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BAM 105 1 of 20 RIGHTS AND RESPONSIBILITIES BPB 2026-016 7-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY All Programs Clients have rights and responsibilities as specified in this item. The local office must do all of the following: • Determine eligibility. • Calculate the level of benefits. • Protect client rights. CLIENT RIGHTS
Right to Apply All Programs On the same day a person comes to the local office, a person has the right to file an application and get local office help to provide the minimum information for filing. An application or filing form, whether faxed, mailed or received from the internet must be registered with the receipt date, if it contains at least the following information: • Name of the applicant. • Birth date of the applicant (not required for the Food Assistance Program (FAP) or the Child Development and Care (CDC) program). • Address of the applicant (unless homeless). • Signature of the applicant/authorized representative. An application/filing form with the minimum information listed above must be registered in Bridges using the receipt date as the applica- tion date even if it does not contain enough information needed to determine eligibility; see Bridges Administrative Manual (BAM) 110, Application Filing and Registration. If an application/filing form does not contain the minimum informa- tion listed above, send it back to the client along with a DHS-330, Notice of Missing Information, informing the client of the missing information.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Exception: FIP, SDA, RCA and FAP If an application is received by the local office for cash or FAP but is not signed by the client, the client should be contacted by phone to obtain the verbal signature. If a verbal signature cannot be obtained, the application should be returned to the client along with a DHS-330, Notice of Missing Information, informing the client of the missing information. Note: If an applicant applies for multiple programs which include FAP and/or CDC and the birthday of the applicant is missing, the FAP and/or CDC programs must be registered. Do not return an application for health care coverage to an applicant; see BAM 115, Application Processing for when to use the DHS-330, Notice of Missing Information. A MDHHS-1171, filing form is not acceptable for any category of health care coverage. Family Independence Program (FIP), State Disability Assistance (SDA), Refugee Cash Assistance (RCA) and Refugee Medical Assistance (RMA) Treat a faxed or emailed application or filing form as an incomplete application. The Michigan Department of Health and Human Services (MDHHS) must receive an original signature before benefits are approved. See Right to Apply in the Client Rights section of this item. FAP A photocopy, facsimile (fax) or an Internet version of a MDHHS- 1171, Assistance Application, or the filing form is acceptable. An original signature is not required. Medicaid (MA) A photocopy, facsimile (fax) or an electronic version of a DCH- 1426, DHS-3243, MDHHS-1171, and DHS-4574 is acceptable. The federal application for health coverage is acceptable for any Medicaid category. Additional information may be required for an SSI-related category. An original signature is not required.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Note: Individuals applying for disability-related MA and/or SDA who have previously been denied by the Disability Determination Service (DDS) must have a new or worsening condition to be referred back to DDS when they submit a subsequent application for these programs; see BAM 815, Medical Determination and Disability Determination Service. Right to Confidentiality All Programs Information concerning individual clients is confidential and pro- tected; see BAM 310, Confidentiality and Public Access to Case Records. Right to Nondiscrimination All Programs Clients have the right to be treated with dignity and respect. For FAP complaints alleging discrimination, clients have the right to make complaints to either of the following: Michigan Department of Health and Human Services Specialized Action Center 235 S. Grand Avenue P.O. Box 30037 Lansing, MI 48909
USDA, See Non-Discrimination Statement/Complaints in this item under FAP. Complaints that are deemed to be potential Americans with Disabilities Act (ADA) or discrimination claims will be routed directly to the county director. The county director will use the Office of Human Resources (OHR) to properly address all aspects of the allegations. All other complaints that come through the specialized action center will be routed to the customer information specialist in the district/county office for follow-up. Michigan Department of Civil Rights (MDCR) and/or US Equal Employment Opportunity Commission complaints regarding clients must be routed directly to OHR for review and a coordinated response with the district/county office. Any mediations, settlements
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
or appeals will be directed to The Legal Affairs Administration for further review and coordination with the district/county office. The Office of Human Resources is responsible for all agency equal opportunity and diversity efforts. For more information, visit the Michigan Department of Health and Human Services website Inside MDHHS/Legal/Equal Opportunity. Non- Discrimination Statements/Compl aints FIP US Health and Human Services (HHS) Nondiscrimination Statement The U.S. Department of Health and Human Services (HHS) complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, religion, or sex (including pregnancy, sexual orientation, and gender identity). HHS does not exclude people or treat them differently because of race, color, national origin, age, disability, religion, or sex (including pregnancy, sexual orientation, and gender identity). HHS Provides free aids and services to people with disabilities to communicate effectively with us, such as: • Qualified sign language interpreters. • Written information in other formats (large print, audio, accessible electronic formats, other formats). Provides free language services to people whose primary language is not English, such as: • Qualified interpreters. • Information written in other languages. If you need these services, contact HHS at 1-877-696-6775. If you believe that HHS has failed to provide these services or discriminated in another way on the basis of race, color, national
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
origin, age, disability, or sex, you can file a grievance with the U.S. Department of Health and Human Services, Office for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, or by mail or phone at: U.S. Department of Health and Human Services 200 Independence Avenue, SW Room 509F, HHH Building Washington, D.C. 20201 1-800-368-1019, 800-537-7697 (TDD) FAP US Department of Agriculture (USDA) Nondiscrimination Statement In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discriminating on the basis of race, color, national origin, sex (including gender identity and sexual orientation), religious creed, disability, age, political beliefs, or reprisal or retaliation for prior civil rights activity. Program information may be made available in languages other than English. Persons with disabilities who require alternative means of communication to obtain program information (such as Braille, large print, audiotape, American Sign Language), should contact the agency (state or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at 800-877-8339. To file a program discrimination complaint, a Complainant should complete a Form AD-3027, USDA Program Discrimination Complaint Form which can be obtained online at: https://www.usda.gov/sites/default/files/documents/ad-3027.pdf, from any USDA office, by calling 833-620-1071, or by writing a letter addressed to USDA. The letter must contain the complainant’s name, address, telephone number, and a written description of the alleged discriminatory action in sufficient detail to inform the Assistant Secretary for Civil Rights (ASCR) about the nature and date of an alleged civil rights violation. The completed AD-3027 form or letter must be submitted to one of the following mail: Food and Nutrition Service, USDA
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
1320 Braddock Place, Room 334 Alexandria, VA 22314 fax: (833) 256-1665 or (202) 690-7442 email: FNSCIVILRIGHTSCOMPLAINTS@usda.gov This institution is an equal opportunity provider. CDC The State of Michigan may not discriminate against individuals applying for or receiving CDC benefits on the basis of race, national origin, ethnic background, sex, religious affiliation, or disability. Right to Request a Hearing All Programs The client has the right to request a hearing for any action, failure to act, or undue delay by MDHHS; see BAM 600, Hearings. Exception: For MA only, a client and the client’s community spouse have the right to request a hearing on an initial asset assessment only if an application has actually been filed for the client. General Complaints FAP Only Record general complaints about the FAP program using the Food Assistance Complaint Tracking Database. The database cannot be used for discrimination complaints. If an individual files a discrimination complaint, the specialist is required to address the issue by following Discrimination Complaints in this item. Examples for when it is appropriate to input general complaints include, but are not limited to: • Overdue FAP applications. • General FAP complaints.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Allegations of inappropriate or rude behavior of the MDHHS staff. • A group's complaint of FAP closure due to incomplete or untimely recertifications. • Allegations the specialist is unresponsive or not acting in a timely manner. Local offices must continually update any complaints and provide detail regarding their efforts at resolution within the database. When new complaints or information regarding prior complaints is received, local offices must make every effort to update the information within 48 hours. Individuals may send complaints about the FAP program to any of the offices listed below: • The appropriate MDHHS local office or self-service processing center. See the MDHHS directory at MDHHS Internet/Inside MDHHS/County Offices/Map of County Offices for office locations. • The Specialized Action Center; see address in Right to Nondiscrimination section in this item. • The Food and Nutrition Service (FNS) regional office: U.S. Department of Agriculture FNS Midwest Regional Office 77 W. Jackson Blvd., 20th Floor Chicago, Illinois 60604-3507 CLIENT OR AUTHORIZED REPRESENTATIVE RESPONSIBILITIES
Responsibility to Cooperate All Programs Clients must cooperate with the local office in determining initial and ongoing eligibility. This includes completion of necessary forms; see Refusal to Cooperate Penalties in this item. Clients must completely and truthfully answer all questions on forms and in interviews.
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The client might be unable to answer a question about themself or another person whose circumstances must be known. Allow the cli- ent at least 10 days (or other timeframe specified in policy) to obtain the needed information. Clients must also cooperate with local and central office staff during quality control (QC) reviews. FAP Only Do not deny eligibility due to failure to cooperate with a verification request by a person outside the group. In applying this policy, a person is considered a group member if residing with the group and is disqualified; see Disqualified Persons in Bridges Eligibility Manual (BEM) 212, Food Assistance Program Group Compensation. When a lack of QC review cooperation is apparent, the QC reviewer notifies the individual of the consequences and sends a copy of the letter to the specialist. If contacted by the individual regarding the audit request, advise the individual to cooperate with the reviewer. Refusal to Cooperate Penalties All Programs Clients who are able but refuse to provide necessary information or take a required action are subject to penalties. Specific penalties can be found in the applicable BEM and BAM items. FIP and SDA Only Begin program closure due to inability to determine continued eligi- bility when notified by a QC reviewer of a group member's failure to cooperate with a QC review. MA Only Refusal to provide necessary eligibility information or to cooperate with a QC review results in ineligibility for: • The person about whom information is refused, and • That person's spouse if living in the home, and • That person's unmarried children under 18 living in the home.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Note: Failure to cooperate with Social Security numbers (BEM 223), Child Support (BEM 255) or Third Party Resource Liability (BEM 257) requirements might disqualify a person but is not a refusal of necessary eligibility information. FAP Only Close the program when notified by a QC reviewer that the group failed to cooperate with a QC review. The reviewer recommends closure on a DHS-1599, Quality Control Audit Results Summary, and the specialist receives a copy. The group is ineligible until after the date shown on the summary attached to the DHS-1599 or until the group cooperates with the reviewer, whichever occurs first. Note: The date shown is 115 days from the end of the QC review period in which the program was scheduled for review. Hearing Request Delete the closure pending a hearing decision if the group requests a hearing during the pended negative action period to contest the reviewer's finding of noncooperation. Attempt to resolve the issue prior to the hearing; see Local Office Review in BAM 600: • If the group agrees to cooperate with the QC review and withdraws the hearing request, notify the reviewer by telephone and follow-up memo. • If the issue remains unresolved, request the reviewer's attendance at the hearing to provide evidence. Note: The reviewer's name will be on the memo that requested the closure of the case and the subsequent quality control results summary issued by the compliance division. If the memo or summary is not available, contact the compliance division at 517- 335-6188. Cooperation During Ineligibility If the FAP group agrees to cooperate with the QC review during the ineligibility period, notify the reviewer by telephone and follow-up
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memo. Accept and process the group's reapplication when notified of the audit findings. Application After Ineligibility If the ineligibility period ends without the FAP group's cooperation in the QC review, the group may reapply. However, all eligibility requirements must be verified, including those which are not rou- tinely verified. Note: This also applies to expedited FAP applications. Responsibility to Report Changes FIP, SDA, RCA, MA and FAP This section applies to all groups except simplified reporting FAP groups; see BAM 200, Food Assistance Simplified Reporting. Clients must report changes in circumstance that potentially affect eligibility or benefit amount. Changes must be reported within 10 days of receiving the first payment reflecting the change. Income reporting requirements are limited to the following: • Earned income: • Starting or stopping employment. • Changing employers. • Change in rate of pay. • Change in work hours of more than five hours per week that is expected to continue for more than one month. • Unearned income: • Starting or stopping a source of unearned income. • Change in gross monthly income of more than $50 since the last reported change. Exception #1: For FAP, groups must report a change in unearned gross monthly income of more than $125 since the last reported change. Exception #2: Only certain changes affect eligibility for Children Under 19 (U19) prior to renewal of benefits.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
See BAM 220, Case Actions for processing reported changes. Other changes must be reported within 10 days after the client is aware of them. These include, but are not limited to, changes in: • Persons in the home. • Marital status. • Address and shelter cost changes that result from the move. For FAP, a change in the group's shelter expense amount without a change in residence, is not a reporting requirement. • Vehicles. (Not required for FAP.) • Assets. • Child support expenses paid. (Not required for FAP.) • Health or hospital coverage and premiums. (Not required for FAP. • Dependent care expenses. (Not required for FAP.) Exception: For FIP only, a parent or other FIP caretaker must notify the department of a child’s absence from the home within five days of the date it becomes clear to the caretaker that the child will be absent for 30 days or more and does not meet temporary absence requirements. For FAP only, see Estimated Medical Expenses, in BEM 554, FAP Allowable Expenses And Expense Budgeting for reporting requirements of medical expenses. Additionally, asset changes are only required for non-categorically eligible FAP groups. For Time-Limited Food Assistance (TLFA) only, the individual must report to the specialist any month the work requirement is not fulfilled. Explain reporting requirements to all clients at application, redeter- mination and when discussing changes in circumstances. Changes may be reported in person, by mail, Mi Bridges or by telephone. The DHS-2240, Change Report Form, may be used by clients to report changes. However, it is not mandatory that changes be reported on the DHS-2240. Changes must be reported timely even if the client does not have a DHS-2240. Give or send the client a DHS-2240: • At application (Bridges automatically sends at certification).
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• At redetermination (Bridges automatically sends at certification). • Whenever it seems appropriate given the case circumstances. • Upon the client’s request. • Whenever a DHS-2240 is returned. Exception: Do not give or send a DHS-2240, Change Report Form, to FAP groups assigned to simplified reporting, or any MA only client. CDC Only Within 10 calendar days of the occurrence, clients are required to report changes in: • Group composition/death. • Out of state residency. • Providers or child care setting. • Assets that exceed $1 million. • When income exceeds the eligibility income scale in RFT 270 for the group size. Verifications All Programs Clients must take actions within their ability to obtain verifications. MDHHS staff must assist when necessary; see BAM 130, Verification and Collateral Contacts and BEM 702, CDC Verifications. LOCAL OFFICE RESPONSIBILITIES All Programs Ensure client rights described in this item are honored and that cli- ent responsibilities are explained in understandable terms. Clients are to be treated with dignity and respect by all MDHHS employees.
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Informing the Client All Programs Inform people who inquire about: • The MDHHS programs available including domestic violence comprehensive services. • Their right to apply. Provide specific eligibility information on all programs in which they are interested. The MDHHS-1171-INFO, Information Booklet, contains information about programs, services, rights and responsibilities. The local office is not expected to: • Provide estate planning advice. • Provide funeral planning advice. • Determine the effect on eligibility of proposed financial arrangements such as a proposed trust. See BEM 100, Introduction regarding public access to policy information. FIP Only Inform clients of the various options (if applicable) to qualify for FIP and the right to select the most beneficial option. In FIP, this is usu- ally the option that results in the largest cash grant; see BEM 210, FIP Group Composition. MA Only The requirement to provide specific eligibility information is satisfied by the eligibility information on the application form. Clients who qualify under more than one MA category have the right to choose the most beneficial category; see BEM 105, Medicaid Overview. FAP Only Local offices must prominently display the following posters:
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• DHS Pub. 521, Your Rights and Responsibilities in the Food Assistance Program. • DHS Pub. 716, Expedited Food Assistance Benefits. • DHS Pub. 765, Right to Apply. • Pub. AD475B, And Justice for All. • DHS Pub. 788, Home Heating Credit Notice. Note: While not mandatory, many of these posters are also available in other languages. Local offices are expected to display these versions as well as the mandatory English version. Assisting the Client All Programs The local office must assist clients who ask for help in completing forms, gathering verifications, and/or understanding written correspondence sent from the department. Particular sensitivity must be shown to clients who are illiterate, disabled or not fluent in English. Note: If such assistance requires interpreter services and the local office is unable to identify an interpreter service provider, please escalate the request to your county's business service center and they will provide guidance on how to assist the client. The poster, DHS Publication 765, Applying for Assistance, must be displayed in the local office lobby. The front page of the application form covers the same information. These documents tell clients that MDHHS must help persons fill out the application when requested. Interpretation The department will provide appropriate interpreters to persons with limited English proficiency (LEP) to afford such persons an equal opportunity to participate in or benefit from MDHHS programs and services. The department and its contracted service providers will take reasonable steps to provide services and information in appropriate languages to ensure that LEP individuals are effectively informed, notified of their rights and responsibilities and can effectively participate in and benefit from MDHHS programs, services and activities.
