may impact eligibility must still be reported within 10 calendar days of the change occurring.

Post-eligibility paper verification is required for discrepancies in any electronic crossmatches and for certain information provided by the applicant. Specifically:

• At the time of application and based on information provided by the applicant, electronic verification will occur for: income, DOB, SSN, citizenship/ immigration status, receipt of Medicare, and incarceration status;

• Citizenship/immigration status verification remains unchanged: if electronic verification cannot confirm citizenship/ immigration status, the applicant is given a reasonable opportunity to provide proof;

• If income that was reported by the applicant is within 10% of the amount verified via electronic crossmatching, or if the difference exceeds 10% but the difference would not affect eligibility, then the information is considered reasonably compatible and is immediately used in the determination process with no further verification required;

• For In and Out MA, if the electronic crossmatch for income is any amount below the self-attested amount, or up to 10% over the self-attested amount, then the self-attested amount is considered verified and will be used to calculate the spenddown. If the electronic crossmatch amount is more than 10% over the self-attested amount, a verification request will be generated to the casehead;

• Self-attestation at the time of application with no further proof required will occur for: residency, household composition, pregnancy, and application for other benefits; and

• Post-application verification is required for discrepancies that occur during the electronic crossmatch for income (such as wages and UCB), resources that exceed the limit, DOB, receipt of Medicare, citizenship/ immigration status, and SSN.

2. Passive redetermination process for non-MAGI categories of MA:

FORMER POLICY

NEW POLICY

For non-MAGI categories of MA, online or mail-in redeterminations were required. If a non-MAGI case failed to complete a redetermination, assistance would be terminated.

For non-MAGI MA, the renewal process is as follows:

No interview is required (interviews may still be requested);
If all eligibility requirements can be verified through electronic crossmatching and if income and resources remain under the income and resource limits at the regularly scheduled renewal, then the case does not need to do anything; no renewal form or proof needs to be submitted to DHHS to automatically advance the case’s renewal another 12 months;
If all eligibility requirements cannot be verified by electronic crossmatching at the regularly scheduled renewal, for example because the case has to verify self-employment income, then the case’s renewal date will not be automatically advanced another 12 months. Instead, the CS0006/CS0030 generated to the casehead will list the proof needed to verify continued eligibility. This proof must be returned to DHHS by the 15th of the month following the date on the CS0006/CS0030; and
For In and Out MA, if the electronic crossmatch for income is any amount below the self-attested amount, or up to 10% over the self-attested amount, then the self-attested amount is considered verified and will be used to calculate the spenddown. If the electronic crossmatch amount is more than 10% over the self-attested amount, notification that eligibility could not be automatically renewed will be generated to the casehead via the CS0006/CS0027.

BACKGROUND

As part of the implementation of the Patient Protection and Affordable Care Act, the process for applying for and renewing Medicaid was streamlined for certain categories that use Modified Adjusted Gross Income (MAGI) for eligibility determinations. This SR expands the streamlined application and renewal process to categories of Medicaid that do not use MAGI.

POLICY

1. Simplified application process for non-MAGI categories with no medical or disability determination (or a previous medical or disability determination that remains valid):

Interviews are no longer required;
Verification relies primarily on electronic crossmatching with various data resources and on self-attestation for certain information; paper verification, if required, is provided post-eligibility; and
Eligibility is based upon self-attestation. Workers will use self-attestation rules to process applications.

As per current policy, all changes in circumstances that may impact eligibility must be reported within 10 calendar days of the change occurring.

Post-eligibility paper verification is required for discrepancies in any electronic crossmatches and for certain information provided by the client at application. Specifically:

At the time of application and based on the information provided by the applicant, electronic verification will occur for: income, DOB, SSN, citizenship/immigration status, receipt of Medicare, and incarceration status;
Citizenship/immigration status verification remains unchanged: if electronic verification cannot confirm citizenship/immigration status, the applicant is given a reasonable opportunity to provide proof;
If income that was reported by the applicant is within 10% of the amount verified via electronic crossmatching, or if the difference in income exceeds 10% but the difference would not affect eligibility in any way, the information is considered reasonably compatible and is immediately used in the eligibility determination process, with no further verification required; and
Self-attestation at the time of application with no further proof required will occur for: residency, household composition pregnancy, and application for other benefits.

Spenddown: For In and Out MA, if the electronic crossmatch for income is any amount below the self-attested amount, or up to 10% over the self-attested amount, then the self-attested amount is considered verified and will be used to calculate the spenddown. If the electronic crossmatch amount is more than 10% over the self-attested amount, a verification request will be generated to the casehead.

Post-application paper verification is required for discrepancies that occur during electronic crossmatching for income (such as wages and UCB), DOB, receipt of Medicare, citizenship/immigration status, and SSN.

2. Passive redetermination process for non-MAGI categories of MA:

Non-MAGI categories of MA will now have a “passive renewal” process similar to MAGI categories of MA if all eligibility factors can be verified by electronic crossmatching.

