IM-36 TPL-1 FORM UPDATE

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  TPL-1 FORM UPDATE

FORM REVISION #
TPL-1 Instructions

 

DISCUSSION:

The TPL-1 form has been updated to include an email address for the Third Party Liability (TPL) Unit. After completion of a TPL-1 form, send a copy via email to the TPL Unit at tpl.database@dss.mo.gov and retain a copy in the participant’s electronic case record in the Electronic Content Management (ECM) system.

The TPL-1 Instructions have been revised to reflect the updated email address.  Other changes were made to align the language on the TPL-1 instructions with the TPL-1 form.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.
  • Begin using the new TPL-1 form and Instructions immediately.

KE/ers

 

IM-35 CONTESTING THE WORK NUMBER INFORMATION

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  CONTESTING THE WORK NUMBER INFORMATION

DISCUSSION:

If the participant believes that the information provided by The Work Number is incorrect, for example an incorrect employer is listed, they can contact Equifax directly:

Telephone: 1-866-349-5191
Mail: Equifax Information Services LLC
P.O. Box 740256
Atlanta, GA 30374-0256

Example:  Mr. B contacts the FSD Customer Service Center to report that the gross earnings reported by The Work Number for his most recent pay periods are incorrect.  Staff suggests to Mr. B that he contact his employer to confirm the accuracy of this information.

Example:  Mr. M contacts the FSD Customer Service Center to report that he has never worked for the company that is reported by The Work Number.  Staff suggests to Mr. M that he contact Equifax to report this information as inaccurate.  If staff determine that this does appear to be an error on The Work Number report, this income must not be included in the eligibility determination. 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/rr/kg/am/cs/sb

IM-34 THE WORK NUMBER MANUAL NOTICE REQUIREMENT FOR NEGATIVE ACTIONS

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  THE WORK NUMBER MANUAL NOTICE REQUIREMENT FOR NEGATIVE ACTIONS

FORM REVISION #

(IM-50E)

DISCUSSION:

The Fair Credit Reporting Act (FCRA) requires the Family Support Division to notify participants when a negative action is the result of information reported by a consumer reporting agency such as The Work Number.

System work is currently being completed in FAMIS and MEDES to add required FCRA language to adverse action notices and action notices when a negative action is taken due to information provided by a specific FCRA source.

FCRA wording has been added to adverse action and action notices related to rejections and closings in FAMIS.  Additional information is available in Email Memo IM-11 Phase 1:  FAMIS Verification Codes and Fair Credit Reporting Act (FCRA) Notification Added to FAMIS Notices, dated 3/22/2021

For all other negative actions that are a result of information provided by The Work Number, staff must mail an IM-  when the adverse action and action notices are sent.

Memorandums will be released as each phase of the system work is complete.  

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/rr/kg/am/cs/sb

IM-33 THE WORK NUMBER FAIR CREDIT REPORTING ACT REQUIREMENTS

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  THE WORK NUMBER FAIR CREDIT REPORTING ACT REQUIREMENTS

DISCUSSION:

The information provided by The Work Number is subject to FCRA requirements.  Refer to manual section 0110.060.05 Electronic Verification System Legal Basis for more information. 

Policy regarding proper authorization to review FCRA sources is available in the Electronic Verification System portion of the General Information manual.

A guide outlining when an IM-6EVS is required is in development.   

Eligibility unit members who are not applying for or receiving benefits must sign an Authorization for Verification (IM-6EVS) form before FSD can access their employment verification in The Work Number portal. 

To determine if an IM-6EVS is required consider the following: 

  • Requesting benefits: Do not request a signed IM-6EVS.  The request for benefits on the application provides the necessary authorization to consult FCRA sources.
  • Not requesting benefits: If the individual is a mandatory member of the eligibility unit a signed IM-6EVS is needed..

NOTE:  Refer to each program policy for mandatory members

As discussed in manual section 0110.060.15 Fair Credit Reporting Act Authorization, the IM-6EVS is valid until benefits are denied or terminated, or FSD receives a written and signed revocation.

Questions:

Questions should be sent through normal supervisory channels. Policy questions can be submitted by managers to the policy unit email addresses:

          MHABD and Family MHN: COLE.MHNPOLICY@dss.mo.gov

          SNAP: COLE.FSPOLICY@dss.mo.gov

          TA and CC: FSD.COLETAPOLICY@dss.mo.gov

For case specific policy clearances, utilize the Request for Interpretation of Policy (IM-14) process.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/rr/kg/am/cs/sb

IM-32 THE WORK NUMBER BY EQUIFAX PORTAL

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  THE WORK NUMBER BY EQUIFAX PORTAL          

DISCUSSION:

The Family Support Division (FSD) is adding The Work Number portal to the Electronic Verification System (EVS).  The Work Number provides earned income verification.   

  • When the Work Number provides a response for an employer a cost is incurred. Only utilize The Work Number portal for all programs at the time of:
    • Initial application—when earned income is reported
    • Recertification—when earned income is reported.
    • Annual renewal—when earned income is reported
  • Exhaust all other electronic resources, such as IMES, prior to requesting information from The Work Number.
  • Staff must only access The Work Number one time per application period and not more than once in a 30 day time period.

