Family MO HealthNet (MAGI)

1805.030.15 Reasonable Compatibility

IM-#39 March 15, 2019, IM-#96 July 13, 2017, IM-46 May, 12, 2017, IM-7 January, 27, 2017, IM-#97, November 9, 2015

Reasonable Compatibility (RC) is defined as the allowable difference between the self-attested income and the income reported by the Electronic Data Sources (EOI).

RC is used to confirm the self-attestation of income. When the self-attested income is not RC with the EOI further clarification is required from the individual to substantiate the self-attested income.

NOTE: RC’s primary purpose is to determine if further clarification should be requested from the individual. When the income is not RC, the EOI returns no response or an error, or when the self-attested/EOI information is questionable; further clarification should be requested.

Income is considered RC when:

      • Both the self-attested income and the EOI fall within the same MO HealthNet program eligibility threshold.

OR

      • The self-attested income is below the MO HealthNet program eligibility threshold and EOI falls in a different MHN program category above the threshold, but the EOI is within 10% or less of the self-attested income.

NOTE:  The eligibility determination is based on the self-attested income.  Neither RC nor the EOI are used to make an eligibility determination.

Income is NOT considered RC when:

  • The self-attested income is above the MO HealthNet program eligibility threshold and EOI falls in a different MHN program category below the threshold.

NOTE: Whether the difference is within 10% or not, income is not considered RC and additional verification will need to be requested.

Whenever there is a Change in Circumstance (CIC) that affects the budget, RC should be applied to determine if further clarification is needed from the individual. RC should be applied in the following situations, as appropriate:

      • Application
      • Annual Renewal
      • Ex-parte Review
      • Add/Remove a Person
      • Marriage/Divorce
      • Income Change

When self-attestation of the employer, or the income source, is different than what is received from the EOI, determine if the sources are compatible. The sources are considered compatible when:

      • income from both sources fall within the same MHN category or
      • the self-attested income is below the threshold and the EOI amount is above the threshold but is within 10% of the self-attested amount, and

If the employers/income sources are compatible accept self-attestation for the income source.

NOTE:  If our records indicate a different employer/income source than what is self-attested, and the employers/income sources are compatible, do not request verification that the income source in our records has ended.  It is appropriate to accept self-attestation in this situation.

Paystubs are considered the individual’s self-attestation and the verification of income. Paystubs trump the information returned by an EOI when there are discrepancies. Use the pay stubs as verified income evidence.

EXAMPLE:  Sue provided her weekly pay stubs for the past 4 weeks with her application. Her pay stubs are used as Sue’s attestation and verification of her income. With Sue’s pay stubs/self-attestation, Sue’s income is below the eligibility threshold for MHK (148% of FPL). The EOI shows income above the eligibility threshold for MHK and more than 10% difference from the pay stubs.

Outcome: Based on her self-attestation, Sue is MHK eligible. RC does not need to be explored as the pay stubs are considered verified and reflect information more recent than the EOI.

When pay stubs are provided, RC does not need to be completed.

Explore RC with all available EOI before requesting additional information/clarification from the individual.

Applying Reasonable Compatibility

To determine if the income is RC gather the following information:

      • household size,
      • MO HealthNet program’s income threshold for the household size,
      • self-attested income, and
      • electronic data source income.

The MO HealthNet program thresholds are grouped together as listed below.

      • MHF – MHF income limit for household size
      • MPW – 196% of the FPL
      • Children under the age of 1 – 196% of the FPL
      • MHK for children age 1 to age 18 – 148% of the FPL
      • CHIP 71/72 – 150% of the FPL
      • CHIP 73 – 185% of the FPL
      • CHIP 74 – 225% of the FPL
      • CHIP 75 – 300% of the FPL
      • SMHB – 150% to 300% of the FPL
      • UWHS – 201% of the FPL

NOTE:  RC should be applied to each CHIP category (CHIP 71/72, CHIP 73, CHIP 74, and CHIP 75) separately.

Applying the 10% Reasonable Compatibility Test

The income is considered RC when the self-attested income falls below the MO Health Net program income threshold and EOI falls above, and the EOI is within 10% of the self-attested amount. This is called the 10% Reasonable Compatibility Test.

To apply the 10% RC Test, complete the following steps for each individual in the household with income:

      • Compare the individual’s self-attested income to the individual’s EOI. If the self-attested income is below the threshold,
      • Determine if the EOI is within 10% of the self-attested income.

        NOTE:  MO HealthNet eligibility is determined for each individual by the individual’s household size and applicable income. Since households are determined by the tax filing unit, each person in the household could potentially have a different household size.

If the self-attested income is below the threshold and the electronic data source income are within 10% of each other, the individual’s income is reasonably compatible.  Use the self-attested income for the budget and eligibility determination.

OR

If the self-attested income is below the threshold and the EOI is above but not within 10% of each other, or the self-attested income is above the threshold while the EOI is below, or the self-attested income and the EOI fall in different MO HealthNet program thresholds, the individual’s income is not reasonably compatible.  Request a reasonable explanation to clarify the difference between the self-attested income and the electronic data source income. 

OR

If a reasonable explanation is not given or the explanation given is not reasonable, request further verification.

EXAMPLE:  George self-attested his income at within the MHK threshold (148% of the FPL), the electronic data source income for George was within CHIP 71 threshold (150% of the FPL), but his self-attested income and the electronic data income was within 10% of each other.  George’s income is reasonably compatible.  He would be eligible at the MHK category level based on his self-attestation.

NOTE: When applying the 10% Reasonable Compatibility Test and one of the household member’s income passes the 10% Reasonable Compatibility Test and another household member’s income fails, only request a reasonable explanation/clarification for the income that failed the test.

Attested Income Electronic Data Source Outcome
Is below the income eligibility threshold. Is below the eligibility threshold. Self-attested income is used.  Individual is eligible.  10% Reasonable Compatibility Test is not required.
Is below the income eligibility threshold. Is above the eligibility threshold. The 10% Reasonable Compatibility Test is required.
Is below the income eligibility threshold. Is not available. Request additional verification/clarification.
Is above the income eligibility threshold. Is above the income eligibility threshold. Individual is ineligible.  10% Reasonable Compatibility Test is not required.  Refer to the FFM.
Is above the income eligibility threshold. Is below the income eligibility threshold.

Request additional verification/clarification.

Is above the income eligibility threshold. Is not available.

Request additional verification/clarification.

Refer to the Reasonable Compatibility Calculator within the MAGI Policy Manual, Appendix B.