FROM: REGINALD E. McELHANNON, INTERIM DIRECTOR
SUBJECT: IRS NOTICE LOG and IRS NOTICE LOG INSTRUCTIONS
DISCUSSION:
Requests for Interpretation of Policy (IM-14), or policy clearances, were originally forms sent to Program and Policy staff regarding the application of program policy to specific cases. This is now an electronic process.
- General: For MAGI programs only
- Case Specific: For all Income Maintenance programs
General requests for interpretation are meant to address trends of case issues that staff are seeing or questions about how to apply policy to MEDES system functionality. These clearances often include a “team” approach with MAGI Program and Policy staff working with the Training Unit and MEDES system subject matter experts to come up with responses that may be applied across similar cases or system issues.
Case specific requests for interpretation are submitted when field staff have questions on how to apply policy to a specific case situation. These are reviewed only by Program and Policy staff and only regard how policy impacts a specific case. Because the responses to these Requests for Interpretation are based on the information for a specific case and policy that is in place at the time the case is reviewed, these clearances must NOT be applied to other cases.
Keep the following items in mind when submitting a Request for Interpretation:
- Specific references to the policy manuals and system user guides are always included in a policy clearance request. With the exception of trusts and annuities, staff must ALWAYS consult available resources before submitting a Request for Interpretation.
- All pages of all relevant documents must be attached to the clearance request in order to receive a policy response.
- Policy staff cannot provide a response when pages of submitted documents are missing or some documents are not submitted at all.
- Policy staff will not search through the SharePoint or the Electronic Content Management System (ECM) to find missing information.
- Requests for Interpretation of Policy must always be submitted through supervisory channels to the Policy and Procedure Collaboration Portal. Only supervisors or managers may submit new general or case specific Requests for Interpretation of policy.
- Requests for Interpretation are always sent for:
- Trusts: These clearances are assigned a “T” number
- Annuities: These clearances are assigned a “A” number
- In cases when the reasonable opportunity exceeds 90 days
- MO HealthNet Undue Hardship Waiver Requests
- Subject lines for Requests for Interpretation of policy should include information about the topic of the clearance, such as, but not limited to:
- Participant’s last name
- “Income Counting” for income questions
- “QIT” for Medicaid Qualifying Income Trusts
- “MSNT” for MidWest Special Needs Trusts
- “ARCare” for ARCare Trusts
- “Spend Down” for clearances regarding spend down expenses
- Requests for Interpretation are internal documents and not to be shared with participants or other outside entities. Case comments must only include a brief summary of the clearance response, and the clearance number.
NECESSARY ACTION:
- Review this memorandum with appropriate staff.
- Refer to Policy and Procedure site instructions for information on how to enter Requests for Interpretation of Policy.
EMAIL-IM-#40
RM/kp/mc
