MEMORANDUM

DISCUSSION:

The purpose of this memorandum is to clarify the verification procedures for Family MO HealthNet programs which became effective with the Affordable Care Act (ACA), and to introduce a calculator to assist in determining reasonable compatibility of income.

The Family Support Division (FSD) must verify all eligibility factors through available means. Available means include but is not limited to information obtained through:

• Electronic data sources,
• Participant’s self-attestation, or
• Other information the FSD has obtained. 

Verification is required at application, annual review, and any other time necessary to determine continued eligibility.

Primary verification will occur through the federal electronic data hub.  If the information obtained through the electronic data hub is reasonably compatible with information provided by or on behalf of the participant, the client’s self-attestation will be used for verification of eligibility. 

Reasonable compatibility, defined in 13 CSR 40-7.010, means the information received by the FSD is not in conflict with other information known by the FSD. See Income Maintenance Manual section 1805.010.20.05 Reasonable Compatibility.

NOTE: The participant must provide permission to access the federal data hub. On the Single Streamlined Application (IM-1SSL), the participant may choose to not allow access to the federal data hub. If so, use other available electronic sources or request secondary verification.

NOTE: Verification of Social Security number, identity, citizenship, immigration status and income are required by law.

If the information is not available on the federal data hub or reasonable compatibility standards are not met, secondary verification is required.  Secondary verification may include:

• Electronic data sources, such as IMES (Employment History), IIVE (Third Party Query System), The Work Number, or SAVE (Systematic Alien Verification for Entitlements);
• Paper documentation; or

• Participant’s self-attestation for residence, age, MAGI household composition, relationship of caretaker relative, pregnancy, and no income or loss of income.  Self-attestation may be provided by a response to a question on the Single Stream-lined Application, or a statement by the applicant, a responsible adult in the applicant's household, authorized representative, or someone acting on behalf of the participant when the participant is a minor or incapacitated, which reasonably explains the discrepancy. Use “other documentation, verified by caseworker” as the verification item and enter a Note into MEDES on the Primary Person Page, Client Contact sub-tab.

Verify income amounts received from income sources that have ended when income is received in the months of an eligibility determination such as month of application or month following, during the prior quarter when prior quarter coverage is requested, or month of annual review.  If income ended before the month of the eligibility determination, such as the month before prior quarter, or before the month of application when prior quarter is not requested, accept the client’s self-attestation that the income terminated.

NOTE: Income from terminated sources may need to be verified when exploring possible overpayments, but don’t delay the current eligibility determination.

When verification cannot be obtained through other sources send a Request for Information (IM-31A) to the participant for any additional information needed. Be specific about the information that is requested including acceptable documents and applicable periods of time.

EXAMPLE: Joe applied for MO HealthNet benefits on Nov 24.  He stated on his application that income from AMAC Construction ended on Oct 20 and he received his last paycheck on Oct 31.  Joe requested prior quarter coverage which would begin Aug 1.  Actual income must be explored for the prior quarter months of August – October.  Electronic data sources were explored first and current month income of $0 verified, but the actual income for the prior quarter months was not found.
A sample of what the Request for Information (IM-31A) may request: “Provide verification of income for Joe from AMAC Construction received from Aug 1 – Oct 31; this could include wage stubs, a completed Employment Information Request form, or a printout or statement from his employer.”

Give the participant ten (10) days from the date the information was requested in writing to provide the required verification.  The application may be rejected on the next business day after the ten (10) days have expired when verification has not been provided. Staff should search ITrackRS and the FSD Work Site for the requested verification prior to rejecting the application.  If the applicant contacts FSD and requests additional time to provide verification, seek supervisory approval prior to allowing the application to pend beyond the 15 or 30 day timeframes.

EXAMPLE: Mary states she has lost her job at Pizza Hut and is unable to provide verification of her termination. Accept Mary's statement of job loss. Request a copy of the last paycheck or the last month's income only when if it was received within the month of application or prior quarter and needed for an eligibility determination.

ACCEPTABLE VERIFICATION BY ELIGIBILITY FACTOR

Residence: Accept the applicant/participant statement, unless a discrepancy that could affect eligibility is discovered based on information that the FSD obtained from electronic data sources or information from other programs.

Age, Date of Birth, And Household: Accept the applicant/participant statement, unless a discrepancy that could affect eligibility is discovered based on information that the FSD obtained from electronic data sources or information from other programs.

Social Security Number:  A participant must provide Social Security numbers (SSN) for all household members requesting coverage. Once the participant has provided the SSN and it is entered into MEDES, if not verified by electronic data sources, it must be verified by paper documentation.

For persons requesting benefits who do not have a SSN, proof of application for the SSN must be obtained prior to the individual's approval. Do not deny or delay approval pending issuance of a SSN once the application for the SSN has been verified.

Individuals failing to complete an application for a SSN or failing to provide an existing SSN are not eligible for MO HealthNet. Include their needs and income in the budget when determining eligibility for the remaining members based on MAGI methodology.  For procedural instructions for these individuals see Income Maintenance Manual section 1805.010.05.05.

EXCEPTIONS: Children who are receiving Newborn coverage based on automatic MO HealthNet eligibility may receive benefits up to one year without providing verification of a social security number

Citizenship and Identity: United States citizens requesting benefits must verify citizenship and identity (ID), if not verified by electronic data sources, they must be verified by paper documentation. 