EXAMPLE:  Mrs. Z submits a Supplemental Nutrition Assistance Program (SNAP) application on 2/1/2021 and a Child Care (CC) application on 2/15/2021.  The Work Number printout from the SNAP application is valid at the time of the CC application.  If Mrs. Z reports a change in earnings on the CC application, do not consult The Work Number portal a second time in the 30 day time period.  Request verification of the change in earnings from the participant.      

  • Employment verification provided by The Work Number can also be used for other eligibility factors such as:
    • work months for Able Bodied Adults without Dependents (ABAWD) determinations or
    • hours worked for eligible student status for the SNAP program.
  • If the participant submits adequate verification of their earnings with their application, do not request a report from The Work Number.
  • If information reported by The Work Number does not match the participant’s statements, call the participant to resolve the discrepancy. If a collateral contact with the employer is necessary, staff can make a three-way call with the employer to verify the information.  If the collateral contact is unsuccessful, a Request for Information Notice (FA-325 for cases processed in FAMIS or IM-31a for cases processed in MEDES) is needed for the additional verification and documentation.

Do NOT utilize The Work Number in the following situations:

  • SNAP Mid Certification Review
  • Add a person or add a category requests, even if earned income is reported by the participant
  • Reports of a change in circumstance
  • Earned income is listed on IMES, but is not reported by the participant on the application/review form or during the interview
    • NOTE: Comments/notes in the eligibility system must reflect the review of this data and document any discussions held with the participant. 

Questions:

Questions should be sent through normal supervisory channels. Policy questions can be submitted by managers to the policy unit email addresses:

MHABD and Family MHN: COLE.MHNPOLICY@dss.mo.gov

          SNAP: COLE.FSPOLICY@dss.mo.gov

          TA and CC: FSD.COLETAPOLICY@dss.mo.gov

For case specific policy clearances, utilize the Request for Interpretation of Policy (IM-14) process.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/rr/kg/am/cs/sb

IM-31 FAMILY SUPPORT DIVISION (FSD) CUSTOMER SERVICE HOURS CHANGE

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  FAMILY SUPPORT DIVISION (FSD) CUSTOMER SERVICE HOURS CHANGE       

DISCUSSION:

The FSD Customer Service Centers will be closed on Saturday, April 3, 2021.   All centers will reopen on Monday, April 5, 2021 and will return to their normal hours of operation.  Effective April 5, 2021, hours of operation will be Monday through Friday 6:00 am to 6:00 pm.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/vm

IM-29 COVID-19: END OF EXTENSION FOR ALL SHOW ME HEALTHY BABIES (SMHB) PROGRAM COVERAGE

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  COVID-19: END OF EXTENSION FOR ALL SHOW ME HEALTHY BABIES (SMHB) PROGRAM COVERAGE                           

DISCUSSION:

Coverage under the SMHB program no longer includes extension of coverage during the Public Health Emergency (PHE).  The Family Support Division has received clarification from the Centers for Medicare and Medicaid Services (CMS) that because SMHB is a Children’s Health Insurance Program (CHIP), participants should not retain coverage beyond normal timeframes.

Beginning April 26, 2021 the following levels of coverage will follow pre-PHE guidelines and will no longer be extended:

  • SMHB pregnant women (citizen or qualified immigrant mother) will move to a 60-day post-partum period after delivery. The post-partum period should end on the last day of the month in which the 60th day after delivery lands.
  • SMHB pregnant women (non-citizen/non-qualified immigrant mother) will have full coverage until the discharge date after delivery, and will include one (1) post-partum visit.
  • SMHB Newborns (citizen or qualified immigrant mother) will end when the child turns age one (1), unless determined eligible for further coverage.
  • SMHB Newborns (non-citizen/non-qualified immigrant mother) will end when the child turns age one (1), unless determined eligible for further coverage.

COVID-19 EEE evidence will be removed from any SMHB coverage that was active prior to April 24, 2021, and an Adverse Action Notice (IM-80) will be mailed to participants. The system will continue sending IM-80s for SMHB coverage for 30 days.  At the end of 30 days, sending an IM-80 at the termination of SMHB coverage will stop. Any SMHB cases approved on or after that date will follow normal (pre-PHE) timeframe and notice guidelines.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/df       

IM-27 2021 FAMILY MO HEALTHNET (MAGI) COST OF LIVING ADJUSTMENT (COLA) FOR VETERANS ADMINISTRATION (VA) AND RAILROAD (RR) INCOME

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  2021 FAMILY MO HEALTHNET (MAGI) COST OF LIVING ADJUSTMENT (COLA) FOR VETERANS ADMINISTRATION (VA) AND RAILROAD (RR) INCOME

DISCUSSION:

The purpose of this memorandum is to inform staff that VA and RR participants received a 1.3% COLA for MAGI programs effective January 2021.

NOTE: The Families First Coronavirus Response Action of 2020 (FFCRA) requires that MO HealthNet (MHN) coverage for individuals be maintained at the same level or better for the duration of the COVID-19 Public Health Emergency (PHE).  The eligibility system will not reduce or end MHN coverage due to the COLA changes until the PHE has ended.

