P901 How to Identify and Process Transfers

Program	Manual Section
All Programs	MA901

Procedures

1) How to Identify Transfers

Look for signs of transfers that the customer may have overlooked, forgotten or does not think of as transfers. Customers may not know what we mean when we ask about transfers. Representatives may not know about transfers the customer made during the look-back period.

The following section will tell you how to identify transfers:

While preparing for the interview; and
While completing the interview; and
When proof is received.

See the examples below for how each stage of the interview process is used to identify transfers that may affect eligibility. Transfers when added together that total $1,500.00 or less during a month are considered as not made to qualify for ALTCS and do not affect eligibility.

Identifying transfers while preparing for the interview

Use the following records to identify transfers while preparing for the financial interview:

Asset Verification System (AVS) Flagged Transfers. Use the AVS results to review any flagged transfers.

NOTE AVS flagged increases that equal flagged decreases in other accounts indicate transfers from one account to another. These transfers do not affect eligibility.
Check HEAplus for the customer’s living arrangement. Note whether the decreases seem related to the customer’s cost of care when the customer is in a facility.
Check online property records to see if the public records show any property transfers within the look-back period; and
Review the case file. Look for large decreases in the customer’s resources that are not explained by known expenses, and previously reported transfers.

NOTE Make a note of the resources that were previously reported. This information may be useful during the financial interview.

Identifying transfers while completing interview

Take the following actions to identify transfers while completing the financial interview:

Use investigative interviewing and open-ended questions to ask about transfers that have occurred within the look-back period.
Ask about financial accounts found by AVS that were not reported during the financial interview.
Identify resources from the case file that are not reported during the financial interview for the current application.

NOTE Ask questions regarding how the customer disposed of the resources and what compensation was received. Request proof of all transfers using the policy in MA901 Transfers Overview and process the transfer using the procedure How to Process Transfers.

Identifying transfers when proof is received

Financial Account Withdrawals
Review the customer’s financial account statements for potential transfers, such as large withdrawals that are not explained by the customer’s lifestyle and living arrangement.

Identify the monthly recurring expenses and charges. Assume that the customer’s living expenses will not be more than the customer’s monthly income when the customer is living at home. When the customer’s withdrawals exceed the income deposits, and are not explained by the customer’s lifestyle or living arrangement, and the potential transfers plus reported uncompensated transfers are more than $1,500.00 in one month, ask questions about:

Withdrawals that seem unusually high;
Multiple withdrawals in whole dollar amounts provided to people or organizations that did not provide a service to the customer; and
Large amounts (thousands) or multiple withdrawals of hundreds ($200 or $300), especially if they are ATM withdrawals.

See Section 3 How to Identify a Transfer on a Financial Account Statement to determine when to enter transfers from a customer’s financial account into HEAplus.

Changes in Interest Credited to an Account
If the current interest credit or year-to-date interest is not consistent with the account balance and known circumstances, investigate whether a transfer with uncompensated value occurred.

Joint Property Ownership
Additional proof is needed when the customer:

Owns real property jointly with someone other than a spouse, ask when the other person was added to the title; and
States the other person’s name was added to the property within the look-back period.

Examples for Identifying Transfers

2) How to Process Transfers

Use the table below when you have identified a transfer that may affect eligibility.

Step	Action
1	In the Transfers battery, select “Yes” to the question: “Has the customer or customer’s spouse transferred any of the following assets?”
2	Click on the blue link to select the type of transferred resource or income. A window will open to enter the transfer details.
3	Ask the customer about each transfer and complete as much information as possible. For each field listed, enter the following information: Owner: Name of the customer or spouse that transferred the asset. If the transferred item was co-owned with their spouse. Type: Type of resource or income that was transferred. Institution/Company Name: Source of the asset (ex., Bank name or Life Insurance Company). Address and phone number: Address and contact information for the asset or income source when applicable. Date Transferred: Date the asset was transferred for individual transfers made during a month (for example, the date of the check or the deed). AVS flagged decreases are transfers that occur the month prior to the month that AVS reports it. Transferred To: Name of the person the asset was transferred to. Relationship: Relationship of the new owner to the customer. Amount Transferred: Countable value of the income or resource at the time of the transfer. Enter the CMV and the amount owed for property. HEAplus will calculate the countable equity value for the transfer. If it is an AVS flagged decrease, check the AVS flag checkbox so the correct language appears on the RFI. When AVS flags decreases and there are no matching increases during that same time period to other accounts, a transfer must be entered. Enter the decreased amount as a transfer for the month prior to the flagged decrease.
4	In the “Amount of Compensation” field, enter an amount only when it was received prior to the application or during the same month the transfer was made.
5	Use the drop-down list in the “Type of Compensation” field to choose the type of compensation received. Select “Other” when the compensation type is unknown.
6	Is there a valid “Excluded Reason” for the transfer listed in Transfers That Do Not Affect Eligibility (MA903)? If YES, select the excluded reason from the drop-down list. HEAplus will add the language to the RFI for any needed proof. Continue to step 7. If NO, continue to step 7.
7	Explain the transfer penalty and the policy about rebutting the transfers. Ask the customer each question about rebutting the transfer and mark the correct answer. If you enter “Yes”, or “Unable to answer”, the RFI will generate a request for proof. Make sure you have explained the policy and what is needed. NOTE Sometimes the customer accepts the penalty and does not want to rebut it. If the customer does not want to rebut the penalty period, enter a case note. There is no need to send an RFI. For example, a customer may accept the penalty period when it has already passed, and the customer was in HCBS. There may not be any services or costs to recover for that period.
8	Did the customer receive more than one compensation type for a transfer? If YES, the transfer will need to be split into two entries that when added together will total the full transferred amount. Use transfers to correctly request the proof for each compensation type. If NO, send the RFI to the customer and continue to step 9.
9	Did the customer provide proof of ownership of resource or income, the transfer date, and the CMV at the time of the transfer? If YES, continue to Step 10. If NO, STOP. Deny or stop eligibility for failure to provide proof of resources or income for any transfers that are not AVS flagged decreases. For AVS flagged decreases, process the flagged decrease amounts as uncompensated transfers.
10	Review proof of compensation or exclusions that apply for each transfer. Take the following actions: Update the HEAplus transfer battery to match the proof provided by the customer. For AVS decreases, enter the actual dates and amounts for the transfers, and remove the AVS flagged decrease amounts. NOTE If the information is provided after the application is processed create a RAC to update verifications and compensated amounts.
11	Is the total of the uncompensated transfers during any month $1,500.00 or less after compensation or exclusions are applied? If YES, apply the exclusion reason, “excluded resource” and enter case notes explaining that the transfer totals $1,500.00 or less in a month and does not get a penalty. Continue to step 12. If NO, continue to step 12.
12	Did the customer provide proof to rebut the transfer penalty? If YES, continue to step 13. If NO, STOP. Process the case
13	See Referring a Transfer Rebuttal to the Office of Eligibility Policy for instructions. NOTE Do not delay processing the application when the only action pending is the transfer rebuttal. The rebuttal can be retroactively applied through a RAC.
14	Was the rebuttal successful or partially successful? If YES, update HEAplus. Verify that HEAplus correctly updated the penalty period and process the case. If NO, process the case with the transfer penalty period applied. NOTE If the customer wants to claim undue hardship, see How to Request an Undue Hardship Determination.