Section 6036 of the Deficit Reduction Act of 2005 amended section 1903 of the Social Security Act to require states to obtain satisfactory documentation of citizenship and identity prior to approving Medicaid benefits, effective July 1, 2006.

The following individuals are exempt from having to provide documentation of citizenship and identity:

• Individuals receiving Supplemental Security Income (SSI);
• Individuals receiving Medicare; and
• Individuals receiving Old Age Survivors Disability Insurance (OASDI) benefits based upon their own disability.

Refer to Income Maintenance Manual section 0110.020.01 for a complete list of acceptable documents to use as verification of citizenship and/or identity. Also refer to Income Maintenance memorandum IM-60 Citizenship and Identity Verification dated October 28, 2014 for further clarification.

Identity and citizenship of an individual, including name changes may be verified by accessing the Missouri Driver’s License Inquiry (MODL) system.  When accessing MODL, the Detail Identification Inquiry screen must show “US Citizen” in the upper right corner to be used for citizenship verification. (See screen print below)

 

NOTE: For children under age 16, identity (not citizenship) can be verified by the signature of a parent, related caretaker, or legal guardian on the application or review forms. This signature is considered an affidavit to the child’s identity. Do not request verification of identity again when the child turns 16 years old as long as there is continuous eligibility for the child in the household from the time of the prior signed affidavit.

EXAMPLE: Susie applies for benefits for her 15 year old daughter Samantha; the child receives continuous eligibility until her 19th birthday. During the ex parte review it is determined that Samantha is eligible for MPW on her own case.  Now that Samantha is on a separate case, she must provide verification of her identity (and citizenship).

The law allows an individual declaring to be a citizen or U.S. National, a reasonable opportunity to present the documentation. A reasonable opportunity is defined as 90 days from the date of approval. Refer to Income Maintenance manual section 0110.020.02 Reasonable Opportunity to Verify Citizenship for more information. 

If the individual is unable to obtain the required documentation for either citizenship or identity, contact the Income Maintenance Program and Policy Unit for further assistance.

Immigrant Status: All non-citizen applicants for MO HealthNet who declare they are qualified immigrants must provide an alien registration number or a United States Department of Homeland Security (DHS) document to establish immigration status. If immigration status is not available through the Federal Data Hub, enter appropriate information into the SAVE system for verification of status.

NOTE: Micronesians, while lawfully present in the United States, must still provide verification that they meet qualified immigrant status.

EXCEPTION: The DHS SAVE system does not contain information about victims of severe forms of trafficking. Until further notice, do not contact SAVE concerning these individuals. See Trafficking Victims under Section 1805.010.10.35.

Pregnancy: An applicant’s/ participant’s statement of pregnancy and the due date is acceptable verification unless the agency has information that is not reasonably compatible with such statement.  When an application is received which does not include an expected due date, send the applicant a request for information to obtain the expected due date.  If there is no response, contact the applicant by telephone. If the expected due date cannot be obtained by the application due date, enter a due date eight (8) months from the date of application.

Income: Income is calculated by totaling all included household Adjusted Gross Income plus any foreign earned income excluded from taxes, tax-exempt interest, and tax-exempt Social Security income. Refer to Income Maintenance memorandum IM-43 Income Verification for Modified Adjusted Gross Income (MAGI) Programs dated August 25, 2014. See also Income Maintenance Manual sections 1805.010.20.10 Earned Income, 1805.010.20.15 Unearned Income, and 1805.010.20.20 Excluded Income. The applicant/participant attestation of income(s) is then compared to a total of household (all included individual’s) income from electronic data sources.

The total included household income information is reasonably compatible if the sources of income information show:

• The income amounts are:
  • Above the applicable income standard or other relevant income threshold, (ineligible), or
  • At or below the applicable income standard or other relevant income threshold (eligible),

  Or

• The difference between the participant’s attestation of income and the income amount obtained through an electronic data source is ten percent (10%) or less and the sources of income are similar. 

  Sources would be considered similar when the income type in MEDES is the same: wages vs. wages, SSA vs SSA, Retirement vs. Retirement.

If the participant’s statement is reasonably compatible with income information obtained through the federal data hub, other electronic data sources, or income verified for any other FSD program within the last 6 months, use the statement provided by the participant (no additional verification is required).

If verification cannot be obtained through the federal data hub, and verification is available through other electronic sources, use these sources to verify the income. Examples of state electronic sources include, but are not limited to:

• The Federal Hub;
• The Work Number;
• State Unemployment Compensation (IMES),
• Social Security Administration (IIVE),
• Public Assistance Reporting Information System (PARIS)
• Quarterly Wage matches/ New Hire matches;
• Income verified for any other FSD program with the last six (6) months

 
If information is not available from electronic sources, send the participant a Request for Information (IM-31A) specifying any additional income verification needed. Be specific about the information that is requested including acceptable documents and applicable periods of time.  Enter a Note into MEDES on the Primary Person Page, Client Contact sub-tab explaining in detail what information is needed and why.

Manual revisions are forthcoming.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.
• Effective immediately, accept Applicant/Participant Attestation when appropriate.
• Effective immediately use the attached Reasonable Compatibility Calculator.

ATTACHMENT:

Reasonable Compatibility Calculator

AC/ef/mks/df