Category: 2023

FROM: KIM EVANS, DIRECTOR

SUBJECT: INTRODUCING NEW INFORMATIONAL NOTICE FOR MO HEALTHNET (MHN) ANNUAL RENEWALS RECEIVED 90 DAYS OR MORE BEFORE THE ANNUAL RENEWAL PERIOD

FORM REVISION #
IM-34 ERRN

DISCUSSION:

On April 1, 2023, Missouri resumed completing annual renewals. Family Support Division (FSD) initiates annual renewals by first attempting to complete the annual renewal without contacting the participant. An annual renewal form will only be required and sent to the participant if FSD is unable to complete the renewal with available information.

If an annual renewal form is submitted 90 days or more before the annual renewal period, the annual renewal will NOT be completed. FSD will review the form for reported changes and will send the participant an Early Renewal Received Notice (IM-34 ERRN).

The IM-34 ERRN notifies the participant that the annual renewal was not completed and provides the MO HealthNet Annual Renewal webpage, mydss.mo.gov/renew, for more information.

If an annual renewal is received more than 90 days prior to the annual renewal period, FSD staff or contracted staff must:

• Send the IM-34 ERRN to the participant.
• Scan and add the IM-34 ERRN to the participant’s electronic file.
• Document in the eligibility system that an annual renewal was received 90 days or more before the annual renewal period and is considered a Change in Circumstance, any changes reported on the form, and the date the IM-34 ERRN was sent to the participant.

The IM-34 ERRN is located in the internal forms manual for staff to utilize when an annual renewal is received 90 days or more before the annual renewal period.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/cj

FROM: KIM EVANS, DIRECTOR

SUBJECT: PUBLIC HEALTH EMERGENCY (PHE) AND MO HEALTHNET (MHN) APPLICATION FLEXIBILITIES ENDING

MANUAL REVISION #
0890.005.00
1895.005.00

DISCUSSION:

The Coronavirus Disease 2019 (COVID-19) PHE has been in place since January 27, 2020 and has been renewed throughout the pandemic. The U.S. Department of Health & Human Services (HHS) has announced plans for the PHE to expire at the end of the day on May 11, 2023. Missouri has used several flexibilities to expedite MHN application processing during the PHE.

Effective April 17, 2023, discontinue using the flexibilities listed below as they are not tied to the end of the PHE:

• Allow Self-Attestation for Most Eligibility Factors
  PHE Flexibility: Allow self-attestation for MHN eligibility factors except ID, citizenship, trusts, and annuities.

Starting April 17, 2023:

• • Review policy in the General Information Manual section 0110.000.00 Verification Requirements for MO HealthNet and Adult Cash Assistance Programs and its subsections for verification requirements when processing Non-MAGI applications.
  • Review policy in MAGI Manual section 1805.000.00 Eligibility and Verification and its subsections for verification requirements when processing MAGI applications.

• Alternative Signatures

PHE Flexibility: Regulation allowing someone to sign an application on the applicant’s behalf is extended to include individuals quarantined due to COVID.

Starting April 17, 2023:

• • Review policy in MAGI Manual section 1802.020.00 Signing the Application and its subsections for application signature requirements. Policy is the same for MAGI and Non-MAGI programs.

Effective May 12, 2023, discontinue using the flexibility listed below as it is tied to the end of the PHE:

• CHIP 75 30 Day Waiting Period Waived
  PHE Flexibility: The 30-day mandatory waiting period was waived for CHIP 75 approvals.

Starting May 12, 2023:

• • Review policy in the Family MO HealthNet (MAGI) Manual section 1840.015.00 Begin and End Dates for Chip Coverage for processing applications and approving CHIP eligibility.

