B How to Process a Transfer

Program	Manual Section
ALTCS	MA901

Procedures

1) Use the table below when the customer has 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?” NOTE Do not enter transfers if the total uncompensated value of all transfers for the month is $500 or less.
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 an AVS flag 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. For examples, see section 3 "Evaluating transfers without submitting a Policy Clarification Request" below.
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 $500.00 or less after compensation or exclusions are applied? If YES, apply the exclusion reason, “excluded resource” and enter case notes explaining that transfer totals of $500.00 or less in a month do 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 MAP907 How to Request an Undue Hardship Determination.

2) Evaluating transfers without submitting a Policy Clarification Request

Examples

Use these examples to decide if a transfer can be processed without a Policy Clarification Request (PCR).

Purchases and payment of debt

The customer applied for ALTCS in July 2020. Asset Verification Service (AVS) shows the customer had a $15,000 transfer in March 2020. The bank account statement showed that in March 2020, the customer paid $14,000 to the nursing facility where she lives. The other $1,000 was used for groceries, a credit card bill, and other purchases. The purchases were for the benefit of the customer.

The $15,000 transfer does not affect eligibility (MA903E). A PCR is not needed.

Transfers Made by Certain Other People

The customer transferred property within the look-back period. He provided a copy of his divorce decree which showed the court awarded his ex-spouse 100% ownership of the property.

The customer’s ownership interest in the property is considered a transfer that does not affect eligibility because it was ordered by the court (MA903B). A PCR is not needed to determine the treatment.

Transfer of an excluded resource

In April 2019, the customer got a one-time lump sum of $50,000 as part of the Radiation Exposure Compensation Act. The customer provided a letter that verified the payment. The payment is excluded as income and resources (MA606VV, MA705BB).

The customer is applying for ALTCS in February 2021 and the $50,000 has been spent. Proof of how the money was spent is not needed because it is verified and excluded. The spend down of the $50,000 does not affect eligibility because it was an excluded resource (MA903F). A PCR is not needed.

Transfer of Home Property to Specific People

The customer is applying for ALTCS in January 2021. He reports that he gave his home property to his son in 2020. He states that his son has been determined to have a disability and provides the son's birth certificate to prove their relationship. The son also gets AHCCCS Medical Assistance. The SOLQI for his most recent renewal verified that he was determined to have a disability.

The relationship and disability determination have been verified. The transfer of the property to the son will not affect eligibility (MA903G). A PCR is not needed.

Transfer of Resources to or for the Benefits of Specific Individuals

The customer applied for ALTCS in July 2020. He reports that in January 2020, he deposited $20,000 into an account belonging to The Joey Fields Revocable Trust. Joey is the customer’s neighbor who has been determined to have a disability. Joey is 25 years old.

The following proof was provided:

Joey’s age; and
That Joey was determined to have a disability; and
That Joey is the sole beneficiary of the trust.

With the proof provided, the transfer was made to a trust established solely for the benefit of a person with a qualifying disability (MA509), who was under 65 years of age at the time of the trust's creation (MA903H). A PCR is not needed.