A How to Identify Transfers

 

Program

Manual Section

ALTCS

MA901

 

Procedure

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:

  1. While preparing for the interview; and

  2. While completing the interview; and

  3. When proof is received.

 

See the examples below for how each tool is used to identify transfers.

1) Identifying transfers while preparing for the interview

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

  1. 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.

  1. 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.

  2. Check online property records to see if the public records show any property transfers within the look-back period; and

  3. 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.

 

2) Identifying transfers while completing interview

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

  1. Use investigative interviewing and open-ended questions to ask about transfers that have occurred within the look-back period.

  2. Ask about financial accounts found by AVS that were not reported during the financial interview.

  3. 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 MAP901B How to Process a Transfer.

 

3) 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.

Assume that the customer’s living expenses will not be more than the customer’s monthly income when the customer is living at home. Ask questions about:

  1. Withdrawals that seem unusually high; and

  2. Multiple withdrawals in whole dollar amounts; and

  3. Large amounts (thousands) or multiple withdrawals of hundreds ($200 or $300), especially if they are ATM withdrawals.

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, a transfer may have occurred.

Joint Property Ownership

Additional proof is needed when the customer:

  1. Owns real property jointly with someone other than a spouse, ask when the other person was added to the title; and

  2. States the other person’s name was added to the property within the look-back period.

 

Examples

Investigative Interviewing

1) When the application shows the customer previously lived in another state (i.e., was born outside Arizona or worked in another state) ask if the customer sold a home in the other state when he or she moved to Arizona or still owns property in another state.

2) When the customer is residing in a nursing facility or alternate residential setting or living with a relative at the time of application, ask where the customer lived before moving to the current living arrangement.

 

Asset Verification System (AVS) Flagged Transfers

Upon reviewing a customer’s AVS results, you find that the system flagged $20,000 that was transferred out of the customer’s checking account. There are no flagged increases for the same amount. Ask the customer questions about the transfer and enter it into HEAplus. Request the appropriate proof of compensation based on the information the customer provides.

 

Financial Account Withdrawals

1) The customer is a 74-year-old widow who lives at home. Her income is $876 per month. Her checking account statement shows 12 checks totaling $6,792.17 cleared the bank during the application month. Most checks written on the account were for small amounts ($10 to $200), but three checks were written for large amounts: one check for $1,500 and two checks for $2,000. Ask the customer to explain to whom these large payments were made and what they were for. Ask for proof of compensation in the form of a check register, copies of checks, billing statements, or receipts. 


2) The customer is a single man who entered a nursing facility five months before applying for ALTCS in July. His representative explained that he has been privately paying for his nursing facility care but is running out of money. His June credit union account statement shows a $3,800 debit on 6/5 and a $3,650 debit on 6/30 and a few other debits in small amounts. The representative states large amounts were checks written to pay the nursing facility for June and July. Through a collateral contact with the nursing facility, you are able to verify that the customer has resided there for 5 months and that he privately paid for his care for June and July. These transfers have been adequately explained; no further investigation is needed.

 

Changes in Interest Credited to an Account

The customer and his spouse live at home. The couple’s quarterly savings account statement shows a balance of $3,800 and third quarter interest of $14.27, but the year-to-date interest is $587.49, indicating that the account balance was much higher earlier in the year. Ask the customer to explain the change in the account balance. Determine if the funds were moved to another account owned by the couple, spent by the couple’s benefit, or transferred to someone else.

 

Joint Property Ownership

The customer reports that she added her daughter’s name to her home property deed 1 year ago. Check online property records for proof of the daughter’s name being added. If there is no proof online, contact the county recorder’s office and ask for the needed information. As a last resort, ask the customer to provide a copy of the deed. Once there is proof that the transfer occurred, use MA704B to determine the customer’s ownership interest after the date of the transfer.

 

Review Previous Applications

In 2018, the customer applied for ALTCS and reported that he owned two vehicles. The 2018 application was denied because the customer was not medically eligible. In 2020, the customer reapplied, and reported only 1 vehicle. Ask questions to determine what happened to the other vehicle previously reported.

 

Online Property Transfer Records

The customer has lived in a nursing facility for 4 months and lives in Maricopa County. A search for the customer’s name shows that 3 months ago, she transferred her home property to her daughter. Ask the customer what she received in return for the property. Enter the transfer into HEAplus and send a request for information for the compensation received.

 

 

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