This memo has been added to the following MO HealthNet for the Aged, Blind, and Disabled (MHABD) and Family MO HealthNet (MAGI) manual sections:

0890.005.00 Unwinding the Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE)
1895.005.00 Unwinding the Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE)

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/sh

FROM: KIM EVANS, DIRECTOR

SUBJECT: ALIGNING FAMILY MO HEALTHNET (MAGI) INCOME VERIFICATION POLICY WITH THE MAGI VERIFICATION PLAN

MANUAL REVISION #
1805.030.05
1805.030.15
1805.030.15.10

DISCUSSION:

MAGI Manual Sections 1805.030.05 Income Evidence, 1805.030.15 Reasonable Compatibility, and 1805.030.15.10 Reasonable Compatibility with More than One Income in the Household are updated to align MAGI policy with recent changes to the MAGI Verification Plan and related federal guidance.

Key changes are:

• Attempt to resolve reasonable compatibility (RC) inconsistencies by first trying to contact the participant to ask for a clarifying statement. Obtain verification only if the clarifying statement cannot be obtained or does not resolve the inconsistency.
• When self-attested income and electronically obtained information (EOI) are both within the same program threshold or the EOI is in a higher program threshold, but is within 10% of the self-attested amount, use the self-attested amount to determine the eligibility level.
• After checking for income verified by another assistance program, such as Supplemental Nutrition Assistance Program (SNAP), accept the self-attested amount of income for self-employment and farming income, pensions, and short or long-term disability.

Refer to the updated sections for more information.

Note: Per federal requirements at 42 CFR 435.945(j), Family Support Division (FSD) is required to maintain a MAGI Verification Plan describing FSD’s MAGI verification policies and procedures.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/ers

FROM: KIM EVANS, DIRECTOR

SUBJECT: UPDATED POLICY ALLOWING ELIGIBILITY CHANGES FOR SUSPENDED MO HEALTHNET (MHN) PARTICIPANTS

MANUAL REVISION #
0840.020.00
1885.040.00

DISCUSSION:

MHN participants who become incarcerated, or are determined eligible while incarcerated, must have their MHN suspended until release. Policy is updated to allow all case actions for a suspended participant.

Suspended participants (or their household or authorized representative) must complete annual renewals and report changes in circumstance during incarceration. Family Support Division (FSD) will attempt to complete annual renewals without contacting the participant; however, if this is not possible, an annual renewal form will be sent to the participant’s mailing address, which may be the jail or prison, or their household address.

If an annual renewal or a change of circumstance causes a change to eligibility for a suspended participant, FSD will take action on these changes and send appropriate notices.

This may include, but is not limited to:

• Changing the level of care.
• Moving from MAGI to Non-MAGI programs.
• Closing eligibility.

Revised MAGI policy is in Family MO HealthNet manual section, 1885.040.00 Suspension of MAGI Benefits for Incarcerated Individuals.

Revised Non-MAGI policy is in MO HealthNet for the Aged, Blind, and Disabled manual section, 0840.020.00 Suspending Incarcerated Participants.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/cj

FROM: KIM EVANS, DIRECTOR

SUBJECT: RECONSIDERATION PERIOD DURING THE TRANSITION PERIOD FOR ALL MO HEALTHNET (MHN) PROGRAMS

MANUAL REVISION #
0840.005.05
0890.010.00
1880.020.00
1895.010.00

DISCUSSION:

Effective April 1, 2023 through May 31, 2024, temporary reconsideration period policy is in effect for all MHN programs.

When a case has closed for failure to return the annual renewal form, cancel close/reopen the case when the signed annual renewal is received within 90 days of closing.

If the participant returns an annual renewal form, it must be signed. Telephonic signatures are allowed for MHN annual renewals, however, only the Family Support Division (FSD) vendor and specialized staff trained to accept and record telephonic signatures can complete annual renewals by phone. If the participant contacts the Customer Service Center and needs to complete the annual renewal, transfer the call to the FSD vendor.

Consider the annual renewal as received if the participant fails to return the annual renewal form but provides all information required to complete the annual renewal by phone, online, in-person, or through the mail within the 90-day reconsideration period. For example, the participant turns in a new application with all required information.

When the annual renewal is received 90 days or less after the case closed:

• Cancel close/reopen the case.
• Follow established procedures to complete the annual renewal.

