IM-02 COVID-19: UNEMPLOYMENT COMPENSATION UPDATES RESULTING FROM THE CONSOLIDATED APPROPRIATIONS ACT, 2021

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  COVID-19:  UNEMPLOYMENT COMPENSATION UPDATES RESULTING FROM THE CONSOLIDATED APPROPRIATIONS ACT, 2021

DISCUSSION:

Memo IM-37, dated April 29, 2020, introduced 3 new types of Unemployment Compensation funds that were created on March 27, 2020, as a result the Coronavirus Aid, Relief, and Economic Security (CARES) Act. 

Those funds were the Federal Pandemic Unemployment Compensation (FPUC) fund, the Pandemic Unemployment Assistance (PUA) fund, and the Pandemic Emergency Unemployment Compensation (PEUC) fund.

On December 27, 2020, the Consolidated Appropriations Act, 2021 (CAA) was signed into law.  The CAA enacts changes to the provisions of unemployment funds introduced by the CARES Act:

  • FPUC-A $300 weekly federal supplement is added to regular unemployment funds starting after December 26, 2020 and ending March 14, 2021. FPUC funds are excluded/non-countable income for the Supplemental Nutrition Assistance Program (SNAP) and all MO HealthNet programs (except for sighted spouses on Blind Pension determinations).
  • PUA funds provide unemployment benefits for eligible individuals who are self-employed, seeking part-time employment, or who would not otherwise qualify for Unemployment Compensation. PUA funds are extended through March 14, 2021 and allow certain individuals to continue receiving benefits through April 5, 2021.  These funds count for all programs.
  • PEUC funds provide an additional 13 weeks of unemployment benefits to individuals who have exhausted benefits under regular Unemployment Compensation. PEUC funds are extended through March 14, 2021 and allow certain individuals to continue receiving benefits through April 5, 2021.  These funds count for all programs.

IMES is updated to include all three types of Unemployment.

Verification of Unemployment Compensation Income

Use IMES to identify, budget, and verify gross income and deductions from Unemployment Compensation for Missouri unemployment recipients.

  1. Review the COMP WEEK column of the IMES. Total all payments made per the CHECK AMT column for each specific COMP WEEK date to determine a gross payment amount. In the red box below, the total payment made for the COMP WEEK 12/30 is $620.00 ($558 + $62=$620). 
  2. Review the WEEKLY AMT field to determine the regular weekly amount.
  3. Enter the WEEKLY AMT as regular unemployment, PUA, or PEUC funds.

NOTE:  Refer to 2020 Hot Tip, Identifying Pandemic Unemployment Types on IMES for more.  

The remaining amount, should be the $300 FPUC funds.  Enter this amount as FPUC.

  1. For FAMIS determinations, evaluate the REC column of the IMES for child support payments (CHSP). If child support payments are deducted, budget the payments on the Court Ordered Expense (SUPEXP/FMXL) screen in FAMIS using normal budgeting procedures. 
  1. Review the budget screens in the eligibility system before authorization. Regular Unemployment Compensation/Insurance is included income for all programs.

Refer participants with questions about Unemployment Compensation to the Missouri Department of Labor and Industrial Relations interactive site at uinteract.labor.mo.gov.  Participants can use this site to file claims for Unemployment Compensation, view income verification, request documentation, and report changes in circumstances.

 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

KE/ers/hrp/mm/sb/nw

IM-180 AFFORDABLE INSURANCE QUOTES UPDATED ON FAMILY MO HEALTHNET (MAGI) APPENDIX G

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  AFFORDABLE INSURANCE QUOTES UPDATED ON
FAMILY MO HEALTHNET (MAGI) APPENDIX G

MANUAL REVISION #
APPENDIX G

 

DISCUSSION:

The purpose of this memorandum is to notify staff that Appendix G has been updated with 2021 insurance quotes from the Federally Facilitated Marketplace (FFM).  Affordable insurance determinations for Children’s Health Insurance Program (CHIP) premium children must still be completed with the CHIP Affordability Test Calculator (MAGI Appendix G).

