SR 15-20 Dated 07/15

STATE OF NEW HAMPSHIRE

INTER-DEPARTMENT COMMUNICATION

SUMMARY

This SR releases the annual July updates to the:

·      Financial Assistance to Needy Families (FANF) Standard of Need (SON) used to determine the period of ineligibility for FANF cases receiving lump sum income and eligibility and benefit amount for FANF cases with deemed income; and

·      resource deduction figures used in the resource eligibility process for Children with Severe Disabilities (CSD) medically-needy medical assistance.

BACKGROUND

RSA 167:7,II mandates annual updates to the SON to reflect changes in the cost of living, as implemented at He-W 658.01. The FANF SON represents an approximate monthly amount that it would cost a family in NH for basic living necessities, including food, utilities, and rent. However, this figure is not used in the FANF eligibility or benefit determination process for most FANF applicants.

For 2015, DFA has determined that the amount of money a household of four needs for basic living expenses in NH, the SON, for a household of 4, is $4,757 per month, whereas the 2015 maximum benefit that DFA provides for that same household living in unsubsidized housing is $738 per month. This translates into a $4,019 discrepancy between the figure DFA has determined it costs a family of four to live per month in NH, and the dollar amount DFA is providing for this family to meet those identified living expenses. Or, put another way, the $738 maximum payment standard we allow for a household of 4 in unsubsidized housing is only 15.5% of what we have determined to be the actual cost of monthly living expenses for that family.

In the years from 2005 to 2015, the SON has increased every year at an average of 4.032% per year, whereas the payment standard has increased only once in that 11-year span. From 2005 to 2015, the payment standard has averaged less than a 1% (.66%) increase per year, but the amount of the discrepancy between the payment standard and the actual living costs as represented by the SON has averaged $3,205 per year, or an 81.13% average annual deficiency.

The annual July update of the CSD resource deduction figures, which is based upon 50% of the current federal poverty guidelines (FPG), is mandated by administrative rule He-W 641.04(e).

POLICY

FANF Standard of Need Changes

The annual July update to the FANF Standard of Need (SON) affects:

• FANF cash cases closed or denied due to lump sum income; and

• open FANF cash, FANF medically-needy, and FANF In and Out cases with a non-sanctioned deemer.

The SON is used to determine the period of ineligibility for cases receiving lump sum income, and eligibility and benefit amount for cases with deemed income. An increase in the SON may result in shorter periods of ineligibility for those cases that are currently FANF ineligible due to receipt of lump sum income, and in less income being counted as available for those FANF or certain medical assistance only cases with deemed income. A decrease in the SON may result in longer periods of ineligibility for those cases that are currently FANF ineligible due to receipt of lump sum income, and in more income being counted as available for those FANF or medical assistance only cases with deemed income.

The maximum SON equals the Basic Maintenance Needs Allowance (BMNA) plus $342, the weighted average of the maximum shelter payment allowances. The 2015 BMNA and SON are noted below:

2015 BMNA and Max SON

*To find the 2015 BMNA for household sizes over 18, add $302 for each additional person to the (old) 2014 BMNA for HH size 18. Multiply that resulting sum by 1.6%. Add the resulting product to the original figure calculated for the HH size over 12, and then round down to the nearest whole dollar.

To find the 2015 SON for household sizes over 18, calculate, per the above, the 2015 BMNA for that HH size, and add actual shelter costs, if incurred, up to the maximum shelter allowance of $342.

Lump Sum Calculations

Individuals who receive lump sum payments are ineligible for assistance for the number of months resulting from dividing the lump sum amount (plus any other monthly income) by the SON. Clients whose cases were closed or denied due to receipt of lump sum income may reapply or request a recalculation due to the increase in the SON. If requested, the District Office must recalculate the client’s period of ineligibility. A new Notice of Decision (NOD) will be generated if the recalculation results in a different period of ineligibility.

Deemed Income Cases

The SON is used for FANF deeming from parents, including ineligible alien parents, alien sponsors, and three generation deeming. Due to the increase in the SON, less deemed income is counted as available to the assistance group (AG). New HEIGHTS will automatically recalculate benefit amounts for open cases with deemed income during the Mass Change. AGs whose cases were closed or denied due to excess deemed income may reapply or request to have their eligibility redetermined due to the increase in the SON. If requested, the District Office must recalculate the AG’s eligibility.

Children with Severe Disabilities (CSD) Resource Deduction

CSD resource eligibility for medically-needy medical assistance is determined by reducing the parents’ total resources by the CSD resource deduction for the appropriate household size and combining the balance with the child’s resources. The CSD resource deduction is based upon 50% of the current FPG. The 2015 CSD resource reduction is noted below.

NEW HEIGHTS SYSTEMS PROCEDURES AND IMPLEMENTATION

July FANF SON and CSD Resource Deduction Update

New HEIGHTS will update all reference tables with the new figures effective July 1, 2015, and will use the new amounts for any cases computed or recomputed beginning on or after that date.

