378.3 County Assistance Office Responsibility

Manual Requests for Asset Verification through the Asset Verification System (AVS), OPS180103 (Published January 30, 2018)

 

The CAO is required to complete an “ex-parte” review of information and use information available through electronic data sources or information in the existing case record before requesting paper verification from the individual.  

42 CFR §435.952(c)

 

An “ex-parte” review is required to be completed at application, renewal, and when a change is reported. See Appendix I for the MA Ex-Parte Review Checklist. The checklist is a resource that the CAO can use when completing an “ex parte” review.

 

The CAO will request information from the individual if the CAO is unable to verify information through electronic data sources or if information obtained through electronic data sources is not reasonably compatible with the information reported by the individual.

 

The CAO will decide what information needs to be confirmed from:

 

  55 Pa. Code § 201.1

55 Pa. Code § 201.4(1)(iii)

55 Pa. Code § 125.21(b)

 

Sources of proof include the following:

 

 

PMA17324378 Changes in SSA Field Office Verification Services October 2, 2014

 

The CAO must help the applicant, when necessary, in getting the required proof.           

 

55 Pa. Code § 201.1

 

The caseworker should keep in mind that, because of age, physical or mental disabilities, language problems, and other reasons, an individual may not be able to help or prove he or she is eligible for MA. The individual will always be told that the worker can help him or her. The CAO will take an active role in helping individuals with mental or physical disabilities obtain needed citizenship or identity papers or third-party resources that can help pay medical expenses.

55 Pa. Code § 201.1(2)

 

The CAO will not require the individual to provide original documents for verification purposes. The CAO will accept duplicates including copies, faxed, or scanned documents as verification, unless there is a genuine issue as to the authenticity of the duplicate. 

 

If the proof the individual uses is not appropriate, not complete, or not consistent with other information, the caseworker will tell the individual that more proof is needed. The caseworker and the individual must decide what other proof can be used. If the proof the individual provides is still unacceptable, the caseworker will make a collateral contact, using a copy of the PA 4 when it is needed.        

  55 Pa. Code § 201.4(1)(iv)

 

If the individual is unable to provide necessary verification due to a third party delay and is cooperating in the verification process, the CAO will authorize/reauthorize MA and will set up a plan with the individual for obtaining the needed proof within the following time limits:    

 55 Pa. Code § 201.4(1)(iv)

55 Pa. Code § 201.3

 

55 Pa. Code § 125.21(b)

 

NOTE:  It is the CAO’s duty to get the needed proof before approving benefits.

 

     55 Pa. Code § 133.23(a)(3)(i)

 Information about medical resources is needed within thirty calendar days after the renewal.

  55 Pa. Code § 133.84(d)  

    55 Pa. Code § 133.84(d)  

 

NOTE:  For verification of U.S. Citizenship and satisfactory immigration status, cooperation is not a factor.

 

If an applying individual declares to be a U.S. Citizen or to have satisfactory immigration status, the CAO must attempt to verify Citizenship/Immigration Status for all applying individuals through electronic data sources. If the CAO is unable to verify information through an electronic data source, the CAO must request verification from the individual in writing and allow a reasonable opportunity period of 90 days for the individual to provide the verification. The CAO must allow five days for mailing the request. The system automatically sets a VERF 062 alert for 101 days to cover the Reasonable Opportunity Period and provide the caseworker with additional time to clear the alert.

 

See Chapter 322, Citizen/Noncitizen for additional information.

 

Reminder: The CAO will clearly identify and explain to the applicant what proof is needed to determine eligibility for MA. Approval of MA must not be delayed while waiting for proof for Cash Assistance or SNAP. Additionally, approval of ongoing MA must not be delayed while waiting for proof necessary to authorize retroactive MA.

If the applicant has cooperated but is still unable to provide acceptable evidence, the CAO must make a collateral contact. (See Section 378.4, Collateral Contacts.)       

   55 Pa. Code § 201.4(1)(i)  

 

If the individual does not cooperate in obtaining proof, the CAO will send a PA 162 Not Eligible notice to applicant if the individual is an applicant or a PA 162 Advance Notice if the individual is a recipient. These notices include the following:

 

NOTE: See Chapter 377, Notices, for complete information about client notices.

 

The record must clearly show eligibility or ineligibility. The CAO will explain in the record any decision to ask for more sources of proof or proof of inconsistent information.