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The provisions described in this policy apply to all MDHHS programs, contract service providers, and sub-recipients who provide direct services to MDHHS clients. Language interpreters will be available for use by clients and applicants in each phase of the service delivery process (for example, telephone inquiries, intake interviews, service delivery, complaints, etc.) Use of Interpreters The following procedures are to be followed by employees, contracted service providers, and sub-recipients to ensure accessibility of programs and services to clients or applicants with LEP: • Assess the need for an interpreter and client's preferred language or method of communication from the application, client statement, family members or other representative. • Interpreters will be provided within two days of a request or as otherwise required. Delaying services may not always be practical or appropriate; therefore, provision will be made when advance notice for an auxiliary aid or interpreter is not given. Client files must be documented to indicate if an interpreter is needed. If so documented, the department or provider will arrange to have the interpreter available for all scheduled appointments. When the department refers a LEP client to a service provider, the department will notify the service provider that an interpreter is needed. • Record the need for special language accommodations and the applicant’s primary spoken and written language on the Household Information screen in Bridges. A client who needs a bilingual interpreter must be informed that he may choose one of the following: • Arrangements for an interpreter by MDHHS, including payment of any costs. • Use of their own adult interpreter. Note: While MDHHS should honor client preference, MDHHS staff can and should use discretion and evaluate the appropriateness of using the family member or other client selection. MDHHS staff should consider the individual's competency for interpretation, potential conflict of interest, confidentiality, and any potential signs
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of coercion or control over the client by the individual providing interpretation. Minor children should never be used as interpreters. If the client does not identify their own interpreter, select one of the options, in the following order of preference as available, and inform the client of the selection: • MDHHS staff person. Note: Clients cannot decline the use of such an interpreter if they do not select their own. • Face-to-face community agency staff or other volunteer. • Telephone interpreter services should be used as a last resort when face-to-face interpretation is not available, or for an infrequently encountered language. Competency of Interpreters Certification of interpreters is not required; however, competency requires demonstrated proficiency in both English and the other language, fundamental knowledge in both languages of any specialized terms, or concepts unique to the program or activity being interpreted, sensitivity to the LEP person's culture, and a demonstrated ability to convey information in both languages accurately. Training in ethics of interpretation is preferred, but interpreters should at least demonstrate an understanding of the ethics of interpreting and confidentiality responsibilities. Note: These competency expectations apply to all potential interpreters, including MDHHS staff members who are utilized as interpreters. Payment for Interpreters If a MDHHS staff person is not available to interpret and the client declines the use of a volunteer, select one of the following: • Contractual provider of interpreter services. • Interpreter hired on an as-needed basis.
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The client or applicant will not be responsible for any costs associated with interpretation or translation. MDHHS or service provider officials, with budget approval, have the responsibility for approving contracted or purchased interpretation and translation services. Information regarding bilingual interpreter services with payment procedures for non-contractual interpreters can be found on the MDHHS intranet site at Bureau of Grants and Purchasing/Interpretation and Translation Services or MDHHS Internet/Inside MDHHS/Legal/Equal Opportunity & Diversity. Documentation of Interpretation and Translation Document translation/interpretation assistance provided to a client on the DHS-848, Certification of Translation/Interpretation for Non- English-Speaking Applicants or Recipients. Note: If interpretation is provided over the phone, document this information on the interpreter's signature line of the DHS-848. If both client and interpreter are on the phone, acquire signatures on the DHS-848 via fax or email. Interpreters for Persons Who are Deaf Information on obtaining qualified interpreters for people who are deaf is found on the MDHHS Public site at MDHHS Internet/Inside MDHHS/Legal/Equal Opportunity & Diversity. Determining Eligibility All Programs Determine eligibility and benefit amounts for all requested programs. Supplemental Security Income (SSI) recipients, title IV-E recipients, special needs adoption assistance recipients, and department wards are automatically eligible for current MA; see BEM 117, Department Wards, Title IV-E and Adoption Assistance Recipients and BEM 150, MA For SSI Recipients.
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Review the effect on eligibility whenever the client reports a change in circumstances. Actions must be completed within the time period specified in BAM 220. At application and redetermination, thoroughly review all eligibility factors in the case. At application, redetermination, semi-annual contact and mid-cert contact, check all available automated systems matches to see if income has started, stopped, or changed (for example: consolidated inquiry (CI), SOLQ, etc.). Note: Equifax Verification Services (formerly known as The Work Number) is not an automated system match which must be checked at application, redetermination, semi-annual or mid- certification contact. The client has primary responsibility for obtaining verification. However, if, for example, verification of income is not available because the employer uses Equifax Verification Services and won’t provide the employment information, it is appropriate to use Equifax Verification Services. FAP Only If the income information reported by Equifax differs from what the individual reported, verification must be requested or a documented discussion with the individual must be completed. Do not deny or terminate assistance because an employer or other source refuses to verify income; see BAM 130 and BEM 702. Do not check automated systems matches for the program Children Under 19 (U19). Refer to appropriate BEM items for information. CDC Only It is required that the One-Stop Management Information System, (OSMIS), be checked for approved hours of participation at application and redetermination. Application and redeterminations must be completed within the standards of promptness; see BAM 115 and BAM 210. Bridges records and documents each eligibility determination for which there is a certified approval or denial on the Bridges certification screen. Upon certification, Bridges automatically sends a notice of case action, informing the client of the decision.
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Initial Asset Assessment MA Only Process the DHS-4574-B, Assets Declaration, for the initial asset assessment. The client must verify the value of the couple's assets. Notify the client and spouse of the initial asset assessment results; see BEM 402, Special MA Asset Rules. Case actions must be completed within the standard of promptness; see BAM 115. Required Actions When Closing FIP/RCA/SDA FIP, RCA and SDA Only When FIP, RCA or SDA closes due to ineligibility (other than death or inability to locate), the client might remain eligible for MA and/or FAP. Bridges automatically determines if MA eligibility exists under any other MA category before terminating MA and displays the results on the eligibility summary screen. Bridges will not cancel FAP benefits or shorten the FAP benefit period solely because FIP/RCA/SDA closes due to failure to coop- erate in the review process. Unless otherwise ineligible, FAP continues until the benefit period expires; see BAM 210. LEGAL BASE FIP P.A. 280 of 1939, as amended
Mich Admin Code, R 400.3101 - R 400.3131 SDA Mich Admin Code, R 400.3151 - R 400.3180 Annual Appropriations Act
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CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016. MA 42 CFR 431, 435 MCL 400.60(2) The Patient Protection and Affordable Care Act (Pub. L. 111-148) and the Health Care and Education Reconciliation Act (Pub. L-111- 152).
FAP 7 CFR 271.6(a) 7 CFR 272.6(a), (b) 7 CFR 273.2(d) 7 CFR 275.12(g)
Mich Admin Code, R 400.3001 - R 400.3015 RCA 45 CFR 400.65 - 400.69 RMA 45 CFR 400.90 - 400.107
BAM 110 1 of 28 APPLICATION FILING AND REGISTRATION BPB 2025-003 1-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY
Request for Assistance Family Independence Program (FIP), Refugee Cash Assistance (RCA), State Disability Assistance (SDA), Child Development and Care (CDC), Medicaid (MA), Food Assistance (FAP) A request for assistance may be in person, by mail, telephone, email or online. The requester has the right to receive the appropriate application form: • MDHHS-1171, Assistance Application. The MDHHS-1171 packet includes an information booklet, the assistance application, and program specific supplement forms. A filing form used to preserve the application filing date for programs other than Medicaid, is available in the MDHHS-1171 and online at www.michigan.gov/dhs-forms. Note: A MI Bridges online application is considered the same as the MDHHS-1171. • DCH-1426, Application for Health Coverage & Help Paying Costs (all Medicaid categories). A Federal Facilitated Marketplace (FFM) application is acceptable for all Medicaid categories. • Brochures are available on the MDHHS website at www.michigan.gov/mdhhs. Select Doing Business with MDHHS, then Forms & Applications. MDHHS Brochures Available for Download is located in Quick Links in the right navigation. • DHS-4574, Medicaid Application for Nursing Facility Patients, Long Term Care residents only. • DHS-1514, State Emergency Relief Application. Note: Local offices must assist clients who need and request help to complete the application forms; see Bridges Administrative Manual (BAM) 115, Application Processing. Note: If a requestor submits a MDHHS-1171 program specific supplement form(s) without the MDHHS-1171, Assistance Application, treat this as a request for assistance.
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Response to Requests All Programs For a request in person, the local office must do all of the following: • Give the requester an application the same day. • Explain the right to file the application (or the filling form in the MDHHS-1171, with the minimum information) that day and encourage the client to do so. • Explain that the application date might affect the amount of benefits. Encourage the person to complete the entire application that day. Persons who cannot complete the entire application should com- plete the filing form in the MDHHS-1171, to protect their application date. BAM 105 Rights and Responsibilities lists the minimum information to file an application. The filling form in the MDHHS-1171, is not acceptable for Medicaid. For a request by letter or telephone, mail the application by the end of the next workday. If the application is not returned, the requester must be contacted according to local office procedures. See BAM 105 for the minimum information necessary to register an application. Applicants must be informed of their option to obtain a MDHHS- 1171, Assistance Application, which includes a filing form and program specific supplement form(s) or a DCH-1426, Application for Health Coverage and Help Paying Costs, at www.michigan.gov/dhs-forms. Note: Local offices may register requests for assistance in Bridges; see the Requests section in this item. The applicant may withdraw the request for assistance at any time. CDC Only For a request in person, the local office must: • Give the client the following forms:
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The MDHHS-1171, Assistance Application, and MDHHS 1171-CDC, Supplement-Child Development and Care. A DHS-4025, Child Care Provider Verification. Explain that the application receipt date will affect the effective date of eligibility for CDC and encourage the requestor to file the application that day. For a request by letter or telephone, mail the application and the above forms to the requester by the end of the next workday. Note: If a client has a completed, pending MDHHS-1171 or MI Bridges application for another program and verbally requests CDC benefits, document the case and send a DHS-3503, Verification Check List, for the additional required verifications. The CDC application date will be the date the CDC program was requested. Medicaid Only Requests must be registered and the client must be sent the following: • DHS-126, Medicaid Application Inquiry. • The DCH-1426, DHS- 4574 and the DHS- 3243 if necessary. • MSA Pub. 726, Nursing Facility Eligibility (if LTC admission). The following publications must be given or sent to MA applicants and other interested parties: • MDCH Pub. A Guide to Michigan Medicaid Health Plans. • DCH Pub. 617, Medicaid Deductible Information. • MSA Pub. 726, Nursing Facility Eligibility. • MDCH Pub. 769, Medicare Savings Program. For Medicaid brochures from the Michigan Department of Health and Human Services, select Doing Business with MDHHS, then Forms & Applications. MDHHS Brochures Available for Download is located in Quick Links in the right navigation.
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ASSET VERIFICATION PROGRAM At the time an application for healthcare coverage is received and declared assets have been entered into data collection, electronic asset detection will be performed. MDHHS will request electronic asset detection by sending the required fields; name, social security number, and address to the asset detection program. This request may occur at any day or time during the month. Asset detection must be completed with all results returned before healthcare coverage may be certified. This process may take up to 10 days. The balance returned by the program for a given account is always as of the first of the month. APPLICATION All Programs The MDHHS-1171 and program specific supplement forms are used for most applications and may also be used for redeterminations; see Redeterminations in this item. The assistance application and program specific supplement forms are available at www.michigan.gov/dhs-forms. Note: An MDHHS-1171 that does not have a program selected, and is not accompanied by a program supplement form, should be considered a request for assistance. CDC Only The MDHHS-1171 and MDHHS-1171-CDC, or the MI Bridges application may be used to apply for CDC. Medicaid The DCH-1426 or FFM application may be used for all MA categories. In addition, the following application may be used for LTC residents, DHS-4574, Medicaid Application for Nursing Facility Patients. The following persons are automatically eligible without complet- ing an application: • Department wards; see Bridges Eligibility Manual (BEM) 117.
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• Title IV-E recipients; see BEM 117. • Special Needs Adoption Assistance Agreement recipients; see BEM 117. • Newborns of MA beneficiaries; see BEM 145. Retro MA Applications Medicaid Only The DHS-3243, Retroactive Medicaid Application, is used along with the DHS-4574 for retro MA applications. Only one DHS-3243 is needed to apply for one, two or three retro MA months; see Retro MA Applications in BAM 115. When the request for retroactive Medicaid coverage, including specific months, is indicated on the DCH-1426, MDHHS-1171 HCC, Supplement Healthcare Coverage, FFM application, or MI Bridges, a separate DHS-3243 is not required. Who May Apply All Programs Any person, regardless of age, or their authorized representative (AR) may apply for assistance. For FAP only, an AR must apply on behalf of certain clients; see the Authorized Representatives section in this item. Date of Application All Programs Paper Applications The date of application is the date the local office receives the required minimum information on an application or the filing form. Record the date of application on the application or filing form. The date of application does not change when the application is transferred to another local or district office. FAP Only See the Where To Apply/Process Applications / section in this item.
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Electronically Filed Applications All Programs Electronically filed applications include all applications filed online in MI Bridges, faxed, or emailed. FIP, SDA, RCA, CDC, FAP If the application is filed electronically after close of business (such as weekends, holidays, or after 5 p.m. EST on business days), the date of application is the following business day. Medicaid Only For applications filed electronically, the date of the application is the submission date regardless of the time received. Date of Application for Member Add FIP and RCA The date of application or online change request for a member add depends on whether the member being added is a mandatory, optional, or disqualified member. Mandatory Group Members - The date of application or online change request is the date the person updates or completes the application form to request assistance; see Date of Application in this item. Conduct a telephone or in-person interview with the adult member add. Update, document and answer all questions on the application form to provide the information necessary to determine eligibility. The specialist must ask when the person joined the group and document the date on the application. Have the adult mandatory group member sign the DHS-1173, Cash Assistance Rights and Responsibilities, and DHS-1538, Work and Self-Sufficiency Rules. Do not approve eligibility until the DHS-1173 and DHS-1538 are signed. For dependent child member adds, obtain the information needed to determine eligibility and document the case record. The client need not sign the updated application. • Optional Group Members - The date of application or online change request is the date the person updates or completes the application form to request assistance; see Date of Application in this item. If the optional adult group member requests FIP, the DHS-1173 and DHS-1538 must be signed and returned before eligibility can be approved.
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• Disqualified Group Members - The date of application or online change request is the date the person meets the eligibility factor or agrees to cooperate, provided they subsequently cooperate with the requirement that caused the disqualification; see Date of Application in this item. A disqualified person remains a member of the applicant group during the disqualification period. Do not approve eligibility of the disqualified adult group member until the DHS-1173 and DHS-1538 are signed and returned.
Exception: An individual disqualified for non-citizen status does not require a signed DHS-1538. SDA Only The date of application or online change request for a member add depends on whether the member being added is a mandatory or disqualified member. • Mandatory Group Members - The date of application or online change request is the date the person updates or completes the application form to request assistance; see Date of Application in this item. Conduct an interview with the adult member add and update and complete the application to provide the information necessary to determine eligibility. Ask when the person joined the group and document the date on the application. Have the adult mandatory group member sign the MDHHS-1171 or DHS-1173. Do not approve eligibility until the MDHHS-1171 or the DHS-1173 are signed. • Disqualified Group Members - The date of application or online change request is the date the individual meets the eligi- bility factor or agrees to cooperate, provided the individual sub- sequently cooperates with the requirement that caused the disqualification; see Date of Application in this item. A disquali- fied individual remains a member of the applicant group during the disqualification period. Do not certify eligibility of the dis- qualified adult group member until the MDHHS-1171 or DHS- 1173 are signed. CDC Only See BAM 220 Case Actions for CDC member adds.
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Medicaid Only The date of application for a member add is either the date the application form is updated and re-signed in the local office, the date the new application form is received by the local office, or the date the online request is submitted. FAP Only See BEM 550 FAP Income Budgeting for member add policy. Response to Applications All Programs An application or filing form, with the minimum information, must be registered in Bridges unless the client is already active for that program(s); see Registering Applications in this item. If there is no record in Bridges, the system assigns individual ID number(s) and an application number. Note: A person may withdraw an application at any time before it is disposed in Bridges; see Withdrawn Application in this item. DHS Pub. 280, Reporting Changes - When To Report - How To Report - What To Report, describes the client reporting responsibili- ties. This publication must be given to the client at application. Multiple Applications FIP, SDA, RCA, CDC and FAP When an application is pending and additional application(s) are received prior to certification of the initial application, do not auto- matically deny the application(s). Do the following: • Review the information for impact on eligibility and benefit level. • Ensure the case record is documented with the additional application(s) received and note the application(s) used to determine eligibility and/or benefit levels. • Attach the additional application(s) to the initial application.
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When the case is already active for program benefits and additional application(s) are received, the specialist must review the applica- tion for changes in circumstances. Additionally, the specialist must either complete a redetermination or deny the programs requested since they are already active. SDA Only Do not process an SDA application as interim assistance for a client with an application pending for FIP. FAP and CDC The local or district office must screen applications to identify those requiring expedited service at the time the household requests assistance. Information to identify those cases is provided on the assistance application. FAP Only SSI applicants and recipients may apply for FAP benefits at the Social Security Administration district office; see BAM 116 SSI/FAP Joint Application Processing. The local office must register the application upon receipt, using the procedures in BAM 116. AUTHORIZED REPRESENTATIVES All Programs An authorized representative (AR) is a person who applies for assistance on behalf of the client and/or otherwise acts on their behalf (for example, to obtain FAP benefits for the group). Note: An AR is not the same as an Authorized Hearings Representative (AHR); see the Bridges Policy Glossary (BPG) for hearings policy definition. When no one in the group is able to make application for program benefits, any group member capable of understanding AR responsibilities may designate the AR. The AR assumes all the responsibilities of a client; see BAM 105. AR’s must give their name, address, and title or relationship to the client. To establish the client’s eligibility, they must be familiar enough with the circumstances to complete the application, answer interview questions, and collect needed verifications.
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Note: For FAP, if an AR applies on the group's behalf, verification of identity is required for both the AR and the head of household. WHO MAY BE AN AUTHORIZED REPRESENTATIVE (AR) FIP, CDC and SDA An AR must be at least age 18. The person is usually a guardian, spouse or relative outside the group. Severe physical or mental limitations might prevent a client from applying or designating an AR. An unauthorized person who is oth- erwise qualified to be an AR may then apply for the client. MDHHS staff may be authorized or unauthorized representatives for FIP-Foster Care clients only. CDC Only For CDC the authorized representative cannot be the child care provider, a department employee or a recruiter. FAP Only An AR who applies on the group's behalf and is a group member may be any age. If outside the group, they must be at least age 18. Age restrictions do not apply for an AR designated by the group to have access to their FAP benefits to buy the group's food and their own Bridge card. An AR who applies on the group's behalf and/or has access to the group's FAP benefits must be designated in writing by the client, via the MDHHS-1171, Assistance Application, and/or DHS-247, Request for Food Assistance Authorized Representative. See the exception for substance abuse treatment center (SATC) residents below. Ensure that the group is informed of the following: • Clients or their spouses should prepare or review the application, if possible. • The group is responsible for incorrect information provided by the AR that results in an overissuance.