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.
  • Begin using the updated CHIP Calculator January 1, 2021

 

KE/df

 

IM-179 INTRODUCTION OF THE IM-7A ALTERNATIVE ACCOUNT VERIFICATION FORM

FROM:   KIM EVANS, DIRECTOR

SUBJECT:  INTRODUCTION OF THE IM-7A ALTERNATIVE ACCOUNT VERIFICATION FORM
FORM REVISION # IM-7A

DISCUSSION:  The purpose of this memo is to introduce the Alternative Account Verification Form, IM-7A. The IM-7A was created in an effort to provide an additional verification option to verify financial accounts. Use this form in the event a participant can display banking, direct benefit, or other account information on his/her device while in a Family Support Division (FSD) office.

EXAMPLE: Mary has completed an interview for her SNAP/MHABD case in her local office and the interviewer requested a bank statement.  Mary has access to her account information on her phone and while in the office, a staff member views the information on the phone and helps her complete the IM-7A form.  Her bank balance is $4000, but she notes on the form that she recently received a tax refund for $3000.  Mary and the staff member sign the form.

EXAMPLE:  FSD requested bank statements from Sue, who is hospitalized.  Her spouse, John, cannot find any statements.  He visits a local office and states he can view her accounts on their tablet.  A staff member completes the IM-7A form for each account with information viewed on the tablet.  The staff member adds a note to the forms to describe the account balances from the prior quarter months.  John views the entries and he and the staff member sign the form.

The following conditions apply when completing this form:

  • The participant must be in an FSD office.

NOTE: Do not request or require a participant come into the office to present account information on an electronic device. Standard verification procedures still apply.

  • If the participant completes the gray areas of the form, a staff member must also view the account information on the participant’s device.
  • If a staff member completes the form for the participant, the participant must agree with the entries made on the form.
  • The participant and the staff member must sign at the bottom of the form.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.
  • Begin using the IM-7A immediately

KE/ers/ja/hrp

 

 

 

IM-178 CLARIFICATION AND CHANGES TO 5% DISREGARD FOR FAMILY MO HEALTHNET (MAGI)

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  CLARIFICATION AND CHANGES TO 5% DISREGARD FOR FAMILY MO HEALTHNET (MAGI)

MANUAL REVISION # 178
1805.030.20.20.05
Appendix A
Appendix B

 

DISCUSSION:

The purpose of this memorandum is to advise staff of changes to the 5% disregard income calculation for Family MO HealthNet (MAGI) eligibility determinations. 

Due to receiving a Payment Error Rate Measurement (PERM) finding from the Centers for Medicare and Medicaid Services (CMS) as well as clarification from the Division of Legal Services (DLS), the Missouri Eligibility Determination and Enrollment System (MEDES) has been updated to no longer add a 5% disregard at every eligibility level.  Instead, the 5% disregard will only be applied when the disregard means the difference between being eligible for MO HealthNet or Children’s Health Insurance Program (CHIP) and being ineligible.

The 5% disregard will still apply to the highest MO HealthNet level for each level of Medicaid (non-CHIP coverage) and CHIP (including Show-Me Healthy Babies), as well as MO HealthNet for Pregnant Women (MPW) and Uninsured Women’s Health Services (UWHS).  Participants will first have an eligibility determination without the 5% disregard.  If found ineligible at either the highest Medicaid or highest CHIP level, the 5% disregard will be added and a new eligibility determination run before moving to the next level of care (if another level of care exists for the participant).

NOTE: The 5% disregard will still apply to MO HealthNet for Families (MHF) Adult as it is the highest level for adults but will no longer be applied to MHF Child as it is not the highest Medicaid (non-CHIP) level for children.  Due to this change, it is possible that a household could have a child/children eligible for MHK while the adult(s) is eligible for MHF Adult.

NOTE: The 5% disregard will still apply to MO HealthNet for Kids (MHK) as it is the highest Medicaid (non-CHIP) level for children but will no longer be applied to CHIP 71 & CHIP 72 as it is not the highest CHIP level for children.  Due to this change, the MHK income level is now higher than the CHIP 71 & CHIP 72 level, placing no one under CHIP 71 & CHIP 72.

