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DHHS Economic Services
Integrated Income Manual
Section 4000
North Carolina Social Services Institute
October 25, 2013
1
Agenda

Integrated Eligibility (IE) Efforts

Overview

History

Development of Economic Benefits Policy Governance
Board (EBPGB)

Role of Work Support Strategies Committee & Policy
Review Subcommittee

Integrated Policy Manual
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Background
Development of the Income Section
Next Steps
2
Overview of IE Efforts

DHHS has undertaken a large initiative to streamline eligibility determination
processes

This falls under the tenets and Action Plan steps of Work Support
Strategies, and is possible with the implementation of NCFAST.
1. Formalize and strengthen county and state partnerships.
2. Develop organizational culture that supports new service
delivery system.
3. Build infrastructure to support new service delivery system.
4. Communicate the vision for a new service delivery system.
5. Increase capacity for data collection and analysis.
6. Reduce burdensome policies and procedures.
7. Perform staff development and readiness activities.
3
History
Integrated Eligibility work includes:

Includes all DHHS economic benefits programs –
 Medicaid (Medicaid Aged, Blind, and Disabled;
 Medicaid Family and Children;
 NC Health Choice),
 Food and Nutrition Services (FNS),
 Work First (WF),
 Refugee Assistance (RA),
 Subsidized Child Care (SCC),
 Special Assistance (SA)
 Energy Programs (EP)

Programs share similar standards for reporting and verifying personal
and financial information

Applicants and beneficiaries have been required to undergo separate
application and redetermination processes for each benefit.
4
WSS Action Step 1
Formalize and strengthen county/state
partnerships.
•
Develop cross-program state and county leadership bodies.
•
Economic Benefits Policy Governance Board
•
Work Support Strategies Committee
•
•
Policy Review Subcommittee
Develop and implement more systemic state-county communication process.
5
Economic Benefits Policy
Governance Board (EBPGB)


Responsibility - to provide a formalized, transparent, and meaningful
platform for developing policy across programs administered by DHHS,
communicating changes in a timely manner, and soliciting input where
appropriate.
Membership – This Board has membership from the four Divisions involved
in WSS:


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The Division of Social Services (DSS) ) represented by Dean Simpson and David
Locklear;
The Division of Aging and Adult Services (DAAS) represented by Chris Urso;
The Division of Medical Assistance (DMA) ) represented by Carolyn McClanahan;
and
The Division of Child Development and Early Education (DCDEE) represented by
Ron Byrd and Kim Miller
6
EBPGB: Policy Review Subcommittee
10 Representatives from each of the three NCACDSS regions and
seven members from NCSSA.

Role is to ensure the policy is clear, concise, and understandable and
has the ability to be implemented locally.


Replaced the old, siloed Economic Services Committee

Co-Chairs:
Brenda Jackson, Cumberland Co. DSS
Cathy Beil, NCSSA & Mecklenburg Co. DSS
Yvette Smith, Iredell Co. DSS
Susan Moore, Lenoir Co. DSS
7
Integrated Manual: Background

DHHS workgroup identified several strategies, including:

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Aligning countable and non-countable income types across
programs;
Aligning verification and reporting requirements;
Developing a common method for calculating gross income
across programs;
Developing a common procedure for collecting eligibility
information; and
Changes are expected to help eliminate redundant work activities
and eligibility processes; reduce administrative resources; reduce
unnecessary client contact with the DSSs; and provide increased
program accuracy.
8
Integrated Manual: Background

The DHHS workgroup had the tedious process of identifying and
aligning, where possible, income across all programs.
9
Examples
This example is related to how SA income affects ALL benefit programs in
determining eligibility. Having this information in one manual saves time and
reduces errors in determining financial eligibility for the universal worker.


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Special Assistance: State-County Special Assistance for Adults (SA) provides
a cash supplement to help low- income individuals residing in adult care homes
(such as assisted living).
 Medicaid, SA, Work First, and Subsidized Child Care do not count.
 FNS and Energy are the only programs that count Special Assistance
Check out the “sources of income” Chart for FNS:
http://info.dhhs.state.nc.us/olm/manuals/dss/ei-30/man/FSs263.htm#P12_82
Energy: http://info.dhhs.state.nc.us/olm/manuals/dss/ei-40/man/EPs30008.htm#P267_16924
10
Writing the Manual: An Overview
The North Carolina Economic Benefits Integrated
Income Manual requires workers to rely on the
policies as written in the manual and to provide
detailed documentation that supports eligibility
decisions.
11
Integrated Manual: Overview




