Category: MoHealthNet Home

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

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

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

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:

• 0105.010.00 Signing the Application
• 1802.020.00 Signing the Application

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

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

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:

• statutorily blind individuals is $2,190.00
• non-blind individuals is $1,310.00

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

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  COVID-19 VERIFICATION FOR FAMILY HEALTHCARE PROGRAMS (MAGI) UPDATE AND CLARIFICATION

DISCUSSION:

The purpose of this memorandum is to provide clarification to Memo IM-19 COVID-19 Verifications for Family Healthcare Programs (MAGI).  IM-19 introduced temporary policy to allow Family Support Division (FSD) to waive many eligibility verification requirements for MAGI programs during the COVID-19 public health emergency (PHE.)

For the duration of the PHE, applications can be rejected for various reasons, but active cases can only be closed in certain circumstances.  Cases on which a Request for Information (IM-31A) is sent, but no response is received, will require review after the PHE ends. For this reason, send IM-31As as a last resort.  Utilize all available resources. This includes but is not limited to, IMES, IIVE, and/or FAMIS and use sound judgement before attempting contact with the participant. 

For more information about contacting participants, see the updated MEDES COVID-19 Self-Attestation Guide.

Resume Reasonable Compatibility

Per clarification from the Division of Legal Services, resume use of Reasonable Compatibility (RC) procedures to attempt to confirm self-attested income.

• If electronically obtained information (EOI) is RC with self-attested income, verify the evidence with RC.
• If EOI is not RC with self-attested income, but the EOI does not clearly contradict self-attested income, verify the income as self-attested. See the MEDES COVID-19 Self-Attestation Guide for examples.
  • Enter a comment to describe the self-attested income and electronic data. Include in the comment “self-attestation accepted due to special circumstances.  42 CFR 435.952(c)(3).”
• If EOI is not RC with self-attested income and clearly contradicts self-attested income, contact the participant. See the MEDES COVID-19 Self-attestation Guide for examples.

Included Income Types

 The participant must provide enough information about the income to determine an income amount in order for the income to be considered self-attested.  If income cannot be considered self-attested, contact the participant.

EXAMPLE:  Marcy is processing a change report on which the participant claimed a job at Wal-Mart making $12.75 per hour. The participant didn’t list weekly hours or a gross amount and pay frequency.  Marcy cannot determine self-attested income with this information.

Excluded Income Types

Do not send an IM-31A to request clarification of an excluded/non-countable income type.  If a current amount can be found on an available resource (such as IIVE for SSI or INTRFACE for child support) enter the amount found on the available resource.  Add a note to explain where the information was obtained and what, if anything, the participant reported about the income.

File IMES, IIVE, or other resources in the electronic case record, as directed by policy.

Tax Filing Status

Continue to accept self-attestation of tax filing status.  If tax filing status is not declared for a participant, contact the participant for more information.        

 Reasonable Opportunity

 Follow normal procedures to allow a reasonable opportunity period except: 

• Accept self-attestation of a pending SSN application for participants eligible to receive a reasonable opportunity period.
• Accept self-attestation of application for a birth certificate for participants eligible to receive a reasonable opportunity period.
• See the MEDES COVID-19 Self-attestation Guide for more information.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.
• Review the updated MEDES COVID-19 Self-attestation Guide.
• Exhaust all available resources for verification before attempting contact with a participant.
• Attempt phone contact before sending an IM-31A.

KE/ers/al/ams/kg