WAG 07-02-20-a: Verifying a Transfer of Resources or Income

PM 07-02-20-a

When a person transfers resources or income, take the following actions:

  • Determine what was received in return for the resource or income and how much it was worth. Use receipts, contracts, written statements, or other documents to verify what was received and how much it was worth.
  • Determine the fair market value (FMV) of the property at the time of transfer.
    • If real property was transferred, verify the FMV using a reputable realtor or other community member knowledgeable of property values (banker, tax assessor, auctioneer, etc.).
    • If personal property was transferred, determine the FMV using: 
      • an institution with knowledge of the property value at the time of the transfer; or a person with knowledge of the transfer and/or the value at the time of the transfer.
  • If the person claims they spent the money received from the transfer, ask them to explain how they spent the money.
    • To verify that the money was spent, use receipts, items purchased, written statements, or other documents. Also consider the person's daily living expenses and possible purchases made with cash.
    • Use judgment when determining if the funds are still available. It is not necessary for the person to account for every dollar. Instead, the person must be able to show that the funds from the transfer are no longer available. 


If the net value of all transfers is New textless than the allowable transfer limit (see PM 07-02-20 for the resource transfer limit), determine whether the transfer was allowable and, if not, calculate the length of the penalty period.


If the net value of all transfers is New textmore than the allowable transfer limit (see PM 07-02-20 for the resource transfer limit), refer the case to HFS Long Term Care - Asset Discovery Investigation (LTC-ADI) Unit using the HFS 3654A Referral Form. The referral packet must include all available information and documents related to the total transfer. LTC-ADI will notify the FCRC of the outcome of its review including the length of the penalty period which must be imposed, if applicable.


Refer LTC cases to the OIG LTC-ADI Unit when the value of all questionable or unexplained transfers totals more than the allowable transfer limit in the 60 months before the application or request for LTC services. Do not refer cases to LTC-ADI when there are no questionable or unexplained transfers, or the questionable transfers do not exceed New textthe allowable transfer limit.


Example: Mrs. M entered a nursing home 6 months ago and applies for LTC this month. She provides bank statements for the last 4 months. There is nothing on the Form 3654 to indicate there may have been any unallowable transfers. The bank statements show she had about $30,000 in her account until six months ago. Her accounts show that $5,000 went to the nursing home every month and that she now has $120 in her account. She has no unexplained transfers. The FCRC does not refer the case to the LTC-ADI Unit.


Example: Mr. J entered a nursing home four months ago and applies for LTC this month. He provides bank statements for the last 4months. Eight months ago, the bank statements show $35,000 was withdrawn and Mr. J was left with a balance of $18,000. four months ago, Mr. J began paying his nursing home charges at $5,000 each month and his account is now $0. Mr. J did not explain what happened to the $35,000 withdrawal. The FCRC refers the case to the LTC-ADI Unit on Form 3654A since the unexplained transfers exceed New textthe allowable transfer limit.

LTC ADI Referral

Refer Long Term Care cases with transfers, which are unexplained or questionable and totaling over $25,000 during the lookback period, to the LTC-ADI Unit using the HFS 3654A Referral Form. FCRCs will review reported transfers totaling $25,000 or less. All applicable documentation should be uploaded to the electronic case record (ECR) in IES.

  • Complete the OIG referral section on the living arrangement page. See wizard Record Living Arrangements for more information. Screenshot of Living Arrangement details below.

Screenshot showing the OIG referral data on the living arrangement page in IES


Once eligibility is run, the LTC EDG should be pending due to an OIG referral. Do not clear the OIG task generated in the ECR until the OIG has returned the case recommendation. The case will not be able to be certified until the OIG has completed its investigation.

Documentation and the reason for the referral should be detailed in the case comment

Screenshot of eligibility summary showing EDG is pending due to OIG referral


Follow office procedure regarding sending OIG referrals. Complete and send Form 3654A to the LTC-ADI Unit by email to HFS.OIG.LTC-ADI@illinois.gov

  • Include the type of referral and the case action (REDE, intake, reopen) in the subject line. Example below.
    • Subject Line: LTC referral -Trust found at REDE.


If the FCRC discovers an unusually large transfer as a result of verifications received after a verification request has been sent for an application that was not initially referred to LTC-ADI, contact LTC-ADI to discuss possible referral at that time. Review by LTC-ADI in such circumstances will be on a case-by-case basis.



When a non-allowable transfer is identified, and a penalty is imposed, notify the applicant of the starting date and length of the penalty period. If an appeal is filed by the applicant regarding a determination by the FCRC or LTC-ADI, notify the LTC-ADI.