 

The CAO must verify all income used in an MA eligibility determination even if it appears that the individual is not eligible for MA based on the income reported.  Children who have no private health insurance and are ineligible for MA due to income are referred to the Children’s Health Insurance Program (CHIP) through Healthcare Handshake process. When CHIP receives a referral, CHIP accepts income information as verified upon receipt and does not request verification.                                                          

If the reported income can be verified through a data source and both reported income and data source income are above the MA income limits, income is considered reasonably compatible and the verified electronic data source income can be used to reject the application or close the budget.

If income cannot be verified through a data source, reported income is not reasonably compatible with a data source, or reasonable compatibility is not a factor, refer to Chapter 378.1 then the caseworker must request income documentation from the individual by sending a PA 253. If income verification is not returned by the applicant, the application must be rejected using reason code (042), Failure to Furnish Required Information.

378.31 Verification at Application

At application an “ex-parte” review must be completed.  The CAO will review electronic data sources and information in the existing case record to obtain verification before requesting the documentation from the individual. If the individual’s statement is required to be verified and the verification is not available through electronic data sources or if information obtained electronically is not reasonably compatible with the information reported by the individual, the CAO will ask for verification from the individual.

 

Reminder: For a child under age 21, the following items will be obtained from the parent’s or caretaker’s statement: Social Security Number, age and date of birth, and who is in the household. If the family notes on the CHIP application there is third-party insurance, contact the family and get the information.


Items that must be verified include the following:

 

 

42 CFR §435.910

 

The CAO must not delay or deny MA to an otherwise eligible individual pending issuance or verification of an SSN by SSA or if the individual meets one of the following exceptions to providing or applying for an SSN:

 

55 Pa Code § 181.3

42 CFR §435.603

 

If the CAO is unable to verify income through electronic data sources or information obtained through electronic data sources is not reasonably compatible with the information reported on the application, individuals can provide a single pay stub (weekly, bi-weekly or monthly) that is representative of the income received and the information will be used in the eligibility determination, either at application, renewal, or SAR. Pay stubs for a full month's income are not required.

It is acceptable verification for individuals to provide a single pay stub received within a 60-day period prior to the application date if it is representative.

If an individual reports having no income and electronic data sources do not contradict this, the CAO does not need to ask for further information from the applicant, unless the applicant’s statement contradicts CAO records or is questionable.

For Quarterly Income Wage Hits from the Department of Labor & Industry (DLI), the quarterly amount should be divided by 13 and then multiplied by four.

Exception: Income that is known to be received once or twice per month should still be divided by three.

Note: If the total weeks worked in a quarter is less than 13, the income amount should be divided by number of weeks worked then multiplied by four.

If the recipient reports a job loss, third-party verification of termination should be required only if the verification is necessary to calculate the client’s monthly income to determine eligibility or for adjusting recent benefits. Verification can be obtained verbally via collateral contact, through written communication, or using the PA 1898. The CAO may discuss this reported information to determine how the recipient is living and paying bills and narrate the explanation. Additional proof is not necessary unless the client’s statement that the job ended is questionable. This determination should be narrated as well.

 

Example:  A client applies for MA and states that her job ended a couple months ago.  She states she is behind on her mortgage and utility bills.  The caseworker will narrate the client’s explanation and authorize benefits, provided that all other eligibility factors are met. The caseworker will not require proof that the job terminated.

 

Example:  A client applies for MA and requests retroactive MA for a hospital bill from 2 months ago. The client states she stopped working sometime in the last couple of months due to her health problems. Due to the unclear end date of employment, the CAO should narrate that the client must provide proof of when the job terminated and paystubs from the start of the retroactive MA period up until the last paycheck.

 

NOTE: If the client is applying for a MAGI-related category of MA only, proof of income termination is not required if the client’s self-reported income and income information obtained electronically through a data source are reasonably compatible. The CAO will use the information from the data source as verification of income.

 

 

55 Pa Code § 181.3

42 CFR §435.603

 

NOTE:  If the individual fails to verify any allowable deductions, the CAO must determine eligibility without giving the deductions. The CAO will not deny benefits if the individual failed to provide verification of allowable deductions and no other eligibility factors require verification.

 

 

NOTE: Child support is excluded for MAGI MA eligibility determinations but may still need to be verified if household members can potentially qualify for non-MAGI MA.

