11/16/04

Summary:

  • Obsoletes Policy Memorandum of 05/05/03.
  • Provides Long Term Care - Asset Discovery Investigation (LTC-ADI) information that will be effective 12/01/04.
  • The initial roll-out of the LTC-ADI project, effective 12/01/04, will be conducted only in Knox, Madison (115), St. Clair (112), Will, and Winnebago counties.
  • The LTC-ADI project will be conducted statewide effective 04/01/05. Specific counties will roll out monthly during the period of 01/01/05 through 04/01/05.
  • Monthly referrals will be limited for each county.
  1. LTC-ADI PROCESS
  2. PROCESS FOR APPLICATIONS MEETING ONE OF THE ABOVE CRITERIA
    1. Maximum Allotted Referrals Met For Current Month
    2. Maximum Allotted Referrals Not Met For Current Month
      1. Referral Procedures
      2. Procedures Following the Completed Investigation

This Policy Memorandum was prepared by the Illinois Department of Public Aid. DPA administers the Medicaid and KidCare programs. These programs provide medical benefits to families with children and to other persons. This information is to be used by staff of the Illinois Department of Human Services when authorizing medical benefits for persons on behalf of DPA.

The LTC-ADI project began in 1996 when the DPA Office of Inspector General (OIG) conducted investigations of LTC applications meeting certain error-prone criteria as identified by Family Community Resource Centers (FCRCs)in Cook (Medical Field Operations) and DuPage counties. It had two phases and was concluded in February 1998.

Due to the success of identifying undisclosed assets and unreported asset transfers in this project, DPA has contracted with a private vendor to conduct asset investigations on LTC applications filed on or after 12/01/04. The initial roll-out, effective 12/01/04, will be conducted only in Knox, Madison (115), St. Clair (112), Will, and Winnebago counties. Specific counties will roll out monthly during the period of 01/01/05 through 04/01/05.

Effective 04/01/05, the LTC-ADI project will be conducted statewide. Do not apply the information contained in this memorandum until your county is included in the project.

The following chart provides the effective roll-out date for each Region/County and the maximum monthly referrals allotted to each county.

Effective Date Regional/County Roll-Out Maximum Monthly Referrals
12/01/04 Will 8 referrals
Knox, Madison (115), St. Clair (112), and Winnebago 3 referrals per county
01/01/05 DuPage, Kane, and Lake 8 referrals per county
Remainder of Region 2 2 referrals per county
Macon and Sangamon 2 referrals per county
02/01/05 Remainder of Region 5 and Region 3 2 referrals per county
03/01/05 Region 1 - Medical Field Operations 56 referrals
04/01/05 Remainder of Region 4 2 referrals per county

LTC-ADI PROCESS

The LTC-ADI project does not include applications for persons residing in supportive living facilities (SLFs).

The LTC-ADI project will focus on the review of error-prone LTC applications. The project is intended to evaluate the cost benefit of completing asset investigations on applications containing specific error-prone criteria to ensure that LTC applicants with excess assets use them for their care.

All LTC applicants are required to complete Additional Financial Information for Long Term Care Applicants (Form 3654). This form is used to obtain additional financial information and assess financial management.

At a minimum, Form 3654 must be signed. By doing so, consent is given to any investigation made by the Department to verify information on the form. Signing Form 3654 is a condition of eligibility. If the applicant or representative refuses to sign Form 3654, deny the application. Since the investigation process may be delayed otherwise, encourage applicants and representatives to complete Form 3654 in full. However, local office staff are not required to ensure that Form 3654 is completed in its entirety.

Refer LTC applications that meet one of the following criteria to the OIG for an asset investigation:

  • applicant who does not have a community spouse and reports more than $20,000 in assets at the time of application on Mail-In Application For Medical Benefits (Form 2378H), or
  • applicant who reports property transfers on Form 2378H (Form C) or Form 3654 (Questions 12, 13, or 14), or
  • applicant who has already transferred assets to a community spouse prior to application date on Form 2378H (Form C), or
  • applicant who has consulted with a financial manager or planner (Questions 5 or 6 on Form 3654), or
  • applicant who has not completed Questions 9, 10, 11, 12, 13, or 14 on Form 3654 in their entirety, or
  • any other reason the caseworker deems appropriate for an investigation.