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Exception: When the AR is an SATC or Adult Foster Care (AFC) Home, the facility is responsible for such an overissuance. Medicaid Only Application may be made on behalf of a client by their spouse, parent, legal guardian, adult child, stepchild, core relative or any other person provided the person is at least age 18 or married. If this person is not a spouse, parent, legal guardian, adult child, stepchild, or core relative, the person must have authorization to act on behalf of the client, by the client, client’s spouse, parent(s) or legal guardian. The application form must be signed by the client or the individual acting as their authorized representative. When an assistance application is received in the local office without the applicant’s signature or without a signed document authorizing someone to act on the applicant’s behalf you must do the following: • Register the application as a request if it contains a signature. • Send a DHS-330, Notice of Missing Information, to the individual explaining the need for a valid signature. The signature page of the application may be copied and sent to the agency or individual who filled out the application with the notice. • Allow 10 days for a response. You cannot deny an application due to incompleteness until 10 calendar days from the date of your initial request in writing to the applicant to complete the application form or supply missing information, or until the initial scheduled interview. • Record the date the application or filing form with the minimum information is received. The application must be registered and disposed of on Bridges, using the receipt date as the application date. An application received from an agency is acceptable if it is signed by an individual and is accompanied by written documentation from the individual authorizing the agency to act as the authorized repre- sentative.
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Note: If unrelated adults living in the same home apply for assistance, neither has the authority to act on the other’s behalf without written permission from the applicant. Authorized Representative Medicaid Only An authorized representative must be one of the following: • An adult child or stepchild. • A core relative. • Designated in writing by the individual. • Court appointed. A representative of an institution (such as jail or prison) where the individual is in custody. Persons Providing Medical Care Medicaid Only Persons who provide medical care to the client, or their agents, should not act for the client when there is a relative, guardian or friend who is willing and able to act. If a court has appointed a guardian for a client’s estate (such as income and assets), the guardian is usually expected to act for the client. Exception: An application may be made for newborns surrendered under the Safe Delivery Law, (MCL 712.1-712.20) by the provider hospital, child-placing agency, court appointed lawyer- guardian ad litem or prospective adoptive parent. A department employee may apply on behalf of a member of the employee's family or a child committed to, or placed with, the department by court order. Note: An authorization to represent is a form of a power of attorney. When a person who gave the authorization dies, the power of attorney ends. After death, the person does not exist as a legal entity, so no one can represent the person. However, if a person dies while the application is pending, the application should be processed. An estate may be created to handle the remaining business and financial issues that were outstanding at the time of death. Only a probate court can create a decedent’s estate. The court will also appoint someone to act as a representative of the estate.
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A court, agency or guardian legally responsible for a client must be identified as an authorized representative (AR) by Type on Bridges. AR - SPECIALIZED SITUATIONS
Substance Abuse Treatment Center (SATC) FAP Only An SATC resident must be represented by the center. The SATC designates a responsible staff member as the AR. Residents should assist their AR to complete the application, and both must sign it. Adult Foster Care Home FAP Only AFC residents with a guardian who has legal control over their finances or protective payee must apply through that person, unless the guardian/payee requests in writing that the home act as the AR. The AFC home determines which other residents are capable of applying on their own. Such a resident may apply individually or as part of a group of residents. The resident may submit the application in one of the following ways: • Personally/in person. • Through an AR they choose. • Through an AR employed by and designated by the home. Note: An AFC home may have some residents apply in groups and others as individuals. Restrictions on AR Appointments FAP Only A provider of meals for the homeless cannot be authorized to represent them.
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A person disqualified due to Intentional Program Violation cannot be an AR unless there is no responsible group member or anyone else available. Medical Information Acknowledgment All Programs When the AR completes the application, give or send the client a DHS-4609, Medical Information Acknowledgment, to sign. The DHS-4609 tells the client that MDHHS may share medical information for purposes of eligibility determination and program administration. If clients are unable to sign the DHS-4609 and their condition is such that medical information might need to be shared, refer the AR to Adult Services. Note: If the form remains unsigned, there is no penalty and eligibility determinations must not be delayed. OTHER AUTHORIZED REPRESENTATIVE FUNCTIONS FAP Only An AR may make food purchases from the FAP benefits account using the Bridge card. There is no age requirement for the AR who uses the group’s FAP benefits on behalf of the group. Note: This can be a different person than the AR who applies for benefits on the group's behalf. Enter on the Alternate Payee/Authorized Representative screen in Bridges the name of the person who is authorized to purchase food for the group and indicate the Type of Authorized Representative. The authorized representative’s name will appear on the Bridge card followed by Food Stamp Authorized Representative (FSAR).
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DOCUMENTATION AND CONTROL FAP Only The name of every AR must be in the group's case file. Ensure that a person who purchases food for the group is properly designated on the current MDHHS-1171, Assistance Application. A head of household can call the Automated Response Unit (ARU) to terminate an FSAR’s access. However, a head of household must contact the Family Independent Specialist/Eligibility Specialist (FIS/ES) to request a new FSAR. Ask the caller a question only the head of household could answer to ensure the request is valid and document the case record. Enter the new FSAR on the Alternate Payee/Authorized Represen- tative screen in Bridges and mail a DHS-247, Request for Food Assistance Authorized Representative, to the client for completion and return; see BAM 401E Electronic Benefit Transfer Issuance System. A person may represent any number of groups. When one person (such as an employer of migrants) represents numerous clients or has access to large amounts of food assistance benefits, use cau- tion to ensure the following: • The group freely requested the AR. • The group's circumstances are correctly represented. • The group is receiving the correct amount of benefits. • The AR is using the food assistance benefits properly. DISQUALIFICATION OF AN AUTHORIZED REPRESENTATIVE FAP Only The Office of Inspector General (OIG) determines when an autho- rized representative should be disqualified; see BAM 720 Intentional Program Violation. Upon notification from OIG disqualify the AR from that role for up to one year if the AR does one of the following: • Misrepresents the group's circumstances by giving false information.
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• Improperly uses the group's FAP. The disqualification begins 30 days after the client is notified (see below). Exception: The disqualification does not apply to an SATC or AFC home acting as AR. Report such acts by a facility representative to OIG. Send a MDHHS-176, Client Notice, to the group(s) and the AR, specifying: • The proposed action. • The reason for the proposed action. • The group's right to request a hearing. • The name and telephone number of a local office contact person for more information. WHERE TO APPLY/ PROCESS APPLICATIONS FIP, SDA, RCA and CDC A person may request or apply for assistance electronically or in any local office in Michigan. The application must be processed by a local office serving the county or district where the person lives or is institutionalized. Exceptions: • For SDA and RCA only, an application received online or in the local office must be processed by the local office. • A person who lives in a county participating in the Transparent County Line project may apply and have his/her application processed by any county that is also participating in the Transparent County Line project; see Transparent County Line Project in this item. • For MA only, see BAM 120, MDHHS Coordination. • For MA only, see Transfers: Prohibited Transfers and Transfer Guidelines in BAM 305 Assignment, Reassignment and Transfer for exceptions to transferring cases. • For MA, applications from incarcerated individuals should be processed and maintained in the local office in which the individual lived prior to the incarceration.
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• For an SDA applicant in a special living arrangement (SLA), there are specific processing responsibilities; see BEM 616 State Disability Assistance (SDA) Special Living Arrangement (SLA). • In Wayne County, specialized districts process applications for individuals in supervised settings, or living arrangements, including: Adult and children's foster care. Nursing homes. Hospitals. Youth residential placements.
Separate adult medical districts and child and family districts serve these special client populations. • In Oakland and Wayne counties, specialized districts process applications for refugee individuals and families. • An application for a person living in another state must be pro- cessed by the local office that receives it. If a client contacts a local office in error: • Give or send the client an application and the address and phone number of the correct office. • If the client chooses to complete the application and turns it in at an office which will not be processing the application, do the following: Accept and register it as an application or request as appropriate. Mail it promptly to the correct office so the transfer-in office may act within the standard of promptness; see BAM 115. Medicaid Only A Medicaid application can be processed by the local office serving the client or the authorized representative. MA applications for incarcerated individuals must be handled by the county of residence prior to incarceration.
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Under 19 Medicaid A person may request or apply for the Under 19 MA categories at: • Any local MDHHS office in Michigan. • Any local health department. • Any other MDHHS authorized contract agencies. FAP Only The application must be processed by a local office serving the county or district where the group resides. Exceptions: • In Oakland and Wayne counties, specialized districts process FAP applications for refugee individuals and families. For application filing purposes, persons who are county residents when physically present in a county include: • Students either attending school or living at home during a school break. • Elderly persons living with others for part of the year. • Persons who are working or seeking work. If clients contact a local or district office where they do not reside, do the following: • Give or send them an application, the address, and phone number of the correct county or district office. • Inform them the processing time begins when they submit their application with at least the minimum information required to register the application. • If they choose to complete the application and turn it in at your office, accept it, register it, and electronically send it the same day to the correct county or district office. Note: If an application is auto-registered to a county or district office where the client does not reside, electronically send it the same day to the correct county or district office. The date of an application is the date it is received by MDHHS.
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Exception: Individuals who live in a county participating in the Transparent County Line Project may apply and have their application processed by any county that is also participating in this project; see Transparent County Line Project in this item. TRANSPARENT COUNTY LINE PROJECT FIP, SDA, RCA, CDC, and FAP Transparent County Line project was developed to allow individuals who live in certain northern counties to apply for and obtain services from the MDHHS office that is most convenient for their circumstances, with certain limitations. In order for an individual to utilize the transparent county line project, all of the following must be true: • The county the individual resides in must be identified as part of the county line project; see EXHIBIT I in this item. • The county the individual choses to apply in or obtain services from must be identified as part of the county line project, See EXHIBIT I in this item. • The county of residence must share a border with the county the individual choses to apply in or from which the individual choses obtain services. If an individual submits an application to a local office other than their county of residence, and the situation meets the criteria listed above, have a conversation with the individual regarding whether or not they want to receive services from a county other than their county of residence. An individual may choose to participate in the county line project for any reason. Exception: Some legal and/or fiscal issues may require that services provided for Children’s Protective Services, Children’s Foster Care, Juvenile Justice, and Adult Protective Services cases must occur in the individual’s county of residence. If an individual is active for any of these services, they must have their case maintained in their county of residence.
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WITHDRAWN APPLICATION All Programs A client/AR may withdraw the application any time before it is dis- posed on Bridges. However, if clients have an AR, they must first revoke the AR’s authorization to represent them before the clients may withdraw the application. The signature of the AR is not required. Document the withdrawal request in Bridges. To confirm it, Bridges will automatically generate a notice of case action to the client. The client may reapply any time. REGISTRATION All Programs All applications, redeterminations, referrals, initial asset assess- ments, member adds and program adds must be registered on Bridges. REQUESTS All Programs Requests for assistance may be oral or written. Those containing enough identifying information may be registered. INITIAL ASSET ASSESSMENTS
MA Only Register an initial asset assessment upon receipt of a signed DHS- 4574-B, Assets Declaration. REGISTERING APPLICATIONS All Programs Register a signed application or filing form, with the minimum infor- mation, within one workday for all requested programs. See BAM 105 for the minimum information necessary to register an application.
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All department programs are registered using the registration func- tions on Bridges including Direct Support Services and SER. When registering an application with minimum information, use judgment to code race and sex. The assigned specialist must update the coding, if necessary, when the application is completed. Note: For FAP and CDC only, select unknown when the client chooses not to declare their ethnicity and/or race. CDC, MA and FAP A photocopy or fax of an application or the filing form is acceptable. FIP, SDA, and RCA Only Treat a fax of an application or filing form as an incomplete applica- tion. However, the original signed application must be received by MDHHS before benefits are approved. FAP Only Register joint applications received from the Social Security Admin- istration following normal registration procedures; register all pro- grams the client has checked on page 1. Bridges screens for expedited processing of all FAP applications; see BAM 116. REDETERMINA- TIONS Record the receipt of a signed MDHHS-1010, Redetermination Form, in Bridges. The MDHHS-1010 receipt date is the date the signed form is received in the local office. FAP Only If an untimely redetermination application is the client’s fault, record receipt of the redetermination packet as described above and document client fault in Bridges. The standard of promptness is extended 30 days when the household/client is at fault; see BAM 210 Redetermination/Ex Parte Review. A photocopy or fax of a MDHHS-1171 and MDHHS-1171-FAP, Supplement-Food Assistance Program, MDHHS-1010, MDHHS- 2240-A or the MDHHS-1046 is acceptable.
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MEMBER ADD
All Programs All individuals in a household must be identified and included in the household. Complete an Add Member case action on Bridges for all individuals who move into a household to add them to the existing household and eligibility determination groups (EDGs). Use the Add Member case action to add a new member to existing EDGs and to request assistance in the appropriate group(s) for the new member. Example: Joan and son, Todd, receive FIP and FAP. Joan’s cousin, Polly, moves in and will be purchasing and preparing food with them. Process an Add Member case action to add Polly. On the Program Request screen, indicate that she is requesting benefits on Joan’s FAP EDG but not on Joan’s FIP EDG. Bridges will show Polly’s Status for the FAP EDG as Requesting and Not Requesting for the FIP EDG. ADD A PROGRAM All Programs All new applications must be registered. However, once an applica- tion for any program is pending or active, use the Add Program case action in Bridges to add an additional program(s) to the existing case. Example: The applicant/grantee has a gas shut-off notice and brings it in shortly after the specialist disposed the application. The head of household states they need help with the bill. Use the Add Program case action to add SER to the head of household's case. Bridges records the SER application, using the new application date entered for the program being added. REINSTATEMENTS All Programs Reinstatements are not registered in the Registration function. Record reinstatements on Bridges using the Reinstatement case
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action if all programs were closed on the case. Use the Case Change case action if any program is still active on the case. An application is not required. REGISTRATION DISPOSITION All Programs All denials, including withdrawals, are recorded in Bridges. An application or initial asset assessment pends in Bridges until eligibility determination and benefit calculation (EDBC) is run and the results are certified. Dispose of applications and initial asset assessments within the standard of promptness (SOP). BAM 115 has SOP timeframes. Certifying eligibility results automatically disposes an application. Note: Report MH-132, Worker Registration Report, shows SOP data based on the Bridges application and disposition dates. Initial Asset Assessments Medicaid Only When processing an initial asset assessment, run EDBC and certify results within one workday of completing the initial asset assess- ment. Applications All Programs When a program is withdrawn, enter the reason on the program request screen in Bridges. Certifying the eligibility results automatically records the approval, denial or pend (such as waiting for FIP client to attend Partnership. Accountability. Training. Hope. [PATH].) Bridges automatically sends the client a notice of case action upon certification and also sends a DHS-198, Child Development and Care (CDC) Provider Notice, to the client’s CDC provider when the provider has been authorized to provide care.
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SSI Coordination MA Only Most SSI approvals are opened automatically by the State Data Exchange (SDX) system. Those that cannot be opened automati- cally are opened by the SSI Coordination Unit in central office. Inquiries regarding SSI openings are handled by the SSI Coordina- tion Unit SSI-Bridges-Coord@michigan.gov . See BEM 150 MA for SSI Recipients for details about handling new SSI transfer-ins. EXHIBIT I -TRANSPARENT COUNTY LINE PARTICIPATING COUNTIES County of Residence County Eligible as Transparent County Line Alcona Alpena, Iosco, Montmorency, Ogemaw, Oscoda Alger Delta, Luce, Marquette, Schoolcraft Alpena Alcona, Montmorency, Oscoda, Presque Isle Antrim Charlevoix, Crawford, Grand Traverse, Kalkaska, Otsego Arenac Bay, Gladwin, Iosco, Ogemaw Baraga Houghton, Iron, Marquette Bay Arenac, Gladwin, Midland Benzie Leelanau, Grand Traverse, Manistee, Wexford Charlevoix Antrim, Cheboygan, Emmet, Otsego Cheboygan Charlevoix, Emmet, Montmorency, Otsego, Presque Isle Chippewa Luce, Mackinac Clare Gladwin, Isabella, Mecosta, Midland, Missaukee, Osceola, Roscommon
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County of Residence County Eligible as Transparent County Line Crawford Antrim, Kalkaska, Missaukee, Montmorency, Ogemaw, Oscoda, Otsego, Roscommon Delta Alger, Marquette, Menominee, Schoolcraft Dickinson Iron, Marquette, Menominee Emmet Charlevoix, Cheboygan Gladwin Arenac, Bay, Clare, Isabella, Midland, Ogemaw, Roscommon Gogebic Iron, Ontonagon Grand Traverse Antrim, Benzie, Kalkaska, Leelanau, Manistee, Missaukee, Wexford Houghton Baraga, Iron, Keweenaw, Ontonagon Iosco Alcona, Arenac, Ogemaw, Oscoda Iron Baraga, Dickinson, Gogebic, Houghton, Marquette, Ontonagon Isabella Clare, Gladwin, Mecosta, Midland, Osceola Kalkaska Antrim, Crawford, Grand Traverse, Missaukee, Otsego, Roscommon Keweenaw Houghton Lake Manistee, Mason, Mecosta, Newaygo, Oceana, Osceola, Wexford Leelanau Benzie, Grand Traverse Luce Alger, Chippewa, Mackinac, Schoolcraft
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County of Residence County Eligible as Transparent County Line Mackinac Chippewa, Luce, Schoolcraft Manistee Benzie, Grand Traverse, Lake, Mason, Wexford Marquette Alger, Baraga, Delta, Dickinson, Iron, Menominee Mason Lake, Manistee, Newaygo, Oceana Mecosta Clare, Isabella, Lake, Newaygo, Osceola Menominee Delta, Dickinson, Marquette Midland Bay, Clare, Gladwin, Isabella Missaukee Clare, Crawford, Grand Traverse, Kalkaska, Osceola, Roscommon, Wexford Montmorency Alcona, Alpena, Cheboygan, Crawford, Oscoda, Otsego, Presque Isle Newaygo Lake, Mason, Mecosta, Oceana, Osceola Oceana Lake, Mason, Newaygo Ogemaw Alcona, Arenac, Crawford, Gladwin, Isoco, Oscoda, Roscommon Ontonagon Gogebic, Houghton, Iron Osceola Clare, Isabella, Lake, Mecosta, Missaukee, Newaygo, Wexford Oscoda Alcona, Alpena, Crawford, Iosco, Montmorency, Ogemaw, Otsego Otsego Antrim, Charlevoix, Cheboygan, Crawford, Kalkaska, Montmorency, Oscoda
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County of Residence County Eligible as Transparent County Line Presque Isle Alpena, Cheboygan, Montmorency Roscommon Clare, Crawford, Gladwin, Kalkaska, Missaukee, Ogemaw Schoolcraft Alger, Delta, Luce, Mackinac Wexford Benzie, Grand Traverse, Lake, Manistee, Missaukee, Osceola
LEGAL BASE FIP 45 CFR 206.10(a)(1)(i)(ii)(iii) MCL 400.25 Social Welfare Act, Act 280 of 1939, 400.1 et seq. CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016. RCA 45 CFR 400.65 - 400.69 SDA Current Annual MDHHS Appropriations Act MA 42 CFR 435.906-908 The Patient Protection and Affordable Care Act (Pub. L. 111-148) and the Health Care and Education Reconciliation Act (Pub. L. 111- 152).