 

55 Pa Code § 178.3

Exception: Resources are still required to be verified if there is a child under 21 in the household for Buy-In-only categories (TA/TJ 65 and 67) and MAWD categories, unless the applicant is under age 21.

 

The CAO will use the Asset Verification System (AVS) to request resource information for non-MAGI MA applicants and recipients who are:

 

If the AVS and the individual report the same resources and the total value of resources reported are within the applicable resource limit, then workers will not wait for additional resource verification. If the AVS response includes unreported resources, the worker will issue a PA 253 to provide the verification. AVS is not to be used for categories and situations that do not require a resource evaluation.

 

For MAGI-eligible individuals, all reported resources will be entered in eCIS but verification will not be requested unless the individual makes a request to be evaluated for non-MAGI MA. For SSI-related MA individuals who did not provide verification of resources or are over the resource limit, the CAO will review the individual for MAGI-related MA if the individual meets the criteria for a MAGI-related MA category.

 

NOTE: Resources are excluded for MAGI MA eligibility determinations, including MG 90 D.

 

     The CAO should not reject an application for failure to provide resource verification if the individual is eligible for MAGI MA.

 

42 CFR §435.603(g)(1)

 

55 Pa Code § 178.3

 

 

55 Pa. Code 178.3(1)

MA should not be delayed or terminated for an individual whose responsible relative fails to cooperate in identifying and verifying TPL information.  

42 CFR 433.148 (b)

 

NOTE: All third-party health insurance must be entered into eCIS. This will ensure that all third-party insurance is billed before MA. This is also needed if a child is over-income for MA, as this will prevent a referral to CHIP since federal law prohibits a child from having other health insurance with CHIP.

 

 55 Pa Code § 178.6

 

55 Pa Code § 150.1

 

If an applying individual declares to be a U.S. Citizen or to have satisfactory immigration status, the CAO must attempt to verify Citizenship/Immigration Status for all applying individuals through electronic data sources. If the CAO is unable to verify information through an electronic data source, the CAO must request verification from the individual in writing and allow a reasonable opportunity period of 90 days for the individual to provide the verification. The CAO must allow five days for mailing the request. The system automatically sets a VERF 062 alert for 101 days to encompass the Reasonable Opportunity Period and provide the caseworker with additional time to clear the alert.

 

See Chapter 322, Citizen/Noncitizen for additional information.

 

  55 Pa Code § 125.1(b)

 

The CAO must use electronic data sources for verification. The CAO will request verification of identity only if the electronic verification fails. Once identity has been verified, the CAO must not require the individual to provide verification in the future.

 

The following must be verified if part of the case record:

 

  

  55 Pa Code § 178.11(4) (ii)

55 Pa Code § 178.12(5) (ii)

 

NOTE: For MAGI-related MA, an individual does not need to be related to the child to be a specified relative in the parents/caretakers category.                                                                                           

42 CFR §435.4 (3)

 

62 P.S. 481.1

 

 

NOTE:  Proof of employment includes, but is not limited to, pay stubs, tax records, and letters from employers.

 

   55 Pa Code § 141.61(c) (1)  

 

If a case record already has proof of information that is not likely to change (for example, birth date, citizenship, identity, health insurance, address, or Social Security number), the CAO must not require proof again unless information does not match up.

 

As long as the applicant cooperates in getting proof, the CAO will approve MA within thirty calendar days from the date of application. If the CAO cannot make a decision in thirty days, they may extend the period to forty-five calendar days, as long as the applicant is told the following in a letter:

 

If the CAO approves MA while waiting for proof, they will allow thirty more calendar days after the approval date for proof to be provided. As long as the applicant cooperates and the delay is caused by a third party, the CAO will continue benefits for thirty more calendar days. The CAO will allow more thirty-day periods if they are needed due to a third party delay.   

 55 Pa Code § 125.21(b) (2)

 

If the applicant refuses to cooperate in getting proof, the CAO will deny benefits.     

  55 Pa Code § 201.1  

378.311 Past Management

Past management is considered when an individual states how he or she has been living or who is the source of the income used to meet the individual’s needs.

 

Proof of past management is only needed if information provided is questionable or inconsistent. The CAO should accept the individual’s statement if it is reasonable. If proof of the individual’s past management is needed, the individual must give the name and most recently known address of the source. The individual will be asked to give written or other proof, including a letter from the source, of how much assistance is currently available. Verification can be written or verbal via collateral contact.

