SR 22-27 Dated 09/22 |
STATE OF NEW HAMPSHIRE
DEPARTMENT OF HEALTH & HUMAN SERVICES – DIVISION OF ECONOMIC AND HOUSING STABILITY
Bureau of family assistance (bfa)
INTER-DEPARTMENT COMMUNICATION
FROM: |
Director of Division of Economic and Housing Stability (DEHS), Karen Hebert
|
BFA SIGNATURE DATE: |
August 23, 2022
|
FROM: |
Director of Division of Medicaid Services (DMS) Henry Lipman
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DMS SIGNATURE DATE: |
August 19, 2022
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AT (OFFICE): |
Bureau of Family Assistance Division of Medicaid Services |
TO: |
All BFA Staff All DMS Staff NHEP Team
|
SUBJECT: |
Addition of Pre-Paid Debit Cards as a Resource; Clarification to FANF Policy for Vehicle Exclusion; Revisions to the Family Assistance Manual, Adult Assistance Manual and Medical Assistance Manual to Clarify Policy on Trusts and Annuities as Resources. |
EFFECTIVE DATE: |
Upon Receipt
|
SUMMARY
This Supervisory Release (SR) releases the following changes and clarification to personal property resources:
· Pre-paid debit cards (such as Direct Express) have been added to the liquid resource type Checking in New HEIGHTS and NH Easy so it now reads Checking/PrePaidDebitCard. Treatment of this resource has been added to each policy manual.
· Revisions have been made to the Family Assistance Manual to clarify the treatment of vehicles for FANF applicants and recipients.
· Revisions have been made to the Adult Assistance Manual (AAM), Family Assistance Manual (FAM), and Medical Assistance Manual (MAM) to clarify when an annuity or a trust is either counted or excluded.
FORMER POLICY |
NEW POLICY |
No former policy for pre-paid cards. |
Pre-paid debit cards (such as Direct Express) are treated in the same manner as a checking account for all programs. |
For FANF financial and medical assistance and 12-month EMA, 1 vehicle was allowed to be excluded per any adult household member, regardless if the adult was disqualified or excluded from the assistance group. |
For FANF financial assistance and medical needy medical assistance, 1 vehicle is excluded per parent or caretaker relative in the assistance group. The total number of vehicles excluded as a resource, regardless of ownership or value, cannot exceed the number of parents or caretaker relatives in the assistance group. |
Annuities were an excluded resource for financial and medical assistance recipients if the expected return on the annuity is commensurate with the life expectancy of the individual and if the state of New Hampshire was named as beneficiary. |
Annuities are excluded as a resource for all categories of financial assistance if the expected return on the annuity is commensurate with the life expectancy of the individual. |
POLICY
· Pre-paid debit cards are cards (such as Direct Express, Green Dot, EPPI/Way2Go) on which an individual receives electronic payments. These have been treated as a countable resource for all programs with a resource test, just as a bank account is, however there has previously been no option for this in the Type dropdown on the Liquid Resources screen in New HEIGHTS. This has led to a procedural discrepancy statewide with some District Offices selecting ‘savings’, some selecting ‘checking’ and so on. To provide for consistency, a request was made to add pre-paid debit cards as an option in New HEIGHTS. Since these are treated in the same manner as checking accounts for eligibility purposes, the “Checking” option has been updated to ‘Checking/PrepaidDebitCard’. There are no spaces between the words due to a 25-character limit.
§ For FANF this means that a pre-paid debit card may be considered a “working account” if the individual’s FANF grant is paid onto the card and the individual uses the card for regular expenses. In this case, New HEIGHTS will automatically subtract the payment standard for the AG size from the card’s balance and count the remainder as a resource. For example, if $1000 is entered as the current balance for a pre-paid card and the AG size is 2, New HEIGHTS will subtract the payment standard of $915 and the resource budget will show a countable amount of $85.
§ Any debit card that is tied to a trust (such as a TrueLink card) will be part of the Trust Department’s review; this review will determine what, if any, portion of the card balance is countable as a resource. Please note that TrueLink cards are not always related to a trust.
§ Gift cards are not the same as pre-paid debit cards. Per FNS guidance, a merchant-specific card (ex: a Market Basket gift card) is not a countable resource. A credit card gift card (such as a VISA gift card) is a countable resource because these can be spent similarly to cash and are accepted at most locations without restriction on items.
· For applicants and recipients of FANF financial assistance and medically needy medical assistance, 1 vehicle can be excluded per parent or caretaker relative in the assistance group. The total number of vehicles excluded cannot exceed the number of parents or caretaker relatives in the assistance group, regardless of ownership or value.
· The requirement for an annuity to name the state of New Hampshire as beneficiary in order to be excluded as a resource for financial assistance has been removed. An annuity is an excluded resource for all categories of financial assistance if the expected return on the annuity is commensurate with the life expectancy of the individual, meaning that the duration of payments will correspond with the individual’s life expectancy. There is no change to the policy for medical assistance.
· On each page regarding Trusts as a resource in the AAM, FAM and MAM, the following has been added:
All trusts must be forwarded to State Office for a trust review. State Office will determine whether the trust is countable as a resource, or any disbursements are countable as income.
Please be sure to follow the Trust Review Procedure at initial applications, redeterminations, and whenever a change is reported.
NEW HEIGHTS & NH EASY SYSTEMS PROCEDURES AND IMPLEMENTATION
New HEIGHTS Update(s)
In the Liquid Resources – Details tab, New HEIGHTS has updated the dropdown for Type of Liquid Resource from ‘Checking’ to ‘Checking/PrepaidDebitCard’. This change will take effect on 8/26/22.
NH Easy Update(s)
In the Assets section, if an individual answers ‘Yes’ to having liquid assets, a follow-up question is “What type of liquid asset is this?” with a drop-down list. The option for Checking in this dropdown has been updated to Checking/PrepaidDebitCard. This change will take effect on 8/26/22.
The Help button for the Liquid Asset screen will be updated in September to add the definition of a pre-paid debit card and to clarify for applicants the difference between pre-paid debit cards and gift cards.
For both New HEIGHTS and NH Easy, the Verification Checklist will be updated to request:
• Proof of: Checking account or Pre-Paid Debit Card number and current balance
• Examples of what to send: Current account statement or copy of Pre-Paid Debit Card and bank receipt with balance
POLICY MANUAL REVISIONS
Revised Adult Assistance Manual Topics
PART 411 TRUSTS USING THE ASSETS OF OTHER PARTIES
PART 411 TRUSTS USING THE ASSETS OF THE INDIVIDUAL OR SPOUSE
Revised Family Assistance Manual Topics
PART 409 TRUSTS USING THE ASSETS OF OTHER PARTIES
PART 409 TRUSTS USING THE ASSETS OF THE INDIVIDUAL OR SPOUSE
Revised Food Stamp Manual Topics
Revised Medical Assistance Manual Topics
PART 411 TRUSTS USING THE ASSETS OF OTHER PARTIES
PART 411 TRUSTS USING THE ASSETS OF THE INDIVIDUAL OR SPOUSE
IMPLEMENTATION
These policy changes are effective immediately with the release of this SR. All manual pages will be updated effective September 1, 2022.
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 https://www.dhhs.nh.gov/sr_htm/sr.htm, effective September 1, 2022.
BFA/DMS:sh