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FAP 7 CFR 273.2 7 CFR 273.2(n) 7 CFR 273.3
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DEPARTMENT POLICY Family Independence Program (FIP), State Disability Assis- tance (SDA), Refugee Cash Assistance (RCA), Medicaid (MA) Magi-Related, SSI-Related MA, Refugee Medical Assistance (RMA), Child Development and Care (CDC), and Food Assis- tance Program (FAP) All Programs Individuals must complete and sign one of the following application forms: • MDHHS-1171, Assistance Application, and program specific supplement form(s): MDHHS-1171-CASH, Supplement-Cash Assistance. MDHHS-1171-CDC, Supplement-Child Development and Care. MDHHS-1171-HCC, Supplement-Health Care Coverage. MDHHS-1171-FAP, Supplement-Food Assistance Program. Note: A MI Bridges online application is considered the same as the MDHHS-1171 and program specific supplement form(s) or a DCH-1426. • DHS-4574, Medicaid Application (patient of nursing facility). • DHS-4574-B, Assets Declaration (for initial asset assessment); see Bridges Eligibility Manual (BEM) 402, Special MA Asset Rules. • DCH-1426, Application for Health Coverage & Help Paying Costs. Any application or the MDHHS-1171, Filing Form, with the minimum information, must be registered in Bridges; see Bridges Administrative Manual (BAM) 110, Application Filing and Registration. Following registration of the application, do all the following:
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• Interview individuals when required by policy; see Interviews in this item. • Certify eligibility results for each program within the applicable standard of promptness (SOP); see Standards of Promptness and Processing Delays in this item. • Bridges automatically generates a notice of case action informing the group of the eligibility decision and explains the use of the notice of case actions; see BAM 220, Case Actions. HELPING INDIVIDUALS All Programs The local office must assist individuals who need and request help to complete the application form. The time limit to respond to requests for help completing the appli- cation form depends on the circumstance: • For individuals in the local office, respond within one workday. • For individuals who send a letter, respond by return letter or phone call within five workdays. • For individuals who telephone, respond by either of the following: Return phone call within one workday. Send letter within five workdays. When help cannot be provided by phone call or letter within speci- fied time frames, complete a home call within five workdays. The local office must have designated staff to make home calls to help complete applications in all the following: • Sufficient help cannot be provided by telephone or letter. • The client is physically unable to come to the office. • The client has no one else to help or to come to the office on their behalf.
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Signature Requirement All Programs Before the application or MDHHS-1171, Filing Form, is registered, it must be signed by the client or authorized representative (AR). Note: The signature(s) establishes both of the following: • Client and/or AR understand their rights and responsibilities. • Client and/or AR prepared the application or filing form truthfully under penalty of perjury. Medicaid A MDHHS-1171, Filing Form, is not used to register a request for assistance. CDC Only An applicant who is unable to write may sign with an X, witnessed by one other person such as a relative, friend, department specialist, etc. If the MDHHS-1171 is updated by the client to request CDC, it must be re-signed and dated. FIP, SDA, RCA, and FAP Only If an in-person interview is held, the client and/or AR must sign and date the application in the specialist's presence, even if it was already signed. Sign and date the application as a witness. FAP Only If the FAP group does not have an adult or an AR, a minor group member must sign the application. FIP Only If an in-person interview is held (all adult mandatory group members in the home must sign the application in the presence of the specialist if physically able. If a telephone interview is an option for the group, the specialist must do all of the following:
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• Send the DHS-1173, Cash Assistance Rights and Responsibilities, to all adult mandatory group members in the home that have not signed the MDHHS-1171. Do not approve eligibility until the DHS-1173 is signed and returned by all other adult mandatory group members. Note: If the application is a MI Bridges online application, the head of household has electronically signed the MDHHS-1171. All other adult mandatory group members in the home have not signed the MDHHS-1171. • Send the DHS-1538, Work and Self-Sufficiency Rules, to all adult mandatory group members in the home. Do not approve eligibility until the DHS-1538 is signed and returned by all adult mandatory group members. Note: If the application is a MI Bridges online application, the head of household has electronically signed the DHS-1538. Do not send the head of household on a MI Bridges application a new DHS-1538 unless requested. All other adult mandatory group members in the home have not signed the DHS-1538. • If a MDHHS-1171, DHS-1173 or DHS-1538 is returned to the MDHHS office with a signature that is questionable, require the client to re-sign the MDHHS-1171, DHS-1173 or DHS-1538 in the local office and witness the signature on the required form. SDA and RCA Only The client's spouse and other adult mandatory group members in the home must sign the application in the presence of a specialist if physically able.
SDA Only: If the SDA application is a MI Bridges online appli- cation, the head of household has electronically signed the application. Other adult mandatory group members have not signed the application. Require all other adult mandatory group members in the home to sign the DHS-1173 in the specialist's presence if physically able. Do not approve eligibility until the DHS-1173 is signed by all other adult mandatory group members.
RCA Only: If the RCA application is a MI Bridges online appli- cation, the head of household has electronically signed the application and the DHS-1538. Other adult mandatory group members have not signed the application and the DHS-1538.
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Require all other adult mandatory group members in the home to sign the DHS-1173 and the DHS-1538. Do not approve eligibility until the DHS-1173 and the DHS-1538 are signed by all other adult mandatory group members. Member Add Signature Requirements FIP Only All adult mandatory group member adds must sign and return the DHS-1173 and DHS-1538. Do not approve eligibility of the member add until the DHS-1173 and DHS-1538 is signed and returned for each adult mandatory group member add. INCOMPLETE APPLICATIONS All Programs An incomplete application contains the minimum information required for registering an application. However, it does not contain enough information to determine eligibility because all required questions are not answered for the program(s) for which the client is applying; see BAM 105, Rights And Responsibilities. When an incomplete application is filed, retain the application and give or send the client the DHS-3503, Verification Checklist. Inform the client of the: • Request for contact to complete missing information. • Due date for missing information. • Interview date, if applicable. If an interview is necessary, conduct it on the day of the filing, if possible. Otherwise, schedule it for no later than 10 calendar days from the application date. If a client submits a MDHHS-1171, Assistance Application, but does not submit the program specific supplement form(s), treat this as an incomplete application. Exception: Accept program specific applications in place of the program specific supplement form(s).
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Application Completed Later All Programs When incomplete applications become complete, explain the sit- uation in the case notes section of the application form or in case comments in Bridges. Example: Incomplete application filed October 3, 2016; became complete October 17, 2016. When the applicant or the representative completes a previously incomplete application, the application must be re-signed and re- dated on the signature page. Bridges retains the original registration date, regardless of how or when the application becomes complete. Failure to Complete the Application Process All Programs Do not deny an incomplete application until 10 calendar days from the later of either the initial: • Request in writing to the applicant to complete the application form or supply missing information. • Scheduled interview. Exception: For FAP, do not deny an application if the client has not participated in the initial interview until the 30th day after the application date even if they have returned all required verifications. When denying cases on the 30th day, navigate to the Program Request Details screen and select Failed to Attend Food Assistance Intake Interview as the reason for the denial. The initial interview must be scheduled as an in-person appointment, phone appointment or home call.
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APPLICATION AFTER DENIAL/TERMINATI ON All Programs The following applies when an application is denied, or eligibility is terminated before the month of a scheduled redetermination or end date: • The application on file remains valid through the last day of the month after the month of the denial or termination. To reapply during this time, the client/AR must do all of the following: Update the information on the existing application. Initial and date each page next to the page number to show that it was reviewed. Re-sign and re-date the application on the signature page. This becomes the new application date. Comply with all application requirements. • If eligibility exists, the updated application is valid until the redetermination or end date. Reminder: An application cannot be updated or re-signed out- side the local office except as part of a home call. REINSTATEMENT All Programs A new application is not required to reinstate eligibility; see BAM 205, Reinstatements. WHEN TO USE THE MDHHS-1171All Programs The MDHHS-1171 and program specific supplement form(s) must be completed: • When applying for program benefits. • When case management dictates. Exception: Medicaid (MA) categories use separate application forms; see when to use the DHS-4574 in this item.
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At Initial Application All Programs A separate application is required for each group. Exception: Only one application form is required when MA groups, even with separate case numbers, live together such as spouses applying for different MA categories. An application may be photocopied or cross referenced for multiple case files. An application form is generally valid for 12 months from the date eligibility is initially certified in Bridges. Exception: For FAP, the period might be fewer or more than 12 months; see Benefit Periods under eligibility decisions in this item. MA Only A separate application is required for anyone not in the home, such as one spouse at home and the other in long term care (LTC). FAP Only A FAP group might be ineligible in the month of application but eligible for a future month due to changes in circumstance: • Use the same MDHHS-1171 and MDHHS-1171-FAP, to deny eligibility for the application month and to determine eligibility for later months. • It is not necessary to interview the FAP group again, but Bridges will request any additional needed verification. • Do not deny and re-register the application in Bridges. Certifying approval for the next month disposes of the registration. At Program Transfer All Programs When recipients request benefits, they are not currently receiving, use the MDHHS-1171 or DCH-1426 on file if it was approved within the last 12 months.
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• Update the application and data collection to add or change information to transfer among MA only categories. The client does not have to resign the application. • For other transfers, update the application and have it re- signed; see When The MDHHS-1171 Is Not Needed in this item. Register the new program using the date the application form was re-signed as the application date. Eligibility for a new program or MA category is limited to the renewal or end date already in Bridges. Exception: When an ex parte review of a client’s current Medicaid eligibility case file shows the recipient indicated or demonstrated a disability (see Glossary), continue Medicaid until information needed to proceed with a disability determination has been requested and reviewed. Continue Medicaid coverage until the review of possible eligibility under other Medicaid categories has been completed; see BAM 210, Redetermination/Ex-Parte Review, and BAM 220, Case Actions. MA Only A recipient losing Medicaid under a category for which a DCH-1426 is not needed may need to complete a DCH-1426 in order to transfer to another MA category if a DCH- 1426 has not been approved for another program within the past 12 months. Always give the recipient a reasonable opportunity to complete the DCH- 1426 and to provide the verification of eligibility under other categories before termination of MA; see BAM 220. Exception: Transitional MA eligibility is 12 months from the date of Low-Income Family (LIF) ineligibility; see BEM 111, Transitional MA. At Redetermination/ Renewal FIP, SDA, CDC, SSI-Related MA and FAP Only A new application, MI Bridges redetermination or MDHHS-1010, Redetermination and program specific supplement form(s), must be completed at each redetermination of eligibility. Exception: When policy requires a benefit period shorter than 12 months, the MDHHS-1171 and specific program supplement
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form(s), DCH-1426 or MDHHS-1010 and program specific supplement form(s) on file may be updated and re-signed if both of the following apply: • The application/redetermination was initially certified within the last 12 months. • The client is interviewed (if required) and provides any needed verification before redetermination. MAGI Medicaid MDHHS must use information currently available in the State of Michigan systems to renew eligibility. Do not request information from the beneficiary if the information is already available to MDHHS. This includes completing a renewal form. See BAM 210, Redetermination/Ex parte review/Renewal. FIP At redetermination, if an adult mandatory group member is added to the group, send the individual the DHS-1173 and DHS-1538. Do not approve the redetermination until the DHS-1173 and DHS- 1538 are signed and returned. See additional requirements in BAM 210, Member Add at Redetermination. WHEN A DCH-1426 IS NOT REQUIREDMA Only No DCH-1426 is required to apply for or renew Medicaid or in the following instances: • Transfers to: Transitional MA; see BEM 111. Special N Support; see BEM 113. Refugee Medical Aid; see BEM 630, Refugee Assistance Program. • Transfers between Medicaid categories; see At Program Transfer, in this item. • Supplemental Security Income (SSI) recipients. • Automatically eligible newborns; see BEM 145, Newborns. Authorize the newborn's MA as soon as the child's birth is reported. Contact the newborn's mother if there is not enough information to obtain a beneficiary ID for the child in Bridges.
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• Beneficiaries who complete the DHS-4574, Patient of Nursing Facility. • Department wards, Title IV-E recipients and special needs adoption assistance recipients; see BEM 117, Department Wards, Title IV-E And Adoption Assistance Recipients. • Individuals who apply through the Federally Facilitated Marketplace (FFM). WHEN TO USE A DHS-457 MA Only Instead of the DCH-1426, the DHS-4574, Medicaid Application (Patient of Nursing Facility), for LTC beneficiaries (do not use for waiver beneficiaries) may be used. An approved application is current for 12 months from the original disposition date. RETRO MA APPLICATIONS MA Only Retro MA coverage is available back to the first day of the third cal- endar month prior to: • The current application for FIP and MA applicants and persons applying to be added to the group. • The most recent application (not renewal) for FIP and MA recipients. • For SSI, entitlement to SSI. • For department wards; see BEM 117, the date MDHHS received the court order for a department ward. • For Title IV-E and special needs adoption assistance recipients; see BEM 117, entitlement to title IV-E or special needs adoption assistance. Exception: Full-coverage QMB eligibility cannot be retroactive. ALMB cannot be authorized for a previous calendar year; see BEM 165, Medicare Savings Programs.
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Exception: A person might be eligible for one, two or all three retro months, even if not currently eligible. The DHS-3243, Retroactive Medicaid Application, is used to apply for retro MA. Only one DHS-3243 is needed to apply for one, two or all three retro MA months; see Retro Ma Applications in BAM 110. Do not request a DHS-3243 if the individual is eligible under Children under 19 (U19), Pregnant Women (PW), or MIChild (MCD) Retro MA Eligibility Requirements. Eligibility must be made for each of the three retro months; see Standard retro MA eligibility requirements in this item. When the need for retroactive coverage, including specific months, is indicated on the DCH-1426, DHHS 1171, Healthcare coverage supplement, or MI Bridges, a separate DHS-3243 is not required. Children Under 19 (U19), Pregnant Women (PW), MIChild (MCD) Determine eligibility for the application month first. An individual who is eligible for Children under 19 (U19), Pregnant Women (PW), or MIChild (MCD) for the application month is eligible for retro MA when all of the following conditions are met. This applies even if the retro MA question on the application is not answered or is answered no. 1. The client is eligible for Children under 19 (U19), Pregnant Women (PW), or MIChild (MCD) for the application month. 2. For a pregnant woman, the woman was pregnant or under age 19 for the retro MA month. 3. The person was a Michigan resident. Retro MA cannot be approved for a month if you know the person was not a Michigan resident for the retro MA month. However, assume a person was a Michigan resident unless you have information to the contrary, such as information on the application indicating the person lived in another state. 4. The person is not ineligible because of BEM 265, Institutional Status. Retro MA cannot be approved for a retro MA month if you know the person would be ineligible because of institutional status. However, assume a person was not institutionalized unless you have information to the contrary.
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5. Any applicable post-eligibility patient-pay amount has been computed. An application month may be a long-term care and/or hospital (L/H) month or you may have information suggesting that a retro MA month is an L/H month. In such situations, decide whether a retro MA month is an L/H month and compute the post-eligibility patient-pay amount. Do not approve retro MA coverage for a month until that decision and/or computation is completed. 6. Use the Standard Retro MA Eligibility Requirements below to determine retro MA eligibility if the client is not eligible for Children under 19 (U19), Pregnant Women (PW), or MIChild (MCD) for the application month. Parent/Caretaker (PCR), Healthy Michigan Plan (HMP), Former Foster Care (FFC) MAGI groups which were automatically approved and certified using federal trusted data sources meet the requirements for retroactive Medicaid with no additional verification. • Individuals must request and be approved for only the specific months they need coverage for, not automatic coverage as is true for U19, PW, and MIChild. • Must meet programmatic requirements for requested months. PCR-must have a dependent child during the requested month(s). HMP- retro month must be April 2014 or later. Not a Medicare recipient, at least age 19 and under 65. FFC- not in foster care during retro months. Standard Retro MA Eligibility Requirements MA Only Determine eligibility for each retro MA month separately. To be eligible for a retro MA month, the person must: • Meet all financial and nonfinancial eligibility factors in that month, and
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• Have an unpaid medical expense incurred during the month, or Note: Do not consider bills that the person thinks may be paid by insurance as paid bills. It is easier to determine eligibility sooner rather than later. • Have been entitled to Medicare Part A. Reminder: There is no asset test for MAGI-related Medicaid categories. Financial eligibility policies might affect a pregnant woman's eligibility for retro months. When a client is eligible for a retro month that is also an L/H month, determine the post-eligibility patient-pay amount; see BEM 546, Post-Eligibility Patient-Pay Amounts. UPDATING THE APPLICATION All Programs An application is never returned to the client or AR to update. While an application is considered valid, the client may update the current application rather than complete a new one to add or trans- fer programs or add a member. Note: To add a new program, the corresponding program specific supplement form(s) or DCH-1426 for healthcare coverage, must also be completed by the client or documented by the specialist. Allow updating only if it can be done without obliterating the previous information and there is sufficient room to legibly add the new information. The client must sign and date the application again after updating it. Exception: For FIP dependent child member adds, obtain the information necessary to add the member and document the case record. The client is not required to sign and date the updated application. Exception: For CDC child or adult member adds, obtain the information necessary to add the member and document the case record. The client is not required to update the application; see BAM 220, Case Actions, for CDC MEMBER ADDS.