DHHS is aligning policy and converting manuals to
this new format in phases, beginning with the
INCOME SECTION.
The next planned section is the RESOURCES
SECTION.
The new manual sections using a new software and
it will be hosted on a different website from the
current manual.
The new manuals will employ Adobe RoboHelp for a
user friendly, easily maneuverable manual site. You
will notice that this is the same software that is used
for NC FAST Help.
12
Integrated Manual: Income Section
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Condensed, very succinct
Few case examples
Contains list of income types and which ones are
countable
Defines base periods
Lists required verifications including verification
hierarchy and instructions for documentation of
verification;
How to determine gross income
What deductions apply
How to respond to changes in income
13
Income Section
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INCOME SECTION
DHHS reviewed nearly 200 types of countable and noncountable income described in program service manuals existed:
 not in response to federal or state requirements, but rather to
provide specific guidance in the “gray areas” of income
determination
 To respond to rare types of income.
Income types that were derived directly from federal regulations
were often differently defined, described or nuanced by the
various programs unnecessarily.
Some income types were duplicative, altogether outdated or no
longer considered relevant.
14
Income Types
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Agreed upon name for the income category
Income types were consolidated under one name.
Others were added to accommodate complex policies that could
not be adjusted (e.g. Tobacco Allotments income types, VA
income types).
Some were renamed to provide more clarity.
Countable if it is counted by at least one program.
Countable income types are divided into “earned” and
“unearned” categories.
Brief definition and/or a clarifying comment to determine under
what circumstances the income type should be counted.
List and definition included for non-countable income types.
15
Exceptions to Alignment of Income
Types and Treatment
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Special base periods: If a special base period is needed for an
income type, the special base period has been included. For
example, child support calls for a special base period of 2
months if representative. In this instance, the general base
period of 1 month suggested across income types does not
create a snapshot of income that is representative, due to the
often infrequent nature of child support payments.
Special Budgeting Notes: If calculating an income type to
represent a gross monthly amount is not readily intuitive to the
case manager, a budgeting method is detailed.
Special Verification Notes: If special verification that is not
included in the general verification instructions, it is listed here.
Comments-includes additional information that does not fit into
one of the other
16
General Rule:
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Evaluate the case for all income that will be
available during the certification period.
Establish a current and representative
estimate of gross earned and unearned
income that will be available to the budget
unit during the certification period.
17
Income Verification
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Verification of all income is required at
application and review/redetermination and at
change in circumstance as designated by each
program.
Verifications are used to support evidence
(information) in the determination of program
eligibility.
The applicant/recipient/claimant’s income is the
“evidence” used to determine eligibility. Pay stubs
are examples of sources of verification used to
support the evidence.
18
Verification Sources

Four main sources of verification:
1.
2.
3.
4.