EXAMPLE: Please see policy section 1805.030.20.20.05 for examples.

The MEDES system was updated November 22, 2020 to reflect these changes.

NOTE: As MEDES runs the updated eligibility determinations for past active periods, eligibility will appear to negatively change on the Product Delivery Case; however, benefits on the Integrated Case and downstream will not change and no adverse action will be triggered.  If the current coverage is determined to change due to the 5% updates, an adverse action will be triggered.

Appendices A and B have been updated to reflect the updated income guidelines.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/al

 

IM-176 APPLICATION FOR MO HEALTHNET FOR THE AGED, BLIND, AND DISABLED (IM-1MA) REVISION

FROM: KIM EVANS, DIRECTOR

SUBJECT: APPLICATION FOR MO HEALTHNET FOR THE AGED, BLIND, AND DISABLED (IM-1MA) REVISION
FORM REVISION # IM-1MA

DISCUSSION:  The purpose of this memorandum is to introduce changes made to the IM-1MA Application for MO HealthNet (Medicaid). 

The IM-1MA has been revised to include the following changes:

  • Addition of the FSD.Documents@dss.mo.gov email address which may be used by participants for submitting the IM-1MA and other documents,
  • A new fax number 573-526-9400 has been added where participants may submit the IM-1MA and other documents,  
  • A space to list preferred first name,
  • An option for language preference,
  • The date of marriage,
  • The question; “Are you or your spouse currently serving or have you ever served in the Military?” has been added to obtain more detailed information on military service,  
  • The question; “Were you in foster care at age 18 or older?” has been added,
  • The word “Cash” was added to the BP/SAB instructions in Section 8 to indicate if applying for BP or SAB Cash, complete this section; and
  • The Rights and Responsibilities section was updated to add this statement: “I/We authorize the Director of the Family Support Division or his/her appointee to investigate and verify these circumstances and statements through any means authorized by law, including accessing public and private databases”.

 

The revised is available in the IM-1MA is available in the IM Forms Manual

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.
  • Destroy all previous paper versions of the IM-1MA and immediately begin using the 08/20 version.

KE/vm

 

 

 

IM-175 ACCUITY AND THE FAIR CREDIT REPORTING ACT (FCRA) NOTIFICATION REQUIREMENTS

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  ACCUITY AND THE FAIR CREDIT REPORTING ACT (FCRA) NOTIFICATION REQUIREMENTS

FORM REVISION #

IM-50AA

DISCUSSION:

This memo is to introduce staff to mandatory reporting requirements and notices that must be provided to participants/applicants when certain actions are taken and Accuity Asset Verification System was used in the eligibility determination.

Due to Fair Credit Reporting Act (FCRA) requirements, when information provided by the Accuity Asset Verification System causes an adverse action to an individual’s active or pending case, the agency must provide additional notification to the participant. Additional information is available in manual section 0110.060.05 Electronic Verification System Legal Basis.

The system generated adverse action and action notices inform the participant of an adverse action or negative action on their case. The applicant or participant must also receive material when information that was used in the eligibility determination was received from a consumer reporting agency as well as the contact information for the consumer reporting agency.

NOTE:  The sentence above only pertains to negative actions that are a result of information provided by Accuity.

FAMIS Notices affected are:

  • FA-510 Adverse Action Notice
  • FA-150 Claimant Action Notice
  • FA-420 Adult MO HealthNet Adverse Action Notice
  • FA-460 Adult MO HealthNet Adverse Action Notice

System work is currently being completed in FAMIS and will not be available on December 1, 2020 when staff begin to utilize Accuity.  In order to meet the FCRA requirements, FSD must send the FCRA notification manually until the system work is completed.

A temporary form, “Information Notice – Regarding an Action on Your Case” (IM-50AA) has been created.  This form will be available in the IM Forms Manual and must be mailed manually to participants any time an adverse action or action notice that negatively affects a participant’s case is the result of information provided by Accuity. 

NOTE: Staff must complete the Name, Address, date the letter was sent, and the date of the (FA-150) that was used in the eligibility determination.