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Note: For FAP, an interview and an updated application can be requested but cannot be required to add a member. Example: An interview is scheduled to add Alexis' boyfriend to the FAP group. Verifications are supplied for all requested verifications needed to determine eligibility but the interview is not completed. Process the member add. Do not deny the member add or close the case. STANDARD OF PROMPTNESS All Programs The SOP begins the date the department receives an application/filing form, with minimum required information. Exception: For FAP, when a person applies for SSI and FAP before being released from a medical institution, the SOP begins on the applicant's date of release. See BAM 105, Rights and Responsibilities, for the minimum required information for filing. Process applications and requests for member adds as quickly as possible, with priority to the earliest application date; see Processing Delays in this item. Requests for member adds must be entered in Bridges. FIP Only Upon immediate receipt of the FIP application, the specialist must run the FIP Eligibility Determination Group (EDG) in Bridges to timely generate an automated Partnership. Accountability. Training. Hope. (PATH) referral, as well as the DHS-4785, PATH Appointment Notice, to the client. While the specialist should run the FIP EDG immediately, this must be completed within five days of the application date. Certify FIP program approval or denial of the application within 45 days. Note: The specialist must review the MDHHS-1171 and MDHHS- 1171-CASH, for any potential deferral requests prior to running the FIP EDG; see BEM 230A, Employment And/Or Self-Sufficiency Related Activities; FIP.
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SDA, RCA, RMA and MA Only Certify program approval or denial of the application within 45 days. Bridges automatically generates the client notice. Exceptions: • 15 days for all pregnant Medicaid applicants. • 30 days for Refugee Cash Assistance (RCA) and Refugee Medical Assistance (RMA) applicants. • 60 days for SDA applicants. • 90 days for MA categories in which disability is an eligibility factor. The SOP can be extended 60 days from the date of deferral by the Medical Review Team. CDC Only Certify program approval or denial within 30 calendar days from the receipt of application. Bridges automatically generates the client notice. Exception: For groups entitled to CDC expedited service, CDC eligibility must be determined by the seventh calendar day following the date of application; see BAM 118, CDC Expedited Service. MA Only The SOP for an initial asset assessment begins the date the local office receives a signed DHS-4574-B, Assets Declaration. Complete the assessment and mail the client and spouse a notice within 45 days; see BEM 402, Special MA Asset Rules. FAP Only The expedited due date (SOP) is seven calendar days after the application date. The regular FAP due date (SOP) is 29 calendar days after the application date. FAP benefits must be available by the seventh day for expedited and the 30th day for regular FAP. Available means individuals must have a Bridge card and access to their benefits by the seventh day for expedited and the 30th day for regular FAP benefits.
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INTERVIEWS FIP, SDA, RCA, CDC and FAP The purpose of the interview is to explain program requirements to the applicant and to gather information for determining the group's eligibility. The interview is an official and confidential discussion. Its scope must be limited to both of the following: • Collecting information and examining the circumstances directly related to determining the group's eligibility and benefits. • Offering information on programs and services available through MDHHS or other agencies. The person interviewed may be any responsible group member or AR. For CDC, the AR cannot be the child care provider, a depart- ment employee, or a recruiter. The client may have any other person present. Do the following during the interview: • State the client's rights and responsibilities; see BAM 105. • Review and update the application. • Help complete application items not completed when it was filed. • Resolve any unclear or inconsistent information. • Note: For FAP, if the individuals’ expenses exceed their income, have a discussion with them and document the case. • Determine the client’s expenses and current situation by: Adding all the client’s expenses such as rent, mortgage, utilities, taxes, etc. When determining the utility amount to include in the calculation, do not use the heat and utility standards; use the average monthly amount the client is responsible to pay. Verification of their actual bill(s) is not required.
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Asking if they are behind in their bills. For example, ask if they have a shutoff notice, eviction, foreclosure, defaulted on a medical bill, someone else is paying their expenses, etc. If they are not current on their bills or someone else is paying their bills, a front-end eligibility (FEE) referral may not be needed based on the specialist's discussion with the client. • If after the expenses vs. income calculation is completed and the client’s situation is still questionable, open the case and refer to FEE. • Document the entire interview. An interview guide is available in Bridges as a source for documentation (for MDHHS-1171 and MI Bridges applications). Request needed verification not brought to the interview. • Advise the client of the SOP for processing. • Make services referrals if needed. • Confirm if the client needs a Mihealth card and/or Bridge card. • Advise cash and/or FAP individuals how and when they receive benefits. Note: For FAP, the client or AR (interviewed on the client's behalf) must be offered a copy of their completed application. The copy must have the Social Security numbers listed for anyone and/or any mention of domestic violence, redacted. FAP and CDC An interview is required before denying assistance even if it is clear from the application or other sources that the group is ineligible. Note: For CDC do not deny the application if the client has not participated in the scheduled initial interview until the 10th day after the scheduled interview, in order to provide time for the client to reschedule. If the client reschedules the interview and again fails to participate, CDC may be denied. FAP Only Do not deny the application if the client has not participated in a scheduled initial interview until the 30th day after the application
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date even if the individual / has returned all verifications; see Scheduling Interviews for FAP only in this item. FIP Only In addition to the above requirements, the following must be reviewed with all adult mandatory group members during the FIP interview: • Work participation requirements. Identify any potential deferrals listed in BEM 230A. • Direct support service opportunities, including transportation and child care required to attend the PATH orientation; see BEM 229, Path Program Referral & The Application Eligibility Period. • Family Self-Sufficiency Plan (FSSP) requirements listed in BEM 228, Family Automated Screening Tool And Family Self- Sufficiency Plan. • Penalties for non-compliance; see BEM 233A, Failure to Meet Employment And/Or Self-Sufficiency-Relates Requirements: FIP. • FIP time limits; see BEM 234. • Child support requirements; see BEM 255. • Vendoring payments request; see BAM 425, Voluntary Vendor Payments. • Prohibited use of FIP to purchase lottery tickets, alcohol or tobacco. It is also prohibited for gambling, illegal activities, massage parlors, spas, tattoo shops, bail-bond agencies, adult entertainment, cruise ships or other nonessential items. The local office may exempt a relative caretaker or unrelated care- taker ineligible grantee and dependent child member adds from the FIP interview requirements. FIP, SDA, and RCA An interview is not required before denying assistance if it is clear from the application or other sources that the group is ineligible.
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MA Only Do not require in-person interviews as a condition of eligibility. Telephone Interviews CDC and FAP Only Conduct a telephone interview at application before approving benefits. However, conduct an in-person interview if one of the following exists: • The client requests one. • The specialist determines if it is appropriate. For example, the information in the application is suspected to be fraudulent. • Do not require an in-office interview if the client is experiencing a hardship which prevents an in-office interview. Instead, conduct the in-person interview at the client’s home or another agreed-upon location. Hardship conditions include but are not limited to illness, transportation difficulties, work hours, etc. • The application is a joint SDA/RCA and FAP application; see Jointly Processed SDA/RCA and FAP Applications in this item. Note: When conducting a telephone interview, ask the caller a question only the head of household could answer (such as last four digits of his/her SSN, date of birth, etc.) to ensure the identity of the caller. The best practice is to document the case record with the answer to the question. CDC Only If an application is submitted in which the CDC asset question is not addressed, the client must be asked during the telephone interview if the program group has assets that exceed $1 million. FIP Only Note: The specialist must conduct an interview at application with each adult mandatory group member before approving benefits. When conducting a telephone interview, ask the caller a question only the individual being interviewed could answer (such as last four digits of his/her Social Security number, date of birth etc.) to ensure the identity of the caller. Document the case record with the
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answer to the question. Complete this step for each adult mandatory group member. Interviews FIP, RCA, SDA Only The specialist must conduct an in-person interview for each adult mandatory group member at application before approving benefits if any of the adult mandatory group members request an in-person interview. SDA and RCA The specialist must conduct a telephone or in-person interview at application before approving benefits. SDA Do not deny assistance if the applicant is a resident of a juvenile justice facility whose verified expected release date is within two weeks of the date the SDA application was received. Schedule an interview with the applicant to be held within the first five days after release, if possible. Jointly Processed SDA/RCA and FAP Applications Conduct an interview at application before approving benefits. For FAP, do not require an in-office interview if the client is experiencing a hardship which prevents an in-office interview. Instead, conduct the FAP interview by telephone, at the client’s home or another agreed-upon location. Hardship conditions include but are not limited to illness, transportation difficulties, work hours, etc. Home Calls All Programs If eligibility factors are questionable, schedule a home call in Bridges; see Helping individuals in this item. Document the reason for the home call in the case record. For FAP only, some individuals who are unable to appoint an AR for the interview may request it be held at their home or other convenient place. These include:
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• Groups made up entirely of members age 60 or older or mentally or physically disabled. • Groups unable to come to the local office due to a specific problem such as illness, care of a group member, rural isolation, prolonged severe weather or work/training hours. Note: Migrant groups may be interviewed at the work site. Schedule interviews outside the office in advance and hold them during normal weekday working hours unless the client requests another time. When requested, obtain prior supervisory approval. Do not enter a home without permission or under false pretenses. Home searches are prohibited. Single Interview FIP, SDA, RCA, CDC, and FAP Only Individuals applying for multiple programs such as SDA/RCA and FAP cannot be required to attend separate interviews for each. For jointly processed SDA/RCA and FAP applications where the client is experiencing a hardship, the FAP interview must be conducted by telephone, at the client’s home or another agreed-upon location. Hardship conditions include but are not limited to illness, transportation difficulties, work hours, etc. Scheduling Interviews FIP, SDA, RCA, CDC and FAP Schedule interviews in Bridges promptly to meet the SOP. For FAP only schedule the interview as a telephone appointment unless specific policy directs otherwise. The interview must be held by the 20th day after the application date to allow the client at least 10 days to provide verifications by the 30th day. SDA Applicants Exiting Juvenile Justice Facilities For SDA applications received up to two weeks prior to the appli- cant’s expected release date from a juvenile justice facility, schedule the interview to be held within the first five working days after release, if possible, or, if not, as soon as possible.
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Missed Interviews FIP, SDA, and RCA Only If the client misses an interview appointment, the application may be denied after the 10th day from the date the MDHHS-170, Appointment Notice, was sent. FAP Only If individuals miss an interview appointment, Bridges sends a DHS- 254, Notice of Missed Interview, advising them that it is the individuals’ responsibility to request another interview date. It sends a notice only after the first missed interview. If the client calls to reschedule, set the interview prior to the 30th day, if possible. If the client fails to reschedule or misses the rescheduled interview, deny the application on the 30th day. If failure to hold the interview by the 20th day or interview rescheduling causes the application to be pending on the 30th day; see Processing Delays in this item. ELIGIBILITY DECISIONS
Denials All Programs If the group is ineligible or refuses to cooperate in the application process, certify the denial within the SOP to avoid receiving an overdue task in Bridges. Bridges sends a DHS-1605, Client Notice, or the DHS-1150, Appli- cation Eligibility Notice, with the denial reason(s). Medicaid denials receive a DHS-1606, Health Care Coverage Determination Notice. FAP Only An interview is required before denying assistance even if it is clear from the application or other sources that the group is ineligible. For non-expedited FAP, the interview must be scheduled to occur by the 20th day to allow the client at least 10 days to provide verifications by the 30th day. Do not deny the application if the client has not participated in the initial interview until the 30th day after the application date even if the individual has returned all verifications.
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FAP groups must verify all countable income before an application or redetermination can be denied for exceeding the income limit. A VCL must be sent giving the group 10 calendar days to provide the income verification. If the group does not provide income verification by the VCL due date, the application or redetermination must be denied for failure to provide verification. If income verification is provided, the application or redetermination can be denied for exceeding the income limit, if applicable. Subsequent Processing FAP Only Proceed as follows when a client completes the application process after denial but within 60 days after the application date. On or before the 30th day: • Re-register the application, using the original application date. • If the client is eligible, determine whether to prorate benefits according to initial benefits policy in this item. Between the 31st and 60th days: • Re-register the application, using the date the client completed the process. • If the client is eligible, prorate benefits from the date the client complied. Approvals All Programs Bridges sends the DHS-1605 detailing the approval at certification of program opening. Bridges sends the DHS-1606 detailing Medicaid approvals. Send the following publications, as appropriate, if not given at application: • MDCH-201, Your Rights and Responsibility in a Health Plan. • MDCH-669, Medicaid Fee For Service Handbook. • MSA Pub. 617, Medicaid Deductible Information. • MDCH Pub. 726, Nursing Facility Eligibility.
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• MDCH Pub. 769, Getting the most out of life by getting the most out of health care. CDC Notices Bridges sends the DHS-198, Child Development and Care Provider Notice, to each provider who has been authorized to provide care for eligible children and the DHS-198-C, Child Development and Care Client Notice, to the client. These forms notify the provider and client of the application approval and authorization of care. Designation of Head of Household All Programs A member of the group must be designated as head of household for purposes of case identification and benefit issuance. Normally, the group chooses the head of household. Designate a member if either of the following: • Policy prohibits the group's choice from acting as head of household. • The group fails to designate a head of household or disagrees about who it should be. For CDC, see BEM 205, APPLICANT; and BAM 110, Who May Apply. FIP Only The person designated as head of household must meet the defini- tion of caretaker; see BEM 210, FIP Group Composition. MAGI-Related MA Only Designate a core relative as head of household for any case with an unmarried person under age 18 for whom support action is required per BEM 255, Child Support. FAP Only An ineligible or disqualified person can be the head of household if the individual is the only adult in the group. Note: The person is identified as a disqualified EDG member in Bridges.
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Initial Benefits FIP and SDA Only Provided the group meets all eligibility requirements, begin assis- tance in the pay period in which the application becomes 30 days old. If the application becomes 30 days old and the group has not met eligibility requirements, begin assistance for the first pay period when it does. Bridges issues initial benefits as appropriate. RCA Only RCA begins the pay period: • After the pay period that includes the application date. • Provided the group meets all eligibility requirements in that pay period. Note: Do not delay approval of RCA benefits solely for employment and self-sufficiency activity requirements. Participation in self-sufficiency activities is not a condition of initial eligibility; however, it is a condition of continued eligibility. If the application becomes 30 days old and the group has not met eligibility requirements, Bridges begins assistance in the pay period the group meets the requirements. FIP and SDA Only For member adds, see BEM 515, FIP/RCA/SDA Needs Budgeting, Changes In Need, and BAM 110, Date of Application for Member Add. FAP Only Bridges prorates benefits for the month of application, beginning with the date of application, when the group is eligible for the appli- cation month. Exception: Migrant/seasonal farmworker groups that were active in the Food Assistance Program the month before the date of application are eligible for a full month's benefit. This policy applies whether the entire group (or any migrant member of the group) was last active for FAP in Michigan or another state.
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CDC Provider Assignment Effective Date CDC Only The first day that a child care provider may be assigned to a child is the latest of the following: • The CDC application receipt date. Exception: For foster care only, 21 calendar days prior to the CDC application receipt date. • The date the child care began (listed on the DHS-4025). • The date the provider becomes eligible for subsidy payments. • 60 calendar days prior to the receipt of a completed DHS-4025. Note: For payment issuance requirements and provider assignment restrictions; see BEM 706, Provider Payments. Benefit Periods FIP and SDA Only The group's benefit period continues until it no longer meets the program's eligibility requirements. MA Only Benefit periods are discussed in various BEM items. Retro MA Applications are addressed in this item. MA Only Except ALMB Certify MA groups for 12 months when: • All group members are senior and/or disabled, and • The group’s only source of income is SSI and/or RSDI benefits, and • The group is also receiving a 24-month benefit period for FAP. Note: The FAP Mid-Certification form may be used to perform an ex parte review for a second 12-month Medicaid period.
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Exception: ALMB eligibility must be completed before the end of each calendar year. Set the ALMB redetermination date as September, October, November or December, but no more than 12 months. FAP Only The group is eligible for a specific benefit period (in calendar months) with a begin and end date. Begin Date At Application The FAP begin date depends on the group's eligibility and whether the 30-day SOP has been met; see Subsequent Processing in this item. Use the following criteria: • When the 30-day SOP is met, or it is not met but the group is not at fault for the delay, the begin date is either of the following: The application date if the group is eligible for the application month (even if proration causes zero benefits). The first day of the month after the application month if that is when the group becomes eligible. • When the 30-day SOP is not met and the group is at fault for the delay, the begin date is the date the group meets all application requirements; see FAP Fault Determination in this item. Exception: See BEM 610, Migrant/Seasonal Farmworkers, to determine the begin date for migrant/seasonal farmworkers. Begin Date At Redetermination The FAP begin date is the first day of the first month of the new benefit period. End Date The end date used at application or redetermination is always the last day of the final benefit month. Eligibility cannot continue without a redetermination and authorization of a new benefit period; see BAM 210, Redetermination.
