Electronic Verification System (EVS) Manual

0110.060.15 Fair Credit Reporting Act Authorization

IM-165, December 09, 2020;

The following Electronic Verification System (EVS) sources have additional requirements due to the Fair Credit Reporting Act (FCRA).   

  • Accuity-portal that is utilized for the MO HealthNet for the Aged, Blind, and Disabled (MHABD) program.
  • Benefit Assessment/Accurint for Government Eligibility-portal that is utilized for the MHABD and the Family MO HealthNet (MHN) programs.

The FCRA requires the Family Support Division (FSD) to have permission from the individual in order to match their information with EVS sources that have FCRA requirements.  This permission may be granted by the applicant signing the application, or may require the use of the Authorization for Verification (IM-6EVS) form.  Refer to manual section 0110.060.10 EVS Legal Basis for a more detailed description of the FCRA requirements.

Authorization from applicants and participants:

For all programs, authorization to use EVS, including sources that have FCRA requirements, is received when the application is signed.  This authorization does not extend to individuals who are in the eligibility unit, but are not requesting or receiving benefits.

Authorization when the applicant or their authorized representative does not sign the application:

There are occasions when applications are not signed by the applicant or their representative. 

If the application is not signed by the participant, the participant’s spouse on behalf of the participant, or an authorized representative, the participant’s signature is required on the Authorization for Verification (IM-6EVS) form before EVS sources that have an FCRA requirement can be reviewed. 

FCRA authorization is a condition of MHABD eligibility for applicants and participants.  If FCRA authorization is not provided by signing the application or the supplemental authorization form the MHABD applicant or participant is not eligible for coverage.  FCRA authorization is not a condition of eligibility for any other FSD programs.  Reference manual section 0110.060.15.05  FCRA Authorization Eligibility Factor for MHABD if needed.       

NOTE:  For situations when an authorized representative does NOT represent BOTH the participant and the participant’s spouse, refer to manual section 0803.020.10.10 Appointment of an Authorized Representative when there is a Spouse or Second Parent in the Eligibility Unit.  If the authorized representative who signed the application is not representing the participant’s spouse who is requesting benefits, the Authorization for Verification (IM-6EVS) form must be signed by the participant who is not represented by the authorized representative before FCRA sources can be reviewed. 

Authorization for individuals who are incapacitated:

Individuals who are incapacitated and are not capable of authorizing the electronic verification of assets through the EVS and who do not have another person authorized to sign on their behalf, are not required to provide EVS authorization. The participant is required to submit all verification necessary for the eligibility determination.

Authorization from eligibility unit members who are not applying for or receiving benefits:

The Authorization for Verification (IM-6EVS) form has been created to acquire authorization to review EVS sources with FCRA requirements for individuals who are part of the eligibility unit, but are not requesting or receiving benefits.

The authorization form can be signed by the individual or someone legally authorized to act on their behalf such as an Authorized Representative, Conservator, or Guardian.

If the individual’s information counts towards program eligibility and they are not applying for or receiving the benefit for which an FCRA source is being consulted, the Authorization for Verification (IM-6EVS) form is required before FCRA sources can be consulted. 

For example:  Mr. S is applying for MHABD.  His wife is included in the eligibility unit, but is not requesting coverage for herself.  Staff can review Mr. S’s information in the Accuity and Accurint for Government Eligibility portals because he signed the application.  Staff cannot review Mrs. S’s information in the Accuity and Accurint for Government Eligibility portals until the Authorization for Verification (IM-6EVS) form is signed by Mrs. S. 

NOTE: Authorization to review FCRA sources is an eligibility factor for MHABD applicants and participants only. If an Authorization for Verification (IM-6EVS) form is requested for a non-participant and it is not received the applicant or participant requesting coverage cannot be denied. But the applicant or participant will be required to provide any verification needed from the non-participant.

Eligibility can NOT be denied to an applicant or participant of Family MHN, TA, Supplemental Nutrition Assistance Program (SNAP), or Child Care (CC) if the signed authorization form (IM-6EVS) is not received. The participant will be required to provide any requested verification needed to determine eligibility. Staff should follow normal policy for required verification for these programs.

As well as providing authorization for FSD to electronically verify his/her information, the individual may need to provide his/her Social Security number, date of birth, maiden name or other name known by, and residence in order to verify information through the EVS.  Since it is not a condition of eligibility that this information be provided by a non-applying individual, eligibility for the participant can NOT be denied or discontinued due to the individual’s failure to provide this information. 

The authorization to review EVS data remains valid until:

  • The Family Support Division (FSD) rejects the application;
  • Benefits are terminated; or
  • FSD receives a written and signed revocation.