Examples for Evaluating Transfers

3) How to Identify a Transfer on a Financial Account Statement

Review the financial account statement line by line. Use the IF/THEN chart to correctly identify a transfer.

If the transfer...	Then...
Is a transfer entered into HEAplus due to an AVS flagged decrease and the financial account statement is provided	Remove the flagged decrease and review the financial account statement for unexplained withdrawals.
Was an AVS flagged decrease and there is an increase to show that the money was transferred between accounts	Transfers between accounts are compensated. Do not enter the information into HEAplus.
Was an AVS flagged decrease and there are no increases to show that the money was transferred between accounts	This may be a transfer with uncompensated value. Enter the transfer in HEAplus. Check the AVS flag checkbox so that the correct proof is requested on the RFI
Was made for ordinary living expenses (does not exceed the customer’s monthly income), entertainment for the benefit of the customer, restaurants, transportation, personal or household purchases	Do not enter the information into HEAplus.
Occurred over 60 months before the application	Do not enter the information into HEAplus.
Occurred during a period the customer was receiving ALTCS, and the penalty has since expired	Do not enter the information into HEAplus.
All transfers and potential transfers do not exceed $1,500.00 in a month.	Do not enter the information into HEAplus.
Was a resource or income that did not belong to the customer or spouse	Do not enter the information into HEAplus.
Was a resource or income transferred to the customer’s spouse	Do not enter the information into HEAplus.
Was a resource or income transferred by the spouse during post initial rules	Do not enter the information into HEAplus.
Was a resource or income (other than a home or facility refunds) excluded for eligibility	Do not enter the information into HEAplus.
Was a resource or income used to purchase an irrevocable annuity that meets the exception (MA902G)	Do not enter the information into HEAplus.
Was used for purchases for the customer’s or spouse’s benefit that are not questionable.	Do not enter the information into HEAplus.
Was due to the customer adding someone to their account but the customer still has access to the full balance	Do not enter the information into HEAplus.
Was due to the customer adding someone with the “or” owner designation to a vehicle	Do not enter the information into HEAplus.
Was made to pre-pay the customer’s burial Typically, a transfer for pre-paid burial for the customer or spouse is considered compensated for the customer’s benefit even if it is irrevocable or no longer owned by the customer Revocable pre-burials are usually a conversion of a resource	Do not enter the information into HEAplus.
Was a check written or electronic transfer to other people or transfers made to accounts not owned by the customer or spouse	Enter the transfer in HEAplus and request proof.
Banking transactions do not appear to be for the benefit of the customer because the customer is in a Long Term Care facility and does not have access to or use of the items or services being purchased.	Enter the transfer in HEAplus and request proof.
Was a large unexplained withdrawal or irregular amounts withdrawn in large sums totaling over $1,500.00 when added to other unexplained or uncompensated transfers for the month	Enter the transfer in HEAplus and request proof.
Was income or a resource given as a gift or to pay someone else’s debt, including adding a percentage ownership to a title or deed without receiving compensation	This is a transfer with uncompensated value. Enter the transfer in HEAplus Ask the rebuttal questions Explain undue hardship to the customer
Was made as an oral loan or a written loan without collateral (non-negotiable) or made as a payment to a non-negotiable loan	This is a transfer with uncompensated value. Enter the transfer in HEAplus Ask the rebuttal questions Explain undue hardship to the customer