Cases Adjusted

Cases that include income types VA and/or RR benefits in the eligibility system were subject to an automatic increase of 1.3% for those income types.  The eligibility system end dated the previous income and added a new piece of income evidence that reflected the adjusted income amount. 

NOTE: Actions to reduce benefits will not be taken until the COVID-19 PHE has ended.

Cases That Did Not Adjust

Some cases did not adjust during COLA.  These cases will require manual intervention from staff to add the increased income amounts.  As cases are reviewed, check the income on each case to determine if the current income is entered.  Update and verify income as required using established procedures.

Notices
For case updates made as a result of COLA, the eligibility system finalized the decision(s) and sent out the appropriate notices.  The reasons and notices that were sent are as follows:

  • Cases with no change were sent the IM-33C.
  • Cases that resulted in a benefit reduction were sent an IM-80 allowing 10 days for the individual to respond to the proposed case action. The IM-33C was sent after the IM-80 expired.
  • Cases that resulted in individuals who no longer qualify were sent an IM-80 PRE allowing 10 days for the individual to respond to the proposed case action. An IM-80PRE and IM-80 were sent, followed by the IM-33C.

NOTE: Adverse Action notices will not be issued until the COVID-19 PHE has ended.

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

KE/kg

IM-26 2021 UPDATED PRESUMPTIVE ELIGIBILITY INCOME GUIDELINES

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  2021 UPDATED PRESUMPTIVE ELIGIBILITY INCOME GUIDELINES

MANUAL REVISION #

APPENDIX A (1900.000.00)

DISCUSSION:

The purpose of this memorandum is to update the income guidelines for Presumptive Eligibility due to the increase in the Federal Poverty Level (FPL). These guidelines are effective from April 1, 2021 through March 31, 2022. Appendix A, found in the Presumptive Eligibility Manual has been updated to reflect the new FPL. 

NECESSARY ACTION:

  • Review this memorandum with appropriate staff.

 

KE/df                                              

IM-25 2021 UPDATE OF POVERTY INCOME GUIDELINES FOR FAMILY MO HEALTHNET (MAGI) PROGRAMS

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  2021 UPDATE OF POVERTY INCOME GUIDELINES FOR FAMILY MO HEALTHNET (MAGI) PROGRAMS

MANUAL REVISION #

1805.030.20.10

1800.000.00 APPENDIX A

1800.000.00 APPENDIX B

1800.000.00 APPENDIX D

1800.000.00 APPENDIX E

1800.000.00 APPENDIX I

FORM REVISION #

IM-4PRM                    

DISCUSSION:

Effective April 1, 2021, the Federal Poverty Level (FPL) income guidelines are increased for:

  • MO HealthNet for Kids (MHK);
  • Children’s Health Insurance Program (CHIP);
  • MO HealthNet for Pregnant Women (MPW);
  • Show-Me Healthy Babies (SMHB);
  • Uninsured Women’s Health Services (UWHS); and
  • All Presumptive Eligibility programs:
    • Temporary MO HealthNet During Pregnancy (TEMP);
    • Show-Me Health Babies Presumptive Eligibility (SMHB-PE);
    • Presumptive Eligibility for Children (PC); and
    • Presumptive Eligibility for Parents/Caretaker Relatives (MHF-PE).

NOTE: New poverty income guidelines for Presumptive Eligibility programs will be provided to Qualified Entities by Income Maintenance Program and Policy.

MAGI cases will be adjusted in April 2021 based on the new FPL income guidelines; however, due to the Public Health Emergency (PHE), no cases will have coverage closed or reduced to a lower level of care due to FPL adjustments until after the PHE has ended. 

PREMIUM REFUNDS

Premiums paid for April coverage will be refunded to the participant if the FPL causes the case to:

  • become eligible as a non-premium case;
  • go from CHIP75 to CHIP74; or
  • go from CHIP74 to CHIP73.

The refund process will take approximately 8 weeks to complete.

REQUEST FOR HEARING/CONTINUED BENEFITS

After the PHE expires, any household receiving an IM-80 Adverse Action Notice may request a hearing on the adjustment action within 10 days from the date of the notice.

If a household receiving an IM-80 Adverse Action Notice requests a hearing on the adjustment within 10 days of the notice, the household benefits continue at the level before the FPL adjustment until the hearing decision is made. Staff should inform the household that if continued benefits are issued and the agency is determined to be correct, a claim will be established for any overpayment.

MAGI MANUAL, PROGRAM DESCRIPTIONS AND OTHER RESOURCES

MAGI Manual section 1805.030.20.10 Income Excluded Under MAGI has been updated to reflect an increase in the tax filer threshold for earned income from a child to $12,400 based on the 2020 IRS Publication 501.

NOTE: The tax filer threshold for unearned income from a child has not increased and remains the same.

The internet pages MHK/MHF/TA Income Chart and Do Your Children Need Health Coverage are updated to include the change in FPL income limits.

NECESSARY ACTION:

  • Begin using the new federal poverty level income guidelines effective for April 2021 and later.
  • Review this memorandum with appropriate staff.

 

KE/al