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Assigning a Benefit Period Bridges assigns the longest benefit period possible based on the group's circumstances. Certain groups are given a specific mini- mum or maximum benefit period. Unless a specific period is required, benefit periods are assigned to accommodate the group's circumstances. The prorated month counts as the first calendar month of the benefit period. Use the following guidelines and the group's circumstances to establish the group's benefit period. Benefit Period to Coordinate with Other Programs Apply the following policy only to FAP groups that do not have countable earned income. For FAP groups with countable earnings, see 12-Month Benefit Period in this item. If the FAP program was opened prior to the other program and the client applied for both programs at the same time, either of the following may be done: • Redetermine eligibility for the other program when the FAP benefits are due to expire (this may result in an 11-month redetermination for the other program). • Redetermine FAP so the end date is extended to the last day of the other program’s redetermination month, provided this does not exceed 12 months. Exception: It may not be possible to coordinate FAP benefit periods for groups that qualify for 24-month benefit periods or groups that require a shorter benefit period. 24-Month Benefit Period Bridges assigns a 24-month benefit period for groups in which all group members are senior and/or disabled and the group does not have any income, or its only source of income is SSI and/or RSDI benefits. Note: The annual mass update in RSDI and SSI benefit amounts does not affect this certification. If a group reports a change in circumstances that affects its benefit period, such as a non-disabled/non-senior person joining the household, Bridges does all the following:
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• Shortens the benefit period according to policy in BAM 220. • Schedules a redetermination. • Sets a new (12 months or less) benefit period consistent with the group's circumstances. Conduct a mid-certification contact with the FAP group once each year. The RD-093, Redetermination Report - Worker Listing, serves as notification that contact is due; see BAM 210. 12-Month Benefit Period Bridges assigns a maximum 12 months for FAP groups that do not qualify for a 24-month benefit period or that do not require a shorter benefit period. For example: • Groups with a mandatory TLFA participant working less than 20 hours per week (80 hours a month). • Migrant/seasonal farmworker groups. Note: FAP groups that are simplified reporters must have a 12- month benefit period. Conduct a mid-certification contact with the FAP group once each year. A notice will be sent when a contact is due on the RD-093, Redetermination Report - Worker Listing; see BAM 210. Three-Month Benefit Period If a group’s circumstances are not stable and do not fit any other benefit period, a three-month benefit period may be assigned. Benefit periods for these groups should be determined on a case- by-case basis. Always assign the longest benefit period possible. Three months is the minimum benefit period which can be assigned. Example: Kathy and 13-year-old child apply for FAP. Kathy is a migrant/seasonal farmworker who just started working and has a shelter expense. Their employer indicates they will be working 30 hours per week. Assign a three-month benefit period or a 12-month benefit period based on the case circumstances. If based on their case circumstances, it is determined a three-month benefit period is warranted, indicate this on the Unstable Circumstances Details Screen. Document the rationale for choosing the benefit period given. Example: Kathy is a migrant/seasonal farmworker who has no income and no obligation for rent and utilities due to living with friends. A 3-month benefit period may be given.
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However, after discussion with the client, it is determined a 12- month benefit period is appropriate. Deferred Actions All Programs To speed eligibility determinations, defer completion of required actions listed below. FIP, SDA and MA Only Referral to the prosecutor of spouses or parents of minor head of households living outside the home. The referral must be made within 14 days of the case opening. MA Only Receipt of a reply to an interstate inquiry regarding individuals who moved to Michigan within 30 days before applying. Make the inter- state inquiry before approving the application. FAP Only When processing expedited service applications both of the follow- ing actions are deferred: • Verifications, other than identity. • For FIP/SDA/RCA-related Food Assistance groups, actions required for the other program. See BAM 117, FAP Expedited Service. CDC Only When processing applications for groups entitled to CDC expedited service, defer verifications, other than identity; see BAM 118. Follow-Ups All Programs Create a manual task in Bridges or other follow-up device when either of the following occur: • Information indicates a potential change in circumstances. • An action has been deferred.
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Bridges will automatically display the task for follow-up on the date that is specified. Department Errors All Programs As soon as possible, document and correct benefits approved or denied in error by changing Data Collection, running Eligibility Determination Benefit Calculation (EDBC) and certifying the results. Bridges sends the client a timely or adequate notice as appropriate for department error corrections resulting in: • Program eligibility or ineligibility. • Increased or decreased need. • Higher or lower patient-pay amount. FIP, SDA, RCA and FAP Only See BAM 405, FIP, RCA AND SDA Supplemental Benefits, and BAM 406, Supplemental Food Assistance Benefits, regarding supplemental benefits. See BAM 705, Agency Error Overpayment, and BAM 715, Client/CDC Provider, regarding recoupment. CDC Only See BAM 705, for procedures to be followed when a department error has occurred. MA Only The period of erroneous coverage cannot be removed from or reduced in Bridges. Service Referrals All Programs Individuals may need referrals to Adult Services, Adult Protective Services, Preventive Services For Families, or Children’s Protective Services. Be alert to those needs and refer cases when indicated or required. If there is a disclosure of domestic violence, and the client is not receiving services, refer the client to the appropriate community service.
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If there is reasonable cause to believe an adult or child has been abused, neglected or exploited, make a referral immediately by call- ing 1-855-444-3911. For all other service programs follow local office procedures. FIP and MA Only Inform individuals under age 21 of the Early and Periodic Screening, Diagnosis and Treatment (EPSDT) program. At an in- person interview, give the client MSA Pub. 491 or 498. Use local office procedures for EPSDT scheduling and/or transportation. CASE ASSIGNMENT All Programs Bridges assigns cases to the next available specialist based on the specialist’s Manage Office Resources profile and/or special skills such as language, long-term care etc. Application assignment does not differentiate between case managers and non-case managers (NCM). If a cash application is assigned to an NCM, and Bridges builds a FIP or RCA Eligibility Determination Group (EDG), reassignment to a case manager must be accomplished manually. PROCESSING DELAYS All Programs If an application is not processed by the SOP date, document the reason(s) in the case record. Document further delays at 30-day intervals. Exceeding the SOP cannot be the sole reason for a denial. When one program approval/denial will exceed the SOP, certify eli- gibility results for any others such as FAP within the SOP, if possible.
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FAP Fault Determination FAP Only For a pended application, determine who is at fault for the delay every 30 days after the application date. Note: This affects an approval of benefits for the months of delay, but not necessarily a denial; see Denials under Eligibility Decisions in this item. FAP Group at Fault If the 30-day SOP is not met and the group is at fault, the following applies: • Select yes for the Extend SOP due to group at fault question on the Program Request Details screen for FAP. • Bridges sends a DHS-1150-E, Food Assistance Application Notice, to inform the group that the EDG is pended and will be denied on the 60th day unless the needed actions are taken. • Bridges prorates benefits from the date the group complies with all application requirements. The group is at fault when you have taken all required actions, but the group has not complied with either of the following: • Provided all verifications by the 30th day, despite 10 days or more to provide them. • Participated in the scheduled interview; see Interviews in this item. Local Office at Fault If all necessary actions have not been completed and the applica- tion will pend beyond the 30th day, the following applies: • Send the group a DHS-5301, Pending Food Assistance Application Notice, to inform them of the pending status. • Take prompt action to correct the cause of the delay. • If eligible, the group's benefits begin with the application date.
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The local office is at fault if the specialist fails to: • Request necessary verifications at least 10 days before the 30th day. • Provide requested help to complete the application process or secure verifications. • Schedule a timely interview, resulting in less client time than policy requires to take an action; see Interviews in this item. • Run EDBC and certify results to authorize benefits. FAP Delays Beyond 60 Days FAP Only If the application pends beyond 60 days, obtain missing information, if possible, and process the application. There are three possible consequences: • Case information complete. If the group is eligible and the local office was at fault on the 30th day, authorize benefits from the application date. If the group was at fault on the 30th day, benefits begin on the date the group completes the application process. • Local office at fault, case information not complete. Request missing information via DHS-1150, Application Eligibility Notice, and verification checklist if appropriate. Give the group 10 days to provide verifications. Authorize benefits as for complete cases above. • FAP Group at fault, case information not complete. This occurs only if verification requested between the 30th and 50th day was not provided, and the application is still pending. Deny the application by running EDBC and certifying the results immediately. LEGAL BASE FIP MCL 400.25 45 CFR 260.10
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Mich Admin Code, R 400.3107, 400.3108, 400.3110, 400.3111, 400.3155, 400.3156 RCA 45 CFR 400.50 - 400.53 RMA 45 CFR 400.93 - 400.104 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016. SDA Current Annual Appropriations Act Mich Admin Code, R 400.3151 - 400.3180 MA 42 CFR 431, 435 The Patient Protection and Affordable Care Act (Pub. L. 111-148) and the Health Care and Education Reconciliation Act (Pub. L. 111- 152). FAP 7 CFR 273.2
BAM 116 1 of 4 SSI/FAP JOINT APPLICATION PROCESSING BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY This item applies to Food Assistance Program (FAP) benefits only. FAP groups consisting entirely of Social Security Income (SSI) applicants or recipients may choose to apply for FAP benefits at the Social Security Administration (SSA) office. This includes individuals who apply for SSI and FAP benefits before being released from medical institutions. Whenever an SSI individual contacts the SSA office for any business, SSA will advise the individual of the right to apply for FAP benefits at the SSA office. SSI individuals retain the option of applying for FAP benefits at an Michigan Department Health Human Services (MDHHS) office. The MDHHS-1171, Assistance Application, and the 1171-FAP, Supplement-FAP are used for SSI individuals choosing to apply for FAP at the SSA office. SSA screens the MDHHS-1171 for potential entitlement to expedited service and informs the applicant that they may receive benefits sooner if they apply at an MDHHS office. SSI individuals may also complete the redetermination process at the SSA office. All FAP redetermination policies in Bridges Administrative Manual (BAM) 210, Redetermination/Ex Parte Review, apply except the in-person interview must be waived if requested by an SSI group and the group is unable to appoint an authorized representative. SSA will handle the application in the same manner as an initial application but will indicate in red at the top of the MDHHS-1171 that it is a redetermination. Individual Rights and Responsibilities SSI groups are entitled to the same rights and have the same responsibilities as any other FAP group. SSA Responsibilities When an SSI group chooses to apply for FAP through SSA, they will take the following actions: • Assist the individual in completing the FAP application. • Prescreen each application for entitlement to expedited service and mark “Expedited Processing” on the first page of all applications which seem to require it.
BAM 116 2 of 4 SSI/FAP JOINT APPLICATION PROCESSING BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Interview with the applicant. • Attach a transmittal form to all applications regarding verification(s). See Verification Provided by SSA in this item. • Forward applications to the designated local office within one working day after receiving receipt. • Give the applicant the local office pamphlet (or loose materials) which provides basic program information, issuance informa- tion, and instructions for obtaining FAP. SSA orders these materials through the local office. • Give the applicant information on how and where to receive Electronic Benefit Transfer (EBT) training. Food Assistance benefits issued in the form of EBT are accessed using a plastic Bridge Card. Individuals must be aware of what is required of them if they don’t go into the local office. Local offices should arrange with their local SSA office for the most convenient and timely method for transmitting applications. Local Office Responsibilities Upon receipt of a signed application from SSA, the local office must take the following actions: • Register the application if the individual has not already applied for or been approved for FAP benefits. Use the date filed at SSA for the application date. • Process applications according to the appropriate standard of promptness, based on the date they were filed at the SSA office. (See Exception below.) • Bridges automatically screens all applications for expedited service. The expedited service timeliness standard begins on the date after the application was received at an MDHHS office; see Exception in this item. Exception: Individuals may apply for SSI and FAP benefits before being released from medical institutions. The application filing date for these applications is the date of release from the institution. Example:
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Application completed 10/10/08 Date of Release 10/10/08 SOP: (expedited FAP) 10/17/08 (non-expedited) 11/9/08 Interviews Since SSA conducts the interview, the local office is not required to reinterview the applicant. The MDHHS specialist must not contact the group unless: • The application is improperly completed. • Mandatory verification is missing. • Certain information on the application is questionable. If the specialist contacts the SSI/FAP group for one of the above reasons, the specialist cannot require the group to come to the local office or discuss items which are unrelated to the reason for the contact. Verification Provided by SSA All mandatory verifications must be obtained prior to approving eligibility. Verification may be provided by SSA via the SSA-4233, Social Security Administration Transmittal for FAP Applications, or through the usual means of verification. SSA will provide all verification available at application. The trans- mittal form will indicate one of three things regarding each item requiring mandatory verification. • Verified. The verification or a photocopy will be attached. • In SSI File. The item is verified, but the document was retained in the SSI file. This statement from SSA is acceptable verification for FAP purposes. • Not Verified. Verification was not available to SSA and must be obtained by the MDHHS specialist. In addition, the SSA workers will indicate areas which are question- able on the back of the transmittal form. The SSA workers will verify these areas if the verification is available at application.
BAM 116 4 of 4 SSI/FAP JOINT APPLICATION PROCESSING BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
If a group returns needed verification to SSA rather than an MDHHS office, SSA will forward it using an SSA-4233 marked “Evi- dence Only.” Verification not provided through SSA must be provided by the group or obtained through automated system matches. The match from SSA may be used to verify SSI status and benefit amount. If the match indicates earned income, it cannot be used to verify the earned income. Also, the FAP group must be given the opportunity to provide verification from another source if the information from SSA contradicts other group information. Do not delay processing the application while waiting for the HR- 070 or BENDEX report. Eligibility Factors SSI/FAP groups must meet all FAP non-financial and financial eligi- bility factors listed in the Bridges Eligibility Manual (BEM). Benefit Periods Assign a benefit period according to the guidelines in BAM 115, Application Processing, Benefit Periods. CHANGES SSI/FAP groups must report changes within 10 days. See BAM 105, Rights and Responsibilities, Responsibility to Report Changes. The FAP group will receive information from MDHHS if their reporting requirements are different. Complete any necessary budget changes in Bridges upon learning of the SSI determination. If the information is discovered and it appears that the FAP group did not report receipt of SSI benefits within 10 days of receipt of first payment as required, an overissu- ance may have occurred. Handle the overissuance according to policy in BAM 700, Benefit Overpayments, and BAM 720, Intentional Program Violation. LEGAL BASE FAP 7 CFR 273.2(k) 7 CFR 273.12 7 CFR 274.2
BAM 117 1 of 7 FAP EXPEDITED SERVICE BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY The policy in this item applies to the Food Assistance Program (FAP) benefits only. The purpose of FAP expedited service is to help the neediest individuals quickly. Defer certain processing requirements and actions (identified in this item) due to the shortened standard of promptness (SOP). DEFINITIONS Expedited Service Has a shorter SOP and fewer verification requirements to determine FAP eligibility than are normally required. Liquid Assets Include: • Cash on hand. • Checking or savings accounts. • Savings certificates. EXPEDITED SERVICE CRITERIA Eligibility factors are the same for expedited as regular FAP benefits. Applicant groups are entitled to expedited service if one of the fol- lowing applies: • They have less than $150 in monthly gross income and $100 or less in liquid assets. • They are destitute migrant or seasonal farmworkers and have $100 or less in liquid assets; see BEM 610, Migrant/Seasonal Farmworkers. • The group's combined gross income and liquid assets are less than its monthly rent and/or mortgage payments plus the Heat and Utility Standard, Non-Heat Electric, Water and/or Sewer, Telephone, Cooking Fuel or Trash Removal Standards. FAP groups entitled to expedited service are required to do all the following:
BAM 117 2 of 7 FAP EXPEDITED SERVICE BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Complete and submit a MDHHS-1171, Assistance Application, and a MDHHS-1171-FAP, Supplement- Food Assistance Program. • Participate in an interview (for example, in-person, telephone, etc.). • Cooperate with certain verification requirements; see Minimum Verification in this item. IDENTIFYING GROUPS ENTITLED TO EXPEDITED SERVICE Bridges screens all FAP applications to identify those requiring expedited service. Answers to the questions on the MDHHS-1171, applicant registration page, provide the information needed to identify expedited service cases. This information is input on the Expedited Screening page. The group does not have to request expedited service. A group cannot waive its right to expedited service. If the individual is unable to complete the entire assistance application, they can complete the filing form to start the SOP and answer questions related to expedited service processing on the form. The filing form is located on page one of the MDHHS-1171, Assistance Application. STANDARD OF PROMPTNESS FAP groups entitled to expedited service must have a Bridge card and access to their benefits no later than the seventh calendar day following the date of application; see Bridges Administrative Manual, (BAM) 115, Application Processing, Standard of Promptness, FAP Only. EXCEPTIONS TO THE EXPEDITED STANDARD OF PROMPTNESS Extend the standard of promptness in the following situations:
BAM 117 3 of 7 FAP EXPEDITED SERVICE BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• A telephone interview is conducted, and the application is incomplete. The standard of promptness begins on the day the signed, completed application is received by the local office. • Entitlement to expedited service is not identified during the screening process but is discovered by the specialist during normal processing. The application must then be processed according to expedited service standards. The standard of promptness begins on the date of discovery. The discovery date must be documented in the case record. INTERVIEWS FAP groups entitled to expedited service must participate in an interview. See BAM 115, Application Processing, Interviews, for specific interview policy. If the application is filed in person, including MI Bridges on the lobby kiosk, the interview must be held, and the application processed on the same day unless the individual requests a postponement. If the FAP group applied by mail, fax, Mi Bridges, etc., they must be contacted within one working day of the application. All efforts must be made to complete the interview and process the application the same day. If they cannot be contacted within one day to be interviewed, this fact must be documented in the case record. The interview must be conducted no later than one working day after contact is made. Provide any necessary help in completing the application during the interview. If a telephone interview is conducted, and the application is incomplete, complete it and mail a copy to the individual for review and signature. MINIMUM VERIFICATION In all cases, the applicant's identity must be verified; see Bridges Eligibility Manual (BEM) 221, Identity. The data match with the Social Security Administration (SSA) is sufficient to verify identity for FAP. Reasonable effort must be made to verify: • Residency. • Income or lack of income. • Assets (only for non-categorically eligible groups), and • All other eligibility factors.