 

Past management, like the other factors,will be discussed only as much as is necessary to understand the individual’s present situation and to find out how much assistance is still provided.       

55 Pa Code § 125.24(c) (7) (ii)

Example: Elizabeth applies for MA and reports no income. Electronic data sources do not indicate any current employment or income for Elizabeth. The CAO does not need to request any income verification from Elizabeth or to contact her to discuss past management as there’s nothing contradictory or questionable.

Example: Maryann applies for MA and reports no income. However, she states on the application that bills are being paid, but it’s getting harder. Electronic data sources do not indicate any employment or income for Maryann. Because of the contradiction, the CAO contacts Maryann to discuss past management. Maryann states that her parents are providing her with money for living expenses. The CAO must request verification of this arrangement.

 

378.32 At Renewal

Social Security Administration (SSA) Renewal and Redetermination Verification (RRV) Interface Service at Enhanced Medical Assistance Renewal (EMAR), OPS180305 (Published March 22, 2018)

At renewal, the CAO must verify the following:           

55 Pa Code §  133.73

55 Pa Code §  133.83

 

Individuals can provide a single pay stub (weekly, bi-weekly or monthly) that is representative of the income received and the information will be used in the eligibility determination, either at application, renewal or SAR. Pay stubs for a full month's income is not required.

 

It is acceptable verification for individuals to provide a single pay stub received within a 60-day period prior to the date the renewal is received by the CAO.

Example: MA case is due for renewal for two children. The CAO was not able to verify the children's parents' income through electronic data sources and mailed a renewal packet requesting income verification.  Mr. Smith provides a pay stub with a gross income of $613.75. He is paid bi-weekly. The caseworker will use this single pay stub to make the MA determination by converting the income to a monthly amount.

NOTE:This policy does not eliminate the requirements for the caseworker to verify income when another source of income does not support the determination made based on the single pay stub or income that was received within the 60 day period prior to application or renewal.

      Example: Caseworker gets an IEVS hit for the third quarter that shows the individual received $7,500 wages from John Public Construction but the pay stub that was presented for this company stated $300 a week which converts to $1,200 a month.  Since there appears to be a discrepancy, the caseworker must confirm the individuals past and present income to establish past and future eligibility.

If an individual reports having no income and electronic data sources do not contradict this, the CAO does not need to ask for further information from the applicant, unless the applicant’s statement contradicts CAO records or is questionable. If not questionable, eligibility must be reviewed based on $0 income.

Example: Frank is open MG 91 based on $0 income. At application, he reported he lives with his grandmother, who allows him to stay rent-free. At renewal, the CAO reviews electronic data sources and finds no current employment or income information for Frank. The CAO must review Frank’s continuing eligibility based on $0 income.

For Quarterly Income Wage Hits from the Department of Labor & Industry (DLI), the quarterly amount should be divided by 13 and then multiplied by four.

Exception: Income that is known to be received once or twice per month should still be divided by three.

Note: If the total weeks worked in a quarter is less than 13, the income amount should be divided by number of weeks worked then multiplied by four.

Note: Child support is excluded for MAGI MA determinations.

Note: If the individual fails to verify any allowable deductions, the CAO must determine eligibility without giving the deductions. The CAO must not deny benefits if the individual failed to provide verification of allowable deductions and no other eligibility factors require verification.

 

Exception: Resources are still required to be verified if there is a child under 21 in the household for Buy-In-only categories (TA/TJ 65 and 67) and MAWD categories, unless the applicant is under age 21.

 

The CAO will use the Asset Verification System (AVS) to request resource information for non-MAGI MA applicants and recipients who are:

 

If the AVS and the individual report the same resources and the total value of resources reported are within the applicable resource limit, then workers will not wait for additional resource verification. If the AVS response includes unreported resources, the worker will issue a PA 253 to provide the verification. AVS is not to be used for categories and situations that do not require a resource evaluation.

 

For MAGI-eligible individuals, all reported resources will be entered in eCIS but verification will not be requested unless the individual makes a request to be evaluated for non-MAGI MA. For SSI-related MA individuals who did not provide verification of resources or are over the resource limit, the CAO will review the individual for MAGI-related MA if the individual meets the criteria for a MAGI-related MA category.

