Classic (non-MAGI) based programs manual

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Asset verification

Revised Date: 
December 18, 2019

Purpose: To explain the asset verification system (AVS) and new program requirements for applicants and recipients of long-term care services. 

WAC 182-503-0055 Asset verification system

Effective 11/3/2019

  1. This rule implements the asset verification system (AVS) outlined in section 1940 of the Social Security Act
  2. This rule applies to any client, or those financially responsible for them, who is subject to: 
    1. The disclosure of resources, as defined in WAC 182-512-0200, to determine eligibility; or
    2. Provisions related to the transfer of assets; as described in WAC 182-513-1363
  3. For purposes of this section: 
    1. "Financial institutions" means the same as defined in section 1101 of the Rights to Financial Privacy Act, and may include, but is not limited to: 
      1. Banks; or
      2. Credit unions.
    2. "Financial record" means any record held by a financial institution pertaining to a customer's relationship with the financial institution; and 
    3. Financial responsibility is described in WAC 182-506-0015.
  4. You and any other financially responsible people must provide authorization for us to obtain any financial record held by a financial institution. The authorization may be provided by anyone described in WAC 182-503-0010 (1) and (2), except in the case of an authorized representative who must be designated  by the client. 
  5. The authorization, provided under subsection (4) of this section, will remain in effect until one of the following occurs: 
    1. Your application for apple health is denied; 
    2. Your eligibility for apple health is terminated; or 
    3. You revoke your authorization in a written notification to us. 
  6. We will: 
    1. Use the authorization provided under subsection (4) of this section to electronically verify your financial records and those of any other financially responsible person to determine or renew your eligibility for apple health; or
    2. Inform you in writing at the time of application and renewal that we will obtain and use information available through AVS to  determine your eligibility for apple health. 

This is a reprint of the official rule as published by the Office of the Code Reviser. If there are previous versions of this rule, they can be found using the Legislative Search page.

Clarifying information

Section 1940 of the Social Security Act 2008 (42 USC 1396w), requires all states to implement a system to verify resources/assets of aged, blind, or  disabled applicants and recipients of Medicaid through the use of an asset verification system. This includes individuals applying for or receiving long-term services and supports (LTSS) or Medicare Savings Program benefits. 

The AVS searches client financial institution accounts via several methods: 

  • Automatically searches for accounts at the top 12 largest financial institutions in the United States
  • Automatically searches for accounts at certain financial institutions near the client's residential address, via a geographic search algorithm
  • Allows financial eligibility staff to directly search for accounts at financial institutions where we believe the applicant/recipient has an account that may not be captured in the above automatic searches

AVS reports on the following account types: 

Checking accounts

 

Christmas club accounts

Savings accounts

Trusts

Certificate of deposit

Burial accounts

Money market accounts

Keogh accounts

IRA accounts

Rent security

The information received from financial institutions is reviewed by the financial eligibility staff and they resolve discrepancies with the client prior to the eligibility determination.

AVS does not change how financial eligibility staff handles questionable situations; AVS is another tool to use to determine eligibility.

Clients, and those financially responsible for them, must provide authorization before a request can be submitted in the AVS.

Once a client or financially responsible person gives authorization for use of AVS, it remains in place until the client or their spouse cancels the authorization in writing, they are no longer eligible for coverage, or the application is withdrawn or denied.

At application:

  • For Medicaid programs that do not have a 60 month look back period, the AVS will provide 4 months of bank balance data from application date.
  • For Medicaid programs that have a 60 month look back period, the AVS will review the 60 month period from application date. 

At renewal:

  • AVS will provide banking information for the review month.

Worker responsibilities

NOTE: For detailed AVS procedures please refer to your agency's AVS procedures documentation.

 Check for a valid authorization. Clients and those who are financially responsible for them, must provide authorization before a request can be submitted to the AVS. The authorization remains in place until the client, their spouse, or the financially responsible person cancels the authorization in writing, they are no longer eligible for coverage, or the application is withdrawn or denied.

For applications where both spouses apply for LTSS, two searches are needed. 

  • Create one search for each head of household and add the spouse as the secondary household member on the search query.

At review: only the recipient is checked through AVS. The only exception is at the first review for a married couple, so eligibility staff can be sure that the client allocated all resources in excess of $2,000.00 to their spouse.

Financial staff must contact the applicant or recipient and give them the opportunity to provide the needed information to resolve a discrepancy and determine ongoing eligibility when AVS returns information that indicates: 

  • Inconsistent withdrawals during the look back period; or 
  • Bank accounts that are over the resource standard; or
  • Accounts not listed on the application, or disclosed during the interview; or 
  • Any other questionable information.

It is a best practice to call the client or authorized representative to review what is needed and then send a 10-day request letter for explanation.

Financial eligibility staff cannot deny or terminate a case based solely on the information received from AVS or LexisNexis.

If the client is ineligible due to transfers in the 60 month look back period, determine if there is eligibility for another medical program without a look-back period: 

  • S99 if client is resource eligible
  • MSP if the client is resource eligible
  • HWD if the client is disabled and working
  • TSOA eligibility

At application or eligibility review, once AVS results are received, document the client's resources in ACES.

For approvals: only remarks are needed for documentation. It is the financial worker's responsibility to adequately remark that resource verification was received from AVS.

For  denials or terminations: a copy of the AVS report is required in addition to adequate remarks. Print the "Case Summary Report" from the AVS Summary page and send to DMS.

Once a final eligibility determination is made, either approval, denial, or termination; the case eligibility needs to be closed out in AVS.

There are four options for closing the case in the AVS portal: 

  • Closed/Withdrawn
  • Eligible
  • Ineligible
  • Other

Closed/Withdrawn: used when an applicant withdraws a case (and worker subsequently needs to withdraw the case) or if the worker determines that an AVS check is no longer needed for an individual.

Eligible: used when an individual is determined as under the resource limit.

Transfer Penalty: used when an applicant or recipient is denied or terminated for a transfer that makes the client ineligible. 

Ineligible: for cases being closed due to "ineligible," additional options for reporting will generate. Financial workers are required to select the correct reason at closure:

  • Over Resources - Financial Accounts - used when the bank balance was the primary reason for ineligibility.
  • Over Resources - Real Property - used when the real property that was known about outside of the AVS was the primary reason for ineligibility.
  • Over Resource - Real Property and Financial Accounts - combination of the two items above. 
  • Other - used when the reason for ineligibility falls outside of the other options. For instance, income ineligibility or citizenship.