BAM 117 4 of 7 FAP EXPEDITED SERVICE BPB 2025-022 10-1-2025
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Note: FAP benefits cannot be delayed beyond the expedited standard of promptness solely because these eligibility factors (other than identity) have not been verified. BUDGETING Allowable shelter deductions are: • Rent/Mortgage. • Heat and utility standard, or • Non-heat electric standard, and/or • Water and/or sewer standard, and/or • Telephone standard, and/or • Cooking fuel standard, and/or • Trash removal standard. FAP FAULT DETERMINATION For pending FAP expedited service applications, determination of fault must be made at seven-day intervals after the date of application. The FAP group is at fault when all required actions have been taken, but the FAP group has not taken one or more of the following actions: • Completed the application form. • Provided verification of identity. • Completed the scheduled interview. If the FAP group is at fault, answer yes to the Extend SOP due to group at fault question on the Program Request-Details screen. The extension should be used as a last resort. This prevents the registration from being overdue on specialist's registration reports and extends the standard of promptness to 29 days following the date of application. BENEFITS AND BENEFIT PERIODS Prorate benefits for the month of application, beginning with the date of application, when the group is eligible for the application month as for other FAP program groups; see BEM 556, Computing the Food Assistance Budget and BAM 115.
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Exception: Migrant/seasonal farmworker groups that were active in the FAP program the month before the date of application are eligible for a full month's benefit. This policy applies whether the FAP group (or any member of the FAP group) was last active in Michigan or another state. Benefit periods are assigned to expedited service cases according to the guidelines in BAM 115. Note: Groups with unstable circumstances may be assigned a short benefit period; see examples in BAM 115. SUBSEQUENT BENEFITS Food Assistance groups that did not provide all required verifica- tions will not be issued benefits for subsequent months until the FAP group provides the waived verification. Groups that apply after the 15th of the month receive a minimum benefit period of two months (month of application and following month), if the individual is eligible for expedited benefits for both months. One of the following standards of promptness must be met based on when verification requirements are met. If they are met: • Before the end of the application month, issue the second month's benefits on the first working day of the second month.
Example: Application = September 10
Expedited Opened = September 12
SOP = September 17
Verifications Received = September 25
Must Issue Second Month = October 1 • In the second month, issue the second month's benefits within five workdays.
Example: Application = September 10
Expedited Opened = September 12
SOP = September 17
Verifications Received = October 2
Must Issue Second Month = By October 7 Note: This second example will only occur if the verification is returned within 30 days of the date of application and the
BAM 117 6 of 7 FAP EXPEDITED SERVICE BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
application is subject to subsequent processing; see BAM 115, Application Processing, Subsequent Processing and BAM 130, Verification and Collateral Contacts. If waived verifications/actions are not met by the 10th day following the request, take the required actions in Bridges timely to deny the ongoing FAP benefits for the remainder of the benefit period. LIMITS ON EXPEDITED SERVICE There is no limit to the number of times a group can be approved under expedited procedures. However, prior to the next expedited approval, the FAP group must either: • Complete the verification requirements that were postponed at the last expedited approval (regardless of the amount of time that has expired); or • Be processed under normal application processing standards. DENIAL OF EXPEDITED SERVICE Verbally notify the individual of the denial if expedited service was registered. Process applications denied for expedited service according to normal application processing standards described in BAM 115. In addition, refer the individual to appropriate emergency programs and/or resources for which they may be eligible. When the individual is denied expedited service but appears eligible for food assistance benefits, Bridges will: • Automatically change the application to a regular FAP application using the original application date once you’ve entered the individual’s information on the expedited screening page in the program request logical unit of work. • Set the due date to 29 days from the original application date. Advise individuals denied expedited service they can request a supervisory conference and/or a hearing if they disagree with the decision; see BAM 600, Hearings. Do not hold the application pending the result of a hearing. If the individual requests a
BAM 117 7 of 7 FAP EXPEDITED SERVICE BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
conference, it must be held within two working days of the request, unless the individual requests that it be scheduled later. LEGAL BASE FAP 7 CFR 273.2(i) 7 CFR 273.14(f)
BAM 118 1 of 6 CDC EXPEDITED SERVICE BPB 2022-005 4-1-2022
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY The policy in this item applies to the Child Development and Care (CDC) program only. The purpose of CDC expedited service is to help the neediest clients quickly. Certain processing requirements and actions (identified in this item) are deferred due to the shortened standard of promptness. EXPEDITED SERVICE CRITERIA Eligibility factors are the same for expedited as regular CDC benefits. Applicant groups are entitled to expedited service if one of the fol- lowing applies: • The child is experiencing homelessness. • The child is considered foster care eligible, as defined in this item. CDC groups entitled to expedited service must do all the following: • Complete and submit a MI Bridges Application or a MDHHS- 1171, Assistance Application, with a MDHHS-1171-CDC Supplement. • Participate in an interview (for example, in-person, telephone, etc.). • Cooperate with certain verification requirements; see minimum verification in this item. DEFINITIONS
Expedited Service Expedited Service Has a shorter standard of promptness and fewer verification requirements to determine CDC eligibility than are normally required.
BAM 118 2 of 6 CDC EXPEDITED SERVICE BPB 2022-005 4-1-2022
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Homelessness A child is considered to be homeless based on the McKinney-Vento Homeless Assistance Act of 1987, as amended 2015. Examples of a child being homeless are: • Sharing housing due to economic hardship or loss of housing. • Living in motels, hotels, trailer parks, or camp grounds due to lack of alternative accommodations. • Living in emergency or transitional shelters. • Children whose primary nighttime residence is not ordinarily used as a regular sleeping accommodation (for example park benches, etc.) • Living in cars, parks, public spaces, abandoned buildings, substandard housing, bus, or train stations. Below are some questions that may be used to determine if a child is homeless: • How long have you been living with others? Is this a temporary situation? • Are you sharing housing due to loss of housing? Economic hardship? Other? • Is your name on the lease? Could you be asked to leave at any time? • Where would you live if you were not sharing housing? Eligibility based on the homeless category does not need to be verified. A valid need reason is required in accordance with this policy item. Foster Care A child is considered foster care eligible when the child has an active MDHHS foster care case and the foster care payments are permitted to be paid to a: • Licensed foster parent. • Relative placement when: There is a court order committing the child to MDHHS.
BAM 118 3 of 6 CDC EXPEDITED SERVICE BPB 2022-005 4-1-2022
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MDHHS placed the child with a non-parent relative. The relative receives MDHHS state ward board and care funding for the child’s placement. Eligibility for CDC for active MDHHS foster care cases ends on the date the child(ren) is removed from the paid licensed foster parent’s home or non-parent relative’s home. IDENTIFYING GROUPS ENTITLED TO EXPEDITED SERVICE Bridges screens all CDC applications to identify those requiring expedited service. Answers to the questions on the assistance application provide the information needed to identify expedited service cases. Homeless and Foster Care information is input on the CDC Expedited Screening page. The group does not have to request expedited service. A group cannot waive its right to expedited service. If the client is unable to complete the entire assistance application, an application or filing form containing the minimum information (see BAM 105) can be completed to start the standard of promptness. Answer questions related to expedited service processing on the back page of the filing form. The filing form is located in the MDHHS-1171 packet. STANDARD OF PROMPTNESS (SOP) For groups entitled to expedited service, CDC eligibility must be determined by the seventh calendar day following the date of application; see BAM 115, Standard of Promptness, CDC Only. EXCEPTIONS TO THE EXPEDITED STANDARD OF PROMPTNESS Extend the standard of promptness in the following situations: • A telephone interview is conducted, but the application is still incomplete. The standard of promptness begins on the day the signed, completed application is received by the local office.
BAM 118 4 of 6 CDC EXPEDITED SERVICE BPB 2022-005 4-1-2022
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Entitlement to expedited service is not identified during the screening process but is discovered by the specialist during normal processing. The application must then be processed according to expedited service standards. The standard of promptness begins on the date of discovery. The discovery date must be documented in the case record. INTERVIEWS CDC groups entitled to expedited service must participate in an interview. See BAM 115, Interviews, for specific interview policy. If the application is filed in person, the interview must be held the same day unless the client requests a postponement. If the client qualifies for an out-of-office or telephone interview, it must be attempted no later than the first working day following the application submission. Document all attempts to reach the client. If the CDC group applied by mail, fax, through MI Bridges, etc., and could not be contacted within one day to be interviewed, this fact must be documented in the case record. The interview must be conducted no later than one working day after contact is made. Provide any necessary help in completing the application during the interview. If a telephone interview is conducted, and the application is incomplete, complete it and mail a copy to the client for review and signature. MINIMUM VERIFICATION In all cases, the applicant’s identity must be verified; see BEM 221. Reasonable effort must be made to verify: • The Social Security number (SSN) of the CDC grantee. • The valid need reason for all P/SPs. • All other eligibility factors. Note: CDC benefits cannot be delayed beyond the expedited standard of promptness solely because these eligibility factors (other than identity) have not been verified. Certify approval for initial pay periods based on any verifications received and the client’s statement for those verifications that cannot be immediately acquired. Follow policy in BAM 130, Verification and Collateral Contacts, for verification due dates, extensions and department responsibilities when a client requests assistance with gathering verifications.
BAM 118 5 of 6 CDC EXPEDITED SERVICE BPB 2022-005 4-1-2022
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CDC FAULT DETERMINATION For pending CDC expedited service applications, determination of fault must be made on the seventh day, after the date of application. The CDC group is at fault when all required actions have been taken, but the CDC group has not taken one or more of the following actions: • Completed the application form. • Provided verification of identity. • Completed an interview. If the CDC group is at fault, answer “yes” to the “Extend SOP due to group at fault” question on the Program Request-Details screen. This prevents the registration from being overdue on worker regis- tration reports and extends the standard of promptness to 30 days following the date of application. BENEFIT PERIODS CDC expedited service approval results in a 45-day presumptive eligibility period. Benefits are approved during this timeframe based on client statement for any eligibility criteria that has not been verified (at eligibility determination). Once all verifications have been received, certify the eligibility based on CDC eligibility policy. The 12-month continuous eligibility period begins upon an approval certification. Note: If the eligibility determination for the 12-month continuous eligibility period results in a reduction in benefits from the presumptive eligibility, this is not considered a negative action. SUBSEQUENT BENEFITS If waived verifications/actions are not met by the end of the 45-day presumptive eligibility period, take the required actions in Bridges timely to close the ongoing CDC benefits. Benefits issued for these children prior to receiving all verifications shall not be considered an error or improper payment, even if verifications are not received or the group is determined ineligible once verifications are received.
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LIMITS ON EXPEDITED SERVICE There is no limit to the number of times a group can be approved under expedited procedures. However, prior to the next expedited approval, the CDC group must do one of the following: • Complete the verification requirements that were postponed at the last expedited approval (regardless of the amount of time that has expired). • Be processed under normal application processing standards. DENIAL OF EXPEDITED SERVICE Verbally notify the client of the denial if expedited service was regis- tered. Process applications denied for expedited service according to normal application processing standards described in BAM 115. When the client is denied expedited service but appears eligible for CDC benefits, Bridges will do both of the following: • Automatically change the application to a regular CDC application using the original application date once you’ve entered the client’s information on the expedited screening page in the Program Request logical unit of work. • Set the due date to 30 days from the original application date. Advise clients denied expedited service that they can request a supervisory conference and/or a hearing if they disagree with the decision; see BAM 600. Do not hold the application pending the result of a hearing. If the client requests a conference, it must be held within two working days of the request unless the client requests that it be scheduled later. LEGAL BASE The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186), Sec. 98.51. McKinney-Vento Homeless Assistance Act of 1987, amended 2015, 42 USC 11431 et seq.
BAM 119 1 of 2 USE OF FOOD ASSISTANCE BENEFITS IN RESTAURANTS BPB 2023-013 7-1-2023
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY Food Assistance Program (FAP) recipients may use their benefits to purchase prepared food in certain authorized restaurants. All group members must be either: • Elderly (60 years of age or over). • Disabled (receives disability or blindness payments or receives disability retirement benefits from a governmental agency because of a disability considered permanent). • Homeless. • A spouse of a FAP recipient who is eligible for the program. Food assistance benefits cannot be used at restaurants in border or in other States. Eligible Restaurants To be eligible to accept FAP as payment for prepared food, restaurants must meet all the following requirements: • Have sit-down seating available. Exception: Unless prohibited by a public heath order that would only allow delivery or takeout. • Be fully accessible to persons with disabilities. • Have a current food service license. • Sign an agreement with the Michigan Department of Health and Human Services (MDHHS) to among other things, offer low cost-meals. • Be authorized by the USDA to participate in the Food Assistance Program as a retailer. • Have a point-of-sale device for use by eligible recipients. Eligible recipients have a code on their Bridge card allowing for purchase of prepared food at authorized restaurants.
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If the household's circumstances change, such as no longer being homeless, the card is updated accordingly and FAP benefits can no longer be used at a restaurant. CENTRAL OFFICE RESPONSIBILITIES
Food Assistance Agreements Central office will process requests from restaurants wishing to accept FAP benefits and approve agreements with those which qualify. Refer restaurants inquiring about the program to: MDHHS- RestaurantMealProgram@michigan.gov. Information on the program and copies of the restaurant agreement are also available on the MDHHS website. LOCAL OFFICE RESPONSIBILITIES
Informing the Client At the group's request, the local office will provide the names and addresses of authorized restaurants that accept FAP as payment for prepared food in their establishments. RFT 262, lists restaurants authorized to accept FAP benefits. A list is also available on the MDHHS website. LEGAL BASE 7 CFR 278.1 Supplemental Nutrition Assistance Program, 42 USC 2011-2036
BAM 120 1 of 12 MSA/MDHHS COORDINATION BPB 2026-007 4-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY Medicaid The Michigan Department of Health and Human Services/Medical Services Administration (MSA) is responsible for the following medical programs in Michigan: • Medicaid. • Maternity Outpatient Medical Services (MOMS). • Breast and Cervical Cancer Prevention and Treatment Program (BCCPTP). The Michigan Department of Health and Human Services (MDHHS) administers Medicaid under the supervision of MSA. MSA adminis- ters the BCCPTP and MOMS programs. MSA has established a no-wrong-door policy for Medicaid to expand where a person may submit an application for medical assistance. MSA RESPONSIBILITY
Maternity Outpatient Services Information about Maternity Outpatient Services (MOMS) is in BEM 657. • Local office MDHHS staff do not determine eligibility for MOMS. • Local office MDHHS staff determine Medicaid ESO for pregnant women and enter the correct codes for pregnancy and citizenship, thereby allowing MOMS eligibility. • MOMS is not Medicaid. • MOMS is not on Bridges.
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Breast and Cervical Cancer Prevention and Treatment Program MSA determines eligibility for this MA category. Policy and proce- dures are in BEM 173. Policy Exceptions MSA is responsible for responding to requests for policy excep- tions for Medicaid. Complete instructions are in BEM 100. Send policy exceptions to:
Michigan Department of Health and Human Services
Behavioral and Physical Health and Aging Services Administration
Eligibility Policy Section
PO Box 30479
Lansing, MI 48909 Exceptions may also be sent to eligibilitypolicy@michigan.gov.. MDHHS LOCAL OFFICE RESPONSIBILITY MDHHS determines eligibility for: • Medicaid. Exception: MSA determines eligibility for BEM 173, Breast and Cervical Cancer Prevention and Treatment Program. • RAP Medical. HMO Member Becomes L/H Client MSA and MDHHS share responsibility when a beneficiary in an HMO enters a long-term care (LTC) facility. The provider contacts the Health Maintenance Organization (HMO) to request that the individual be disenrolled from the HMO. The HMO submits the request for disenrollment to MSA.
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The Quality Improvement Section, Medical Services Administration, reviews the request for disenrollment documentation and decides whether to approve the HMO’s request for disenrollment. Do not request a change to the MCO Program Enrollment Type (PET) code when a beneficiary enters LTC. The HMO is responsible for requesting the disenrollment. Exception: A beneficiary might be enrolled in managed care after admission to LTC. In such cases, contact MSA at 517-241-8759 to request removal of the managed care PET code. MSA is responsible for: • Ending the managed care PET code on Bridges. • Adding the LTC PET code and the Provider ID on Bridges. The authorization begin date for the LTC PET code is the day after the MCO PET code end date. • Forwarding a copy of the DCH-1185, Request to Disenroll from Health Plan to Nursing Facility, to the local MDHHS. Note: All DCH-1185s for recipients in Wayne County will be forwarded to the medical district. That office is responsible for obtaining the case record from the appropriate district office. If notified that a beneficiary in managed care has entered LTC before there is notice of the HMO disenrollment, you may begin actions necessary to determine continued eligibility (request verifications). However, not all case actions can be completed until the DCH-1185 is received from MSA. MDHHS is responsible for: • Determining continuing eligibility. Computing the post-eligibility patient-pay amount. • Entering the post-eligibility patient-pay amounts after MSA has entered the LTC PET code in Bridges. Use standard negative action procedures to begin the patient-pay amount; see BEM 547.