Electronic matching is the primary income verification source for income
received through Social Security, Employment Security Commission (UIB), Work
Number, etc.
Documentary evidence for income verification includes wage stubs, award
letters, banks statements, etc. The applicant or the household has primary
responsibility for providing documentary evidence to support statements on the
application and to resolve any questionable information. Documentary evidence
may be provided in person, by mail, or through an authorized representative.
Accept any reasonable documentary evidence if the verification adequately
proves the information provided on the application.
A collateral contact may be necessary when documentary evidence cannot be
obtained, or is insufficient to make eligibility determination or determination of the
correct benefit level. A collateral contact is a person knowledgeable enough
about the information needed to provide an accurate statement of verification.
The DSS is responsible for obtaining verification from acceptable collateral
contacts.
Client’s Statement is acceptable in some circumstances based on individual
program policy unless otherwise questionable. Example: Client’s statement can
be accepted as verification of income that results in ineligibility, decrease, or
termination of Food and Nutrition Services.
The DSS must assist the applicant or household in obtaining
verification as needed.
19
Income Verification: General Guidelines
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Use reasonable documentation to verify income.
Avoid over-verification (e.g. requiring excessive pieces of
evidence for any one item or requesting verification that is not
needed to determine eligibility.)
Do not require additional verification once the accuracy of a
written or verbal statement has been established.
Do not require a specific type of verification when various types
are adequate and available.
Only re-verify income information when required by program
policy or when different or conflicting information is presented.
If fraud is suspected, determine if a referral for fraud or for frontend verification should be made.
20
Verification Method Hierarchy
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The Electronic Online Verification (OVS) is
required for all programs and all income
types.
Only pursue other methods if there is a
discrepancy or if electronic verification is not
available.
Accept verifications that reasonably establish
eligibility.
21
Documentation of Verification
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Income documentation is required for all cases.
Documentation means the type of verification and a
summary of the information obtained has been
entered in the appropriate evidences in NC FAST.
Documentation must be detailed so that a County,
State, or Federal reviewer is able to determine the
reasonableness of the determination.
For example, when income is verified by the
presentation of pay stubs, the gross amount of
income on each pay stub, and the frequency of
receipt of income is documented in NC FAST
evidence(s) or case record.
22
Documentation Required For:
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Applicant or beneficiary statements regarding available
income; including client’s statement of no income.
The source and type of income, and a collateral contact if one
is necessary.
Efforts to determine employment and exploration of potential
unearned income
Copies of correspondence and documents, forms, notification.
Amount and type of earned and unearned income and any
operational expenses.
Base period used and the income available.
Changes which may occur in the future. Flag the case.
Other facts, information, or dates used to support your decision
23
Determining Gross Income
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When determining projected income for the
certification period, count gross monthly income.
If income is received other than monthly or if income
fluctuates, convert to a monthly amount that is
current and representative for each pay period.
NC FAST will convert income to a monthly amount
based on the frequency entered.
24
Determining Gross Income:
Base Periods
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Representative: Base periods are the basis for
determining income eligibility.
The base period establishes a set period of time for
workers to create a “snapshot” of a budget unit’s
income and for which income must be verified.
The base period should be an accurate
representation of the income the household is
expected to have available during the certification
period.
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Determining Gross Income:
Base Periods
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One Month: The base period for most income is the month prior
to the month of application or redetermination, if representative.
Three Months: The base period for child support, spousal
support and alimony is the three months prior to the month of
application or redetermination, if representative. Add the months
together and average (divide by 3).
Twelve Months: if the income is received annually or from selfemployment, the base period is 12 months.
Special base periods: Certain types of income require special
base periods, particularly if the income is not stable or
predictable. Exceptions to the base periods are listed in 4030.1
and 4030.2 Countable Income in the column labeled “Special
Base Periods”
26
Determining Gross Income:
Base Periods Not Representative
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If the base period income is not representative,
explore using alternative budgeting methods such
as projecting or averaging income.
Determine which budgeting method is the most
representative estimate of the budget unit’s income
over the certification period.
Project income using the best available information
about the number of hours, rate of pay, and
frequency of pay expected to be received over the
certification period.
If you use an alternate budgeting method you must
document why the base period is not representative
and how you determined what base period is used.
27
Determining Gross Income:
Base Periods Not Representative
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Averaging is used when the budget unit’s
income fluctuates across pay periods. Total
the income for all pay periods and divide by
the total pay periods to reach an average
income across pay periods.
Do not round.
Enter average income into NC FAST along
with the appropriate frequency.
28
Formulas to Convert or Average
Incomes
NC FAST uses the following formulas to
convert or average incomes:
 If received weekly, multiply by 4.3
 If received bi-weekly, multiply by 2.15
 If received semi-monthly, multiply by 2
 If received quarterly, divide by 3
 If received monthly, use the monthly gross
 If received semi-annually, divide by 6
 If received annually, divide by 12
29
Deductions, Exclusions and
Disregards
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These have been grouped in the Integrated
Income Manual section by the type of
deduction.
These are found in an easy to use chart.
30
Change in Income
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When a change is reported react to changes based on program
policy.
A Change in earned income is:
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New employment (which includes initial employment as
well as a change of job with the same or a different
employer)
An increase or decrease in rate of pay
An increase or decrease in the required number of hours
worked
Termination of income
A change in unearned income is:


Beginning or termination of unearned income
An increase or decrease in the amount of unearned income
31
Budgeting New, Changed or
Terminated Income
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A change may be reported during the application
period, during the certification period or during the
redetermination period.
New or changed Income:
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begin budgeting the representative income the month after
the month in which the notice expires.
Use any earned or unearned income received to project
income forward.
If no income has been received then use the best available
information about the number of hours, rate of pay, and
frequency of pay expected to be received over the
certification period.
Terminated Income: do not count the source beyond
the month the income terminates.
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Next Steps
Current location: http://www.ncwss.com/manual/index.html
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Transfer the Manual to permanent site
Begin work on the Resources section
Publish the paper-based Integrated
Application
Add MAGI Sections
Archive Income sections of existing manuals
33
Questions?
34
Key Contacts
Chris Urso, SA Program Administrator
Division of Aging and Adult Services
chris.urso@dhhs.nc.gov
Carolyn McClanahan, Chief MA Eligibility
Division of Medical Assistance
carolyn.mcclanahan@dhhs.nc.gov
Ron Byrd, Chief of Child Care Subsidy
Division of Child Development and Early Education
ron.byrd@dhhs.nc.gov
David Locklear, Acting Chief, Economic and Family Services
Division of Social Services
david.locklear@dhhs.nc.gov
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