 

Note: Resources are excluded for MAGI MA determinations, including MG 90 D.

 

The CAO should not close MA for failure to provide resource verification if the individual is eligible for MAGI MA.

 

The following things must be proven if they are part of the case record:

  62 P.S. 481.1

At a Partial Renewal for Breast and Cervical Cancer Prevention and Treatment (BCCPT), the need for continued treatment must be proven. The CAO will be notified by a fax from OMAP of the continued need for treatment, less treatment, or the stopping of treatment because (a) the treatment is no longer medically necessary or (b) because the  individual has not provided proof of the need for treatment.    

Public Law 106-354

 

When processing a complete renewal for the BCCPT program, the continued need for treatment for breast or cervical cancer or for a precancerous condition of the breast or cervix must be proven. If credible coverage is shown on the renewal papers, it must also be proven.  

     Public Law 106-354

 

If a case record already has proof of information that is not likely to change (for example, birth date, citizenship, identity, health insurance, address, or Social Security Number), the CAO will not ask for proof again unless information does not match.

 

The CAO will allow the recipient at least 30 days from the date the renewal form is mailed to provide any needed proof. If all other conditions of eligibility for MA are met except proof of identity, and the individual is cooperating with CAO staff in getting the proof, MA must not be denied or stopped while waiting for proof.      

55 Pa Code § 133.23(a) (3) (i)

42 CFR §435.916

 

If the recipient cooperates but cannot meet the 30 day deadline because of a third party, then the CAO will continue MA and allow more time for proof to be provided. The CAO will review cooperation  every thirty days.    

 

55 Pa Code § 133.23(a) (3) (i)

55 Pa Code § 125.21 (b)

 

If the recipient does not cooperate in giving proof, the CAO will send an Advance Notice that benefits will end. The notice must tell the recipient what proof is needed for continued eligibility for MA.                                                   

55 Pa Code § 201.1 (1)

378.33 A Change Takes Place

When the CAO learns of a change, the CAO must review the case for continued MA eligibility.

 

When there is a change that affects eligibility, the CAO must complete an “ex-parte” review and attempt to verify information through electronic data sources before requesting information from the individual. See Appendix I for the MA Ex-Parte Review Checklist.

 

If required verification is not available through electronic data sources or if information obtained electronically is not reasonably compatible with the information reported by the individual, the CAO will ask for verification from the individual.

42 CFR §435.952 (c)

 

The CAO will allow no more than thirty days from the date the CAO learns of the change for the recipient to provide the proof.  If the recipient is cooperating but cannot get the proof because of a delay caused by a third party, MA will continue until proof is received. The CAO will review progress every thirty days.      

  55 Pa Code § 133.84 (d)   

 

When a recipient asks the CAO to close his or her case, the CAO will find out why. If it is because the individual has income, the CAO will verify when the individual received it and the gross amount. If the reason for the closing is unknown or cannot be confirmed, the CAO will narrate the information in the case record. If the individual applies for MA again, the CAO will verify the information that was unknown and verify that a resource causing the closure no longer exists.

55 Pa Code § 255.3(d)

378.34 When a Fair Hearing Is Pending

An individual who files a timely appeal of adverse action may submit new or extra proof of eligibility at any time up to and including the fair hearing. If proof shows that the individual was eligible for MA, he or she can get retroactive benefits.          

 55 Pa. Code § 275.4(a)(3)

 

The individual does not need to show that the CAO made a mistake in stopping, denying, or reducing benefits.

 

When the individual provides the needed proof, the CAO will:

 

Example: Mr. Landry (age 67) submitted an MA application on February 2. Both Mr. Landry and his wife (age 65) applied for benefits. On February 8, he sent unpaid hospital bills from December to the CAO. Mrs. Landry had a life insurance policy with a face value of $5,000. The CAO calculates that the cash value of the insurance policy plus other resources puts the couple over the resource limit. The Landrys met all other eligibility factors. On February 19, the CAO issued a notice denying the Landrys’ application for MA.

On February 28, Mr. Landry files an appeal. Before the hearing, he gives the CAO a statement from his wife's insurance company saying that the cash value of her life insurance policy had been lowered because she borrowed against it several years ago. This proves that the couple’s total resources are less than the limit now and in December.

The CAO approves continuing MA effective February 2 and retroactive MA for the month of December.

 

Updated April 27, 2023  Replacing November 24, 2020