HI 03035: Verification Process and Pre-Decisional Issues
TN 18 (02-11)
This section provides instructions specifically on verifications for cases with agency data from the IRS. Use this section and the instructions in HI 03035.006 for completing the verification screens when a case includes agency data from the IRS.
A. Verify IRS data in MAPS
We receive the same type of data from the IRS for Medicare Part D Extra Help determinations that we receive for the Supplemental Security Income (SSI) and IRS data match. For information about IRS alerts and data development see SI 02310.048. The IRS data is derived from information on IRS Form 1099 and similar reports of financial transactions that financial institutions, brokerage firms, government agencies, employers, etc., submit to the IRS for a tax year.
The IRS data reflects the total amount paid during the tax year. The data we receive is generally two years old (e.g., IRS data received in 2010 is for tax year 2008).
Unlike most other sources of agency data, IRS is not the originator of the payment. Therefore, do not direct the Extra Help applicant to contact IRS to resolve disagreements. IRS will not be able to provide any additional information about the report. Instead, contact the company, institution, or organization that paid the funds and submitted the report to IRS, or have the applicant contact the source to retrieve the evidence needed to resolve the disagreement.
1. Categories of IRS data
For Extra Help purposes, we categorize the IRS data as follows:
Transactions which generally represent unearned income to the applicant or spouse (e.g., pensions, annuities);
Transactions which are indicators of an underlying resource and we can estimate a value of the resource based on the transaction (e.g., interest or dividends); and
Transactions which are indicators of an underlying resource, but we cannot estimate a value of the resource based on the transaction (e.g., proceeds from the disposition of stocks, withdrawals from IRA, 401(k), or similar account).
2. Treatment of IRS data
NOTE: In some cases, we use the data from IRS differently for Extra Help purposes than we do for SSI purposes.
MAPS treats each general IRS transaction type as follows:
Net loss of income - MAPS ignores transactions that reflect a net loss of income.
Savings bond interest - See SI 02310.049B.6., for instructions on verifying and documenting U.S. Government Interest Payments.
-
Unearned income - For transactions that represent unearned income to the applicant or spouse, MAPS divides the amount shown on the IRS record by 12 and displays the result as a monthly income amount.
NOTE: The IRS report could pertain to a one-time distribution or could represent distributions from multiple sources.
Interest and dividends - MAPS uses an estimated prevailing interest rate to estimate the value of the underlying resource and displays that estimated resource value.
Other resource indicators - MAPS totals the other resource values. MAPS displays the combined total of these other resource indicators and the estimated value of the income and dividend producing resources.
For detailed information about how each IRS transaction type is categorized, see the chart located in HI 03035.008. For documentation instructions for pensions and annuities, see HI 03035.012.
3. Treatment of an individual retirement account (IRA), 401(k), or similar account
We count withdrawals from an IRA, 401(k), or similar account as a resource, not as income. If verification is required, develop the case per HI 03035.020, Verification Process for Liquid Resources. Obtain the various agency data about the applicant or spouse as follows:
View the Issue Verification (VRAI) screen in MAPS per MSOM INTRANETMAPS 006.006.
If the applicant alleges that funds shown by the IRS data are from withdrawals from an IRA, 401(k), or similar account, complete the verification per HI 03035.020 and document the verification on a report of contact (DWRC) screen per HI 03035.006D.2. Verify the amount in the underlying account.
NOTE: Do not develop an IRA, 401(k), or similar account data using the pension and annuity verification rules listed in HI 03035.012.
4. IRS detailed data on detailed agency data screen
For each report received from IRS, the Detailed Agency Data Screen in MAPS (accessed by clicking on “View Detailed Agency Data” on the Verification Screen) reflects:
the document code (i.e., the type of form submitted to IRS);
an indication of the type of income involved;
the EIN of the payer; and
the amount paid during the tax year of the report.
5. Verification interviews involving IRS data
If the applicant agrees with the IRS data and can explain the discrepancy between the IRS data and the allegations on the application, follow the instructions in “d” in the If/Then chart at HI 03035.007A.6. in this section.
If the applicant disagrees with the IRS data, alleges no knowledge of income or resources reported by IRS, or cannot adequately explain the discrepancy between the IRS data and the allegations on the Extra Help application, follow the steps in HI 03035.007A.6. in this section to develop and determine the correct amount of income and resources.
NOTE: Based on possible “exceptions” per HI 03035.005C., check all prior DWRC screens to see if the issue has been developed in the past.
6. Steps for verifying IRS data during a verification interview
Use the following steps to complete the verification process when the applicant is unaware or disagrees with the IRS data:
Explain to the applicant that the IRS data is from two years ago and ask if he or she recalls any financial activity that could have resulted in the IRS report. If yes, go to the If/Then chart and process accordingly.
If the applicant is still unable to provide any information, access the Employer Identification File following MSOM QUERIES 005.004 and enter the EIN(s) shown on the MAPS query to identify the payer.
Advise the applicant of the payer's name and ask if he or she recalls having any dealings with that payer. If yes, go to the If/Then chart and process accordingly.
Ask the applicant if it is possible that his or her name and SSN is on someone else's account with the payer. If yes, go to the If/Then chart and process accordingly.
Have the applicant contact the payer to resolve the issue. If you believe the applicant will have difficulty contacting the payer, obtain the applicant's authorization (e.g., an SSA-8510, “Authorization for the Social Security Administration to Obtain Personal Information”) and contact the payer directly. Once you have retrieved the information needed to verify the IRS data, go to the If/Then chart and process accordingly.
If the payer is unable or unwilling to locate any records, make the determination based on the applicant’s statement and available evidence. Document MAPS following HI 03035.006D. No further development is necessary.
If the following applies: |
Then document or develop the file accordingly: |
---|---|
|
Document MAPS following HI 03035.006D. No further development is necessary. |
|
Document MAPS following HI 03035.006D to reflect the applicant's allegation. No further development is necessary. NOTE: If a pension or annuity is involved, see HI 03035.012 for verification and documentation instructions. |
|
Document MAPS following HI 03035.006D to reflect the applicant's allegation. No further development is necessary. |
|
Document MAPS following HI 03035.006D to reflect the applicant's allegation. No further development is necessary. |
|
Develop ownership following HI 03030.010, How Resources Are Counted. Document MAPS following HI 03035.006D to reflect the development. |
B. References
HI 03035.005 - Verification Policy within the Medicare Application Processing System (MAPS)
HI 03035.006 - Verification and Documentation Process for Medicare Application Processing System (MAPS)
HI 03035.008 - Chart with IRS Transaction Types for Medicare Application Processing System (MAPS) During the Verification Process
HI 03035.010 - Income Verification Process
HI 03035.020 - Verification Process for Liquid Resources
HI 03035.030 - Verification Process — Real Property
HI 03020.055 - Income Limits for Subsidy Eligibility