Clients Denied or Closed Prior to 7/1/15 due to Deemed Income or Receipt of Lump Sum

No District Office action is necessary unless a client requests to have their eligibility redetermined or their period of ineligibility recalculated. If a client requests this recalculation, the current SON released by this SR and effective July 1, 2015 will be automatically applied during the recalculation. If the client’s eligibility for assistance or length of ineligibility changes during the recalculation, a new NOD will be generated.

Open Cases With Deemed Income

New HEIGHTS will run an initial query to identify all open/on-going cash cases with a non-sanctioned deemer and all deductible cases with a non-sanctioned deemer whose grant amounts or spenddowns will change during the mass change. The cases identified will be recomputed during the daily production run the evening of June 23, 2015. Cases with deemed income whose grant amounts or spenddowns change will receive the appropriate message reflecting the new benefit level.

Because less deemed income may be counted as available in some cases, medical assistance only cases with a non-sanctioned deemer, and cases with a non-sanctioned deemer currently eligible for FANF cash assistance but not actually receiving the grant because the amount is under $10 per month, may now become eligible for a cash grant for the first time.

The latter cases described that do not have sufficient Benefit Issuance information during the daily production run of June 23th will appear on the MC Exception Report (NMC550RA) with the Reason for Exception listed as “No BI Payment Information.” District Offices must rerun eligibility and supply the missing Benefit Issuance information when that screen appears in the driver flow.

NOTE: These cases should be contacted prior to confirmation to be informed of the availability of cash assistance, including an explanation of appropriate FANF cash program policies (e.g., work program requirements and the 60-month time limit on receipt of cash assistance). If the client agrees to receipt of cash assistance, explain the process required to establish benefit issuance. $10 minimum grant cases confirmed after the mass change will receive a standard opening message from New HEIGHTS. District Offices are not required to refer these cases to the NHEP team, as New HEIGHTS will have already referred mandatory NHEP participants to the NHEP team.

Procedures for CSD Cases

New HEIGHTS will update all reference tables with the new CSD resource deduction figures effective July 1, 2015, and will use the new amounts for any cases computed or recomputed beginning on or after that date.

POLICY MANUAL REVISIONS

Revised Family Assistance Manual Topics

PART 601, Table A FANF Basic Maintenance Needs Allowance and Maximum Standard of Need

Revised Medical Assistance Manual Topics

Section 605.03  Children with Severe Disabilities (CSD) Medically-Needy Resource Deduction Table

IMPLEMENTATION

New HEIGHTS will implement the SON updates on June 23rd during the annual July Mass Change, effective July 1, 2015. The SON revisions identified in this SR are effective July 1, 2014, and will apply to all cases processed on or after that date.

CLIENT NOTIFICATION

Assistance groups experiencing a change in eligibility due to the mass change will receive the following text in the “Explanation” section of the Notice of Decision (NOD):

On July 1, the Financial Assistance to Needy Families Standard of Need, the Resource Deduction for families with a medically needy severely disabled child, and the Child Care Income Limits and Payment Rates changed. Your benefits, as shown in the old and new budgets below, may have been adjusted to reflect this or other changes that occurred in your case. He-C 6910.18, He-W 641.04(e), He-W 658.01, RSA 167:7,II, RSA 167:3-c,X

In addition to the client notice referenced above, clients will be notified, as needed, about the updates in the SON and CSD Resource Deduction at the next case action or upon request.

No other client notification is planned.

POST MASS CHANGE REPORTS

The following reports will be available with any July Mass Change related information beginning June 24, 2015.

NMC540RA: AG’s Affected by MC

This report lists all cases that the Mass Change ran successfully through confirmation. It contains the following information: D.O., Worker Name, Client Name, and Case Number.

NMC550RA: MC Exception Report

This report lists cases that were selected for computation during the Mass Change, but were not confirmed due to some discrepancy in data. These cases require further District Office action. The report contains the following information: D.O., Worker Name, Client Name, Case Number, Reason for Exception, and Mass Change Type.

TRAINING

No training is planned or needed due to the procedural nature of this SR.

DISPOSITION

This SR may be destroyed or deleted after its contents have been noted and the revised manual topics released by this SR have been posted to the On-line manuals.

DISTRIBUTION

This SR will be distributed according to the electronic distribution list for Division of Family Assistance policy releases. This SR, and revised On-Line Manuals, will be available for agency staff in the On-Line Manual Library, and for public access on the Internet at www.dhhs.nh.gov/DFA/publications.htm, effective June 29, 2015. Additionally, this SR, and printed pages with posting instructions, will be distributed under separate cover to all internal hard copy holders of the Family Assistance and Medical Assistance Manuals.

DFA/KD:s