If an application does not meet any of the criteria, process the application in the usual manner. If a criterion is met, complete Long Term Care - Asset Discovery Investigation (LTC-ADI) Referral Form (Form 3654A). A copy of Form 3654A is attached for use until an initial supply is received.

PROCESS FOR APPLICATIONS MEETING ONE OF THE ABOVE CRITERIA

Maximum Allotted Referrals Met For Current Month

When the maximum allotted referrals are met for the current month, send only the completed Form 3654A to the OIG (the address is at the end of this memorandum). Do not attach any documentation. An investigation will not be completed for these additional referrals. However, they will allow the OIG to track the number of applications meeting the referral criteria. Process these applications in the usual manner.

Maximum Allotted Referrals Not Met For Current Month

Until the FCRC refers the maximum number of cases allotted for the current month, immediately refer the application to the OIG (the address is at the end of this memorandum). Attach copies of the application, any asset verifications provided, Form 3654, and the CAF to Form 3654A. Retain a copy of Form 3654 and Form 3654A.

Referral Procedures

The OIG will review each referral to determine if it should be forwarded for investigation. FCRCs will be notified of any referrals not forwarded for investigation. If not forwarded for investigation, process the application in the usual manner.

For referrals forwarded by the OIG for investigation, the investigator will complete the asset investigation within 35 calendar days and verify all assets and asset transfers reported on the application. Since the investigator will verify the information, do not request verifications of assets or asset transfers. However, the FCRC may inform the applicant that the OIG may be contacting them for this information.

If any verifications of assets or asset transfers are received by the local office on a referred application, send the information to the OIG (the address is at the end of this memorandum). Include the case name, case number, and the date the application was referred for investigation.

Applications referred for investigation cannot be approved until the investigation is completed or the local office is advised by the OIG that the referral was not forwarded for investigation. For cases pending beyond the time limits, follow policy at PM 17-03-00.

Applications referred for investigation may be denied prior to the completion of the investigation. If an application is denied, notify the OIG by memorandum (the address is at the end of this memorandum). Include the reason for denial.

If a referred application is transferred to a new local office due to an address change, attach a copy of Form 3654A to the case record. Forward any information received from the OIG to the new local office. Notify the OIG that the application has been transferred to a new local office.

Procedures Following the Completed Investigation

The investigator will forward the results of the investigation to the OIG. The OIG will send an Asset Report to the local office on each application investigated. The Asset Report provides all required information for each asset and asset transfer and includes the following information:

  • type of asset and location (bank name, company name, etc.),
  • account numbers,
  • joint account names (if applicable),
  • current value or balance and date verified,
  • value or balance in the 36 months prior to application,
  • any closing dates and amounts,
  • any asset transfers (asset transferred, amount received, value, date transferred, and reason for transfer),
  • information on changes to the way an asset is held (for example, a bank account is closed and an annuity is purchased with the funds), and
  • any questionable transactions which may affect eligibility.

Local offices will not receive copies of verifications or supporting documentation with the Asset Report. This information will be available upon request from the OIG. The local office may request copies of the verifications and supporting documentation for appeals, when necessary to finalize an application, when documentation is requested by the applicant or representative, and in any other situation deemed appropriate. To obtain copies of the information, or for questions, contact the OIG at (217)524-5097 or fax your request to (217)524-6038.

Along with the Asset Report, the OIG will send an LTC-ADI Recommendation Report to the local office. The report includes the investigation findings and any recommendation by the OIG. Although the OIG may make a recommendation, the local office retains the responsibility for determining eligibility, including whether an asset transfer is allowable or nonallowable. All inquiries by the applicant or representative are to be handled by the local office.

Local office staff must notify the OIG, by memorandum, of the reason any recommendations are not taken.

As stated throughout this memorandum, send all referrals and correspondence to:

Office of Inspector General
Long Term Care - Asset Discovery Investigations
404 N. Fifth St.
Springfield, Il 62702.

[signed copy on file]

CAROL L. ADAMS, Ph.D.
Secretary, Illinois Department of Human Services

BARRY S. MARAM
Director, Illinois Department of Public Aid

Forms referenced:
Form 2378H
Form 3654
Form 3654A