If all eligibility factors for the non-MAGI case can be verified through electronic crossmatching at the regularly scheduled renewal and all eligibility criteria are met, the non-MAGI MA case’s regularly scheduled renewal period will be automatically advanced another 12 months.

- The CS0006/CS0030 includes a request that the casehead contact DHHS to report any corrections that need to be made to the information that DHHS used to renew eligibility, but this information is assumed to be correct and it is not expected that corrections will be returned. The return of the information is not required in the renewal process. The eligibility worker should never close any recipient for failure to return this information.

If all eligibility factors for the non-MAGI case cannot be verified through electronic crossmatching, the regularly scheduled renewal period will not be automatically advanced 12 months.

- Eligibility factors for the non-MAGI case that cannot be verified through electronic crossmatching include:

§ When reported wages or unearned income are not able to be electronically verified (because there is no electronic crossmatch available; because no response is received in the electronic crossmatch process; or because the response from the crossmatch is not within the 10% threshold);

§ When the MA case includes self-employment income;

§ When the Asset Verification System (AVS) response shows that the recipient is over the resource limit; or

§ When the MA case includes a trust or annuity, or another resource that cannot be verified by the AVS.

- Notification that eligibility could not be automatically renewed will be generated to the casehead via the CS0006/CS0030. In the CS0006/CS0030, the casehead is provided with 1) a list of required proofs and 2) the information that DHHS used to determine that eligibility could not be automatically renewed.

§ The proofs listed in the CS0006/CS0030 must be provided to DHHS by the 15^th day of the month following the date on the CS0006/CS0030. Failure to provide the requested proofs within timeframes results in termination of MA.

§ The CS0006/CS0030 includes a request that the casehead review the information that DHHS used to determine that eligibility could not be renewed, and return it if corrections are needed. This information is assumed to be correct and it is not expected that corrections will be returned. The return of this information is not required in the renewal process. The eligibility worker should never close any recipients for failure to return this information.

The notification associated with the type of redetermination/recertification scheduled for cash, SNAP, or NH Child Care Scholarship will be generated: New HEIGHTS-generated CS0001, Rede Interview, is generated if the case is scheduled for an interview; New HEIGHTS-generated CS0005, Mail-In Rede Letter, is generated if the case is eligible for a paper redetermination/recertification; New HEIGHTS-generated CS0027, Online Rede Letter, is generated if the case is eligible to complete the redetermination online.
If all eligibility factors for the MA case can be verified through electronic crossmatching, the MA case’s regularly scheduled renewal period will be automatically advanced 12 months with no action required by the eligibility worker or the recipient.
If all MA eligibility factors for the case cannot be verified through electronic crossmatching, the case’s regularly scheduled renewal period will not be automatically advanced 12 months, and this group will additionally receive the CS0006/CS0030 requesting the specific proof needed to renew MA eligibility.

If the regularly scheduled redetermination/recertification date for cash, SNAP, or NH Child Care Scholarship does not align with the regularly schedule MA renewal date, the MA renewal date is not impacted at all and remains unchanged.

NEW HEIGHTS & NH EASY SYSTEMS PROCEDURES AND IMPLEMENTATION

1. Simplified application process for non-MAGI categories with no medical or disability determination (or a previous medical or disability determination that remains valid):

If eligibility workers need to pend a case, they should uncheck the “Individual meets MA verification requirements” box (located on the Income, Unearned Income, and Resources screens).

All New HEIGHTS changes were programmed effective March 31, 2020.

2. Passive redetermination process for non-MAGI categories of MA:

All New HEIGHTS changes were programmed effective May 6, 2020; this process first affected July 2020 redeterminations. CS0006 Rede Letter and CS0030 Online Rede Letter will now be used for non-MAGI categories of MA. Passive versions of CS0006 and CS0030 will be used for non-MAGI categories of MA where all eligibility factors can be electronically verified.

POLICY MANUAL REVISIONS

Revised Medical Assistance Manual Topics

PART 109 APPLICATION PROCESS

Section 109.01 Filing an Application

PART 113 APPLICATION PROCESSING TIME FRAMES

PART 115 JOINT APPLICATIONS

PART 123 INTERVIEWS

PART 157 REDETERMINATION

Section 157.01 Timely Notice

Section 157.03 Required Verification for Redeterminations

Section 157.05 Processing Redeterminations

Section 157.09 Termination at Redetermination

Section 205.01 Verification: OAA

Section 213.01 Verification: QMB

Section 217.01 Verification SLMB/SLMB135

Section 301.13 Verification of Residency

PART 509 VERIFICATION

IMPLEMENTATION

1. Simplified application process for non-MAGI categories with no medical or disability determination (or a previous medical or disability determination that remains valid):

All New HEIGHTS changes were programmed effective March 31, 2020.

2. Passive redetermination process for non-MAGI categories of MA:

All New HEIGHTS changes were programmed effective May 6, 2020; this process first affected July 2020 redeterminations.

CLIENT NOTIFICATION

No special client notification is planned or needed.

TRAINING

No special training is planned or needed.

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 September 1, 2021.

BFA/BDC:s