This requirement affects only programs that are affected by information provided by Accuity:  MO HealthNet for the Aged, Blind, and Disabled (MHABD), Temporary Assistance (TA), and Supplemental Nutrition Assistance Program (SNAP).

EXAMPLE:  Accuity provides information indicating that an individual is over the resource limit for the TA and SNAP Programs.  The participant is under the resource limit for the MHABD program.  Staff calls the participant and confirms that the information provided by Accuity is accurate.  An adverse action to close the TA and SNAP cases is issued by FAMIS.  Staff manually send the Information Notice-Regarding an Action on Your Case form to the participant.   

Negative or adverse actions that require the supplemental notice include actions such as case closings and application rejections.  If this manual process is in effect at the time that COVID-19 public health emergency ends, this could include coverage changes from MHABD to QMB/SLMB due to resources that exceed the MHABD resource limit.

Please send any questions through proper supervisory channels to the policy unit at COLE.MHNPolicy@dss.mo.gov.

A new memo will notify you when this temporary process ends. 

 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/rr/am

IM-174 GUIDANCE ON SIGNING MO HEALTHNET (MHN) APPLICATIONS DURING THE COVID-19 PUBLIC HEALTH EMERGENCY (PHE)

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  GUIDANCE ON SIGNING MO HEALTHNET (MHN) APPLICATIONS DURING THE COVID-19 PUBLIC HEALTH EMERGENCY (PHE)

DISCUSSION:

Regulations allow for the electronic signing of MHN applications. With the exception of web applications, Family Support Division (FSD) does not have policy in place regarding the acceptance of electronic signatures on MHN applications.

Current policy regarding signing MHN applications:

Providers have reported that they are experiencing challenges assisting individuals with the application process.  Many people do not have family members who can sign the application on their behalf when the participants are unable to sign the application themselves or due to social distancing guidelines.

Due to the COVID-19 PHE, the following considerations are being allowed by FSD regarding signatures on MHN applications:

 Option 1: To fill out the application, the applicant can type in their responses on a fillable PDF application using a laptop, smart phone, or answer questions over the phone. The signature field on the PDF application form is not fillable (note: a typed signature is not necessarily an electronic signature). To sign the application, the applicant can write or type a statement that they would like to apply for MO HealthNet then type or sign their name and date. This information is then sent by email or fax to either the provider or to FSD. The email or fax is accepted as authenticating the electronic signature during the COVID-19 state of emergency.

  • This type of signature is acceptable on any IM-1MA application for MHABD, it is not strictly for MHABD coverage due to a COVID-19 diagnosis.
  • This type of signature is allowable on any Family MHN application.
  • This type of signature is allowable on PE applications.
  • This type of signature is allowed due to social distancing, self-quarantine, medically recommended quarantine or isolated quarantine in a medical facility.
  • There is not required wording of the statement from the applicant, so long as the intent to apply for MHN coverage is expressed.
  • Include a comment in the electronic record regarding the reason that a pen and ink signature is not on the application.

Option 2: If a participant is medically isolated or quarantined due to a diagnosis of COVID-19, someone acting responsibly for the applicant may sign on the applicant’s behalf. Note, individuals who are in isolated quarantine in a medical facility are not allowed to have paperwork come into or out of the quarantined area. The participant should type their information onto the fillable PDF using a laptop, smart phone, or answers the eligibility questions over the phone.

  • Sample format for facility: “Name of person signing on behalf of (o/b/o) facility name for patient/applicant’s name
  • Unless the participant is unable to communicate, the applicant should give their verbal or electronic consent to the provider to sign the application on their behalf.
  • Documentation must be included on the application that the application is being signed by the provider due to quarantined in isolation due to COVID-19.
  • This option is to be used as a last resort.

 

Authorized Representative Forms:

 Regulations and policies are already in place for an individual to electronically sign an IM-6AR form that allows another party to sign an application for them.

If the provider is unable to print and sign the IM-6AR to accept the designation, they can sign the form electronically or type/write a separate document that accepts the designation as long as it contains the same information as the designation portion of the IM-6AR form.