When the annual renewal is received 91 days or more after the case closed:

• Do not use the annual renewal form in place of an application.
• Tell the participant how to reapply by sending the form Annual Renewal Received Outside Reconsideration Period (IM-1U90).

Note: MEDES system changes to allow cases to be reopened up to 90 days will be in a future MEDES Release.

MO HealthNet for the Aged, Blind and Disabled (MHABD) Manual section 0840.005.05 Reconsideration Period and Family MO HealthNet (MAGI) Manual section 1880.020.00 Reconsideration Period were updated instructing staff to follow guidance in this memo during the transition period.

This memo has been added to the following MHABD and MAGI manual sections:

0890.010.00 Transition Period
1895.010.00 Transition Period

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/sh

FROM: KIM EVANS, DIRECTOR

SUBJECT: WAIVERS APPROVED BY CENTERS FOR MEDICARE & MEDICAID SERVICES (CMS) FOR ALL MO HEALTHNET (MHN) ANNUAL RENEWALS

MANUAL REVISION #
0890.010.00
1895.010.00

DISCUSSION:

An increased number of eligibility and enrollment actions must be completed when MHN annual renewals resume on April 1, 2023. CMS has approved Missouri to use the following waivers to help expedite renewal processing, protect participants from inappropriate terminations, and reduce administrative burden. Headings shown below are the official CMS waiver titles.

These waivers are effective April 1, 2023 and will continue until further notice.

1. Renewal for Individuals Based on SNAP Eligibility

Renew MHN eligibility for participants under 65 years of age who are receiving Supplemental Nutrition Assistance Program (SNAP) benefits, despite the differences in household composition and income-counting rules.

Note: This waiver allows the “Targeted Enrollment SNAP Strategy” flexibility currently used for Modified Adjusted Gross Income (MAGI) applications to also be used for all MHN annual renewals.

2. Ex Parte Renewal for Individuals with No Income and No Data Returned

When using the ex parte (not requiring information from the individual) renewal process for non-CHIP cases, complete the income determination without requesting additional income information or documentation if:

• An attestation of zero-dollar income was verified at an initial application or renewal completed no earlier than March 2019; and
• No income information is reported on an electronic source, such as IMES, IIVE, or The Work Number.

Continue to take appropriate steps to complete a determination of non-financial eligibility requirements.

Note: This waiver does not apply to CHIP cases.

3. Facilitating Renewal for Individuals with no Asset Verification System (AVS) Data Returned within a Reasonable Timeframe

Assume there has been no change in resources and complete the ex parte (not requiring information from the individual) renewal process without any further verification of assets when:

• No information is returned through Accuity; or
• Accuity response is not returned within 15 days.

If information from Accuity indicating potential ineligibility is received after a renewal has been completed, treat the information as a change in circumstance.

4. Extended Timeframe to Take Final Administrative Action on Fair Hearing Requests

All participants must remain active on MHN pending the outcome of a fair hearing decision regardless of whether the participant has requested that their MHN benefits continue. This flexibility does not extend the timeframe to take final administrative action when benefits cannot be provided pending the outcome of a fair hearing, such as a denial of eligibility for a new applicant.

• Staff who submit the hearing request must place both the Adverse Action Benefit Reduction (AABR) and No Change (NOCH) actions on hold before submitting the hearing request handoff. Information on how to change an adverse action status can be found in FAMIS Resources.
• The Income Maintenance (IM) Hearing Unit is responsible for reinstating coverage back to the date of the action for any person who requests a fair hearing after the date of action.

Note: Missouri will not recoup the cost of MHN benefits provided to the participant while the fair hearing is pending, regardless of whether the fair hearing ultimately upholds the agency’s determination.

This memo has been added to the following MO HealthNet for the Aged, Blind, and Disabled (MHABD) and Family MO HealthNet (MAGI) manual sections:
0890.010.00 Transition Period
1895.010.00 Transition Period

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/sh