During the COVID-19 PHE, if additional support is needed regarding acceptable signatures on applications, please submit the case information through supervisory channels to Cole.MHNPolicy@dss.mo.gov.

  • Reference COVID-19 and either MAGI or MHABD in the subject line of the email.

 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/ams

IM-173 NEW FORM FOR MO HEALTHNET FOR FAMILIES (MAGI) ONGOING COVERAGE SIGNATURE REQUEST (IM-1SSL)

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  NEW FORM FOR MO HEALTHNET FOR FAMILIES (MAGI) ONGOING COVERAGE SIGNATURE REQUEST (IM-1SSL)

FORM REVISION #

IM-1SSL Ongoing Coverage Signature Request

DISCUSSION:

The purpose of this memorandum is to introduce a new form, the IM-1SSL Ongoing Coverage Signature Request. This form is to be used for completing an ex parte review for MAGI eligibility when a new case is established for the participant due to moving out of the existing MAGI household.

Example: Ms. A is receiving MO HealthNet for Pregnant Women (MPW) under her mother’s case and when the birth of the baby is reported it is learned that the birth mother is no longer living in the existing MAGI household.  A new case should be established and a signature should be obtained by sending the IM-1SSL Ongoing Coverage Signature Request with an IM-31A.

Note: In this example, Family Support Division (FSD) would observe the pending adverse action period on the case on which the participant is being removed.  Once the new case is established, after the observation of the adverse action period, FSD will not take a negative action if the IM-1SSL Ongoing Coverage Signature Request form is not returned, however, FSD will attempt another contact as well as send a new IM-31A with the form. 

When requesting a signature, the following statement should be used on the IM31A:

Please complete the enclosed IM-1SSL Ongoing Coverage Signature Request Form.  You either receive(d) coverage on someone else’s case or you don’t currently have your own case with FSD.  FSD has information that indicates you may be eligible to continue coverage on your own MO HealthNet case, but we’d like your permission to open a case for you.   Review your Rights and Responsibilities and complete section 1 with your additional household members. 

Please call 855-373-4636 with any questions.

Thank you for your cooperation!

 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.
  • Implement the manual follow up process for tracking the IM-31A and the signature request form.

 

KE/ams

IM-172 MANUAL UPDATE AND IIVE CLARIFICATION FOR ALL INCOME MAINTENANCE (IM) PROGRAMS

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  MANUAL UPDATE AND IIVE CLARIFICATION FOR ALL INCOME MAINTENANCE (IM) PROGRAMS

MANUAL REVISION #

0110.025.10

DISCUSSION:

The purpose of this memorandum is to clarify when to utilize IIVE information and to inform staff of an update to the General Information Manual.   Section 0110.025.10 Unearned Income provides clarification that IIVE should be viewed and scanned to the Enterprise Content Management (ECM) system for each eligibility unit (EU) member/household member at the time of the interview or at the time the case is worked if no interview is held.

IIVE is a tool that can be used to verify a participant’s Social Security and/or SSI benefits and any changes to these benefits.  It is only necessary to view and scan the IIVE to the ECM once during the application, recertification, mid-certification (MCR) or annual review/renewal process. 

NOTE:  When scanning the IIVE to the ECM, all pages of the IIVE must be included.

When IIVE has been scanned to the ECM during the application process and subsequent views show no changes, record a comment in the eligibility system regarding IIVE.

NOTE:  For questions regarding when to view and scan IMES to the ECM, refer to memo IM-67 posted May 26, 2020, Manual Update and IMES Clarification for All Income Maintenance (IM) Programs.

 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

KE/kg/nw/ks/ph

IM-171 2021 INCREASE IN SUBSTANTIAL GAINFUL ACTIVITY (SGA)

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  2021 INCREASE IN SUBSTANTIAL GAINFUL ACTIVITY (SGA)

MANUAL REVISION #

APPENDIX D

APPENDIX J

DISCUSSION:

The Social Security Administration announced an increase to the SGA amount. 

Effective January 1, 2021, the monthly SGA amount for:

The Income Maintenance (IM) policy manual section: Appendix D has been updated to reflect this change.

 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/vb