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MI Health Link Member Becomes L/H Client Beneficiaries enrolled in MI Health Link, a program for individuals dually enrolled in Medicare and Medicaid, are eligible to remain enrolled in MI Health Link when they enter a long term care (LTC) facility. Individuals in MI Health Link are enrolled in a health plan known as an Integrated Care Organization (ICO), which provides all Medicare and Medicaid services, including long term care services to individuals. Since MI Health Link allows beneficiaries to remain enrolled in an ICO, the LTC facility does not contact the ICO to request that the individual be disenrolled from the ICO. Additionally, the ICO will not submit a request for disenrollment to MDHHS/MSA. Instead the LTC facility will inform the ICO when a member is admitted so that the facility and ICO can coordinate the individual's care. MDHHS is able to identify if an individual is enrolled in an ICO by checking the provider ID associated with the PET code. MI Health Link uses eight PET codes. • ICO-HCBS: Individual meets nursing facility level of care determination (LOCD) and lives in the community. Lives in the home and receives community based waiver services. • ICO-NFAC: Resident of nursing facility. • ICO-COMM, ICO-HOSH, ICO-HOSR, ICO-HOSN, ICO-HOSW : Enrolled in Medicaid managed care. • ICO-CMCF: Resident of a county medical care facility (CMCF). Each PET code will accompany a provider ID number. Each ICO has two provider IDs. One number identifies if the individual voluntarily enrolled in the ICO, and one number those individuals automatically enrolled in the ICO. The first number listed indicates voluntarily enrolled, the second indicates automatic or passively enrolled.
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Integrated Care Organizations (ICO)/Provider ID Aetna Better Health of MI 2836392 2836393 Fidelis SecureCare of MI 2836406 2836407 HAP Midwest Health Plan 2836404 2836405 Meridian Health Plan 2836394 2836396 Molina HealthCare 2836399 2836400 UP Health Plan 2836390 2836403 When a beneficiary enters LTC, the provider will enter the information into CHAMPS in order to change the PET code. MDHHS LOCAL OFFICE RESPONSIBILITY • Computing the patient-pay amount (PPA). When a nursing facility notifies MDHHS that a beneficiary has been discharged from the LTC facility, complete the following steps: • Update PPA. When a nursing facility notifies MDHHS that a beneficiary has changed facilities complete the following step:
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• Confirm that the PPA is still accurate. Newborns MSA AUTHORIZATIONS in BEM 145, Newborn explains when the Medical Services Administration will authorize MA for a newborn. LOCAL HEALTH DEPARTMENTS AND MDHHS Local health departments may participate in outreach and application assistance. Application assistance means helping clients apply for and obtain verifications for Medicaid. Each local health department chooses whether or not it will participate. Local Health Department Responsibilities For applications submitted through the participating local health department, the local health department is responsible for: • Ensuring that the application is signed and that all items are completed. Items that do not apply are to be marked N/A. • Obtaining all information needed to make an eligibility determination and supplying copies of all necessary documentation and verification. • Doing a preliminary income budget to determine if the application should be submitted for a Medicaid determination. • Attaching documentation of the client’s noncooperation with obtaining verifications to the application. Missing Verification An application received from a participating local health department should have all the information and verification necessary to determine Medicaid eligibility. If all of the necessary information/verification does not accompany the application: • Contact the local health department and request that the local health department obtain the missing information or
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verification. Use the DHS-3503, Verification Checklist, or other mutually agreeable written means, to notify the local health department of the missing information or verification. Do not delay a determination of eligibility because an application does not specify a family’s choice of a health or dental plan. • Allow the local health department at least 10 days to provide the information or verification. • Contact the local health department if the requested information is not received by the due date. Extend the time limit if there has been a delay in getting the information or verification (BAM 130). Do not deny the application as long as the local health department is working to obtain the information or verification. • If the local health department says that verification cannot be obtained despite a reasonable effort, use the best available information. See Obtaining Verification in BAM 130 for details and exceptions. • If the local health department indicates that the client has not cooperated in efforts to obtain verification, review the local health department’s documentation relating to the refusal (copies of correspondence, record of telephone contacts). Determine if the client has refused to cooperate. Deny the application, if appropriate. If denial is not appropriate (client was not informed of what was needed or client was not given sufficient time), ask the local health department to request the verification again. MDHHS Application Processing When an application is submitted through a participating local health department: • Register the application if it contains at least the applicant’s name, the applicant’s birth date, the applicant’s address, and the applicant’s/authorized representative’s signature; see BAM 105, Right to Apply. The application date is the date the application is received at MDHHS with the minimum information.
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• Determine eligibility for Medicaid. • Notify the client of the eligibility decision. Informing Local Health Departments and Confidentiality Confidentiality is not violated when information is provided to local health departments regarding applications and eligibility or ineligibility. Provide the following information if participating local health departments want to know the disposition of an application: • Whether a person has been approved for Medicaid. • Whether coverage is limited to emergency services. • If denied, the reason for each person’s denial. • Each beneficiary's ID number. • The begin date of MA coverage, including retro MA coverage. Changes and Renewals MDHHS is responsible for: • Reviewing continued eligibility when changes are reported, including obtaining any necessary verification. Exception: Medicaid Under 19 and MIChild eligibility continues until renewal unless the child reaches age19, moves out of state, becomes ineligible due to Institutional Status, dies, or (MIChild only) is enrolled in other comprehensive health insurance. • Processing renewals. Referrals to MSA Reimbursement Unit Notify MSA of the potential need for reimbursement of paid medical expenses during a Retroactive Period/Corrective Action period for which the client recevied the DHS-333 or DHS-334 Reimbursement Notice; see BAM 600. Send reimbursement information to: Michigan Department of Health and Human Services Medical Services Administration
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Eligibility Quality Assurance Section/Reimbursement Attn: Venetta Tucker 400 S. Pine St., 5th floor Lansing, MI 48913 MSA ESTATE RECOVERY UNIT Recoveries for Medicaid claims correctly paid are as follows: • For individuals who received medical assistance at age 55 or older, recovery is made from the individual’s estate for all services covered by the Michigan Medicaid program with dates of service on or after July 1, 2010, except Medicaid cost sharing. To be subject to estate recovery, a person over 55 must have begun receiving long-term care services after September 30, 2007. If a beneficiary over the age of 55 began receiving long-term care services prior to September 30, 2007 and there was a break in coverage and a new eligibility period began any time after September 30, 2007, the Medicaid recipient will be deemed to have begun receiving long-term care after September 30, 2007 and therefore be subject to recovery. • Recovery will only be pursued if it is cost-effective to do so as determined by the department at its sole discretion. Limitations on Recoveries The state complies with the requirements of section 1917(b)(2) of the Social Security Act: Recovery of medical assistance will be made only after the death of the individual’s surviving spouse, and only when the individual has no surviving child who is either under age 21, blind, or disabled. The department is responsible for approving and denying all undue hardship waivers and statutory exemptions. The department will establish and use internal policies regarding what documentation is required to establish that an undue hardship waiver or statutory exemption may exist. Undue Hardship Recovery may be waived if a person inheriting property from the estate can prove that recovery would result in an undue hardship. An application for an undue hardship must be requested by the applicant and returned with proper documentation in order for a
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hardship waiver to be considered. In order to qualify for a hardship exemption, an applicant must file the application with the depart- ment not later than 60 days from the date the department sends the Notice of Intent to the personal representative or estate contact. An undue hardship exemption is granted to the applicant only and not the estate generally. Undue hardship waivers are temporary. Submitted applications will be reviewed by the department or its designee, and the department shall make a written determination on such application. An undue hardship may exist when one or more of the following are true: • The estate subject to recovery is the sole-income producing asset of the survivors (where such income is limited), such as a family farm or business. • The estate subject to recovery is a home of modest value, see definition in this item. When considering whether to grant an undue hardship, the depart- ment shall apply a means test to all applicants to ensure that waiv- ers are not granted in a way that is contrary to the intent of the estate recovery program under federal law. An applicant for an undue hardship waiver will satisfy the means test only if both of the following are true: • Total household income of the applicant is less than 200 percent of the poverty level. • Total household resources of the applicant do not exceed $10,000. Appeals The Hardship Waiver applicant has the right to contest the depart- ment decision of whether an undue hardship exists. The applicant may request a hearing within 60 days of the notice of case action on the application. The request for a hearing must be in writing and will be conducted under the provisions of BAM 600, Hearings.
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Definitions: • Survivor: An heir who does not predecease the deceased beneficiary under the provisions of MCL 700.2104 or according to the terms of the decedent’s will. • Home of Modest Value: A home that is valued at 50 percent or less of the average price of homes in the county where the home is located as of the date of the Medicaid beneficiary’s death. • Value of Medicaid recipient’s home: The State Equalized Value (SEV) of a Medicaid recipient’s home from the year the Medicaid recipient died is used to determine whether that home is a home of modest value. The SEV will be double to find the value of the home. • Average Price: The average price of homes in the county shall be determined from the Equalized Valuation Totals Summary report (L-4023) published by the State Tax Commission. The average price shall be calculated by dividing the total True Cash Value of Residential Real Property in the county by the total Number of Parcels. • Resources: All income, as defined in BEM 500 series, and assets, as defined in BEM 400 an applicant has. • Long-Term Care Services: Means services, including but not limited to, nursing facility services, hospice, home and community based services, adult home help, and home health. Divestments When a divestment is discovered, it will be determined if the state was aware of the transfer and whether the transfer was or would have been allowed. If necessary MSA will refer the case to the Office of the Attorney General to have the property put back in the estate. MSA will not pursue a divestment when any of the following are true: • The transfer of assets was disclosed as part of the Medicaid eligibility determination process and notwithstanding such transfer, the applicant was determined to be Medicaid eligible.
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• The transfer of assets was not disclosed as part of the Medicaid eligibility determination process, but the department determines that if it had been disclosed the applicant would still have been determined to be Medicaid eligible. • The transfer was disclosed as part of the Medicaid eligibly determination process, and a divestment penalty was assessed, which at the time of the decedent’s death was exhausted. MSA will refer a divestment to the Michigan Department of Health and Human Services Office of Inspector General, or MSA will seek additional recovery from the estate when either of the following are true: • The transfer of assets was disclosed as part of the Medicaid eligibility determination process, a divestment penalty period was assessed and the assessed penalty period had not been exhausted at the time of the beneficiary’s death. MSA will only seek the value of the outstanding penalty period that was assessed under these circumstances. • The transfer of assets was not disclosed as part of the Medicaid eligibility determination process, and the department determines that if it had been disclosed the applicant would not have been determined to be Medicaid eligible.
Cost-Sharing Limits The limit is based on income and applies to most types of health care coverage cost-sharing including HMP. Beneficiaries in the same household cannot be charged more than 5 percent of the family's income each calendar quarter for cost- sharing. Updates to the cost-sharing limit occur prospectively as income and other changes are received. MDHHS monitors the cost-sharing limit and costs as they are incurred and processes changes each quarter. Beneficiaries are not required to keep track of these costs.
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DEPARTMENT POLICY All Programs According to federal and state law, the Michigan Department of Health and Human Services (MDHHS) is a designated voter registration agency. Laws require that MDHHS provide voter registration services to MDHHS clients in specific situations. These services include: • Providing form NSP-938-B, Michigan Voter Registration Application, at specified times and upon request. • Providing form ED-121a, Michigan Voter Preregistration Application and Change Address Form upon request. • Assisting clients in completing the NSP-938-B. • Assisting client in completing the ED-121a • Accepting and validating the NSP-938-B. • Accepting and validating the ED-121a. • Forwarding the NSP-938-B to the appropriate governmental clerk in a timely manner. • Forwarding the ED-121a to the appropriate governmental clerk in a timely manner. IN PERSON TRANSACTIONS Individuals are required to present photo identification when registering to vote in person. If an individual does not possess photo identification, he/she is permitted to sign an affidavit form to this effect. Acceptable photo identification documents include: • Michigan driver’s license or Michigan personal identification card (current or expired). • Current driver’s license or personal identification card issued by another state. • Current federal or state government-issued photo identification.
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• Current U.S. passport. • Current student identification with photo – from a high school or an accredited institution of higher education. • Current military identification card with photo. • Current tribal identification card with photo. Voter registration applicants that do not possess one of the above- listed photo ID documents may sign the DHS-1185, Affidavit of Voter not in Possession of Picture Identification Form. The DHS-1185 should be stapled to the voter registration form (NSP-938-B and/or ED-121a) and sent to the governmental clerk.
OBTAINING FORMS • The NSP-938-B may be obtained from the: • Department of Technology, Management and Budget (DTMB) warehouse. • Online at the website: Doing Business With MDHHS/Forms & Applications. Select the NSP-938-B from the Applications category. • The ED-121a may be obtained online: ED-121: Michigan Voter Registration Application and Change of Address Form. The Bureau of Elections prohibits MDHHS from making the NSP- 938-B and/or the ED-121a form available on MS Word. Photo copies may be used if supplies run short. Individual copies may also be printed from the MDHHS public website. The MDHHS-1185 is available in the MDHHS Forms Library. ISSUING VOTER REGISTRATION FORMS Distribute an NSP-938-B: • With an application for assistance, including, but not limited to: • MDHHS-1171, Assistance Application.
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• DHS-4575, Medicaid Application (Patient of Nursing Facility). • DHS-4574-B, Assets Declaration. • DHS-1011, Medicaid Supplemental Application. • With a redetermination, including, but not limited to: • MDHHS-1010, Redetermination Form. • DHS-542, MiCAP Redetermination Form. • Upon request. • When a change of physical address is reported to the local office. Exception: The only time an NSP-938-B is not distributed is when an individual declines in writing by checking the No box on page seven of the MDHHS-1171, Assistance Application, or declines in writing on another MDHHS form that asks whether the individual would like to register to vote. If this question is unanswered (left blank), distribute an NSP-938-B. Note: An NSP-938-B is automatically generated and mailed when Yes-out of office transaction is selected, and when an individual reports a change of physical address. • When an individual applies for assistance, redetermination or reports a change of physical address in the local office, distrib- ute an NSP-938-B in person. If for any reason, an NSP-938-B is not distributed while the individual is in the local office, and the individual has not declined to register to vote, select Yes-out of office transaction, so an NSP- 938-B is automatically mailed. For forms that do not include the voter registration question, mail an NSP-938-B to the individual. Note: Individuals using MI Bridges to apply for or renew benefits are automatically offered an NSP-938-B and the response is pre filled in Bridges. Note: The ED-121a only needs to be distributed upon request.
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ASSISTING INDIVIDUALS Assist individuals in the completion of the NSP-938-B and/or ED- 121a when requested. Do not: • Seek to influence an individual’s political preference or party. • Display any political preference or party allegiance. • Make any statement or take any action to discourage a person from registering to vote. • Make any statement or take any action which may lead a person to believe that a decision to register to vote or not to register to vote has any bearing on their eligibility for services or benefits. PROCEUDURE
Complete Form Returned When a complete NSP 938-B and/ or ED-121a is received complete the following steps: • Accept the completed form. • Review the form to ensure that it is complete and legible. • When the yes box is checked, the upper-most portion of the form serves as the individual’s voter registration receipt. • Detach and give or mail the receipt to the individual once the form is validated. • Forward the lower portion of the completed NSP-938-B to the local office voter registration services coordinator immediately upon receipt, to ensure that forms will be sent to the appropriate governmental clerk in a timely manner; see Timely Forwarding Voter Registration Forms in this item. • Forward the top of portion of the completed ED-121a to the local office voter voter registration services coordinator immediately upon receipt, to ensure that forms will be sent to the appropriate governmental clerk in a timely manner
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Incomplete NSP- 938-B If an individual returns an NSP-938-B with the Yes box checked but it is missing a signature or information forward to the local office voter registration services coordinator immediately. Note: Bureau of Elections has a process in place to follow up with a client for missing information. If an individual returns an NSP-938-B with the No box checked, completion of the remainder of the form is not necessary. Enter the current date and your initials in the upper right corner of the form, and forward to the local office voter registration services coordinator for storage; see Storing Declinations below. Incomplete ED- 121a If an individual returns an incomplete ED-121a forward to the local office voter registration services coordinator immediately.
VOTER REGISTRATION SERVICES COORDINATOR RESPONSIBILITIES Each local office must designate a voter registration services coordinator as well as a back-up coordinator. Coordinator responsibilities include all of the following: • Answering local office questions regarding voter registration services. • Ensuring that there is an adequate supply of voter registration applications in both English and Spanish. • Ensuring that there are voter registration applications available in the local/district office lobby. • If it is determined or a report is received that an individual was not given the appropriate opportunity to register to vote, ensure
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that an NSP-938-B, along with an explanatory letter, is mailed to the individual. A template for the explanatory letter can be obtained by contacting the central office voter registration coordinator, see Communicating with Central Office Voter Registration Services Coordinator in this item. Note: A copy of the letter sent to the individual must be retained in the local office for 24 months. • Prominently displaying National Voter Registration Act (NVRA) posters in each local/district office lobby and ensuring that posters are available for community partners, as requested. • Reporting voter registration information; see Reporting and Tracking in this item. • Forwarding complete and incomplete voter registration forms to the governmental clerk of the county, city or township in a timely manner; see Timely Forwarding of Voter Registration Forms in this item. • Communicating with the central office voter registration services coordinator; see Communicating With Central Office Voter Registration Services Coordinator in this item. Timely Forwarding of Voter Registration Forms Voter registration services coordinators must forward voter registra- tion forms within seven calendar days of receipt in the local office. Forms must be forwarded to the governmental clerk of the county, city or township where the client resides. Exception: During the 7 day period which precedes the registration deadline forms must be forwarded to the governmental clerk of the county, city or township within one business day. This is required to allow a person who registers close to the close of registration to participate in the election. Where to Send Voter Registration Forms Forward the complete NSP-938-B and/ or Ed-121a to the governmental clerk of the county, city or township where the client
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resides. The governmental clerk information can be found at the website: Michigan.gov/Vote. If it is unclear where to send the form, forward to: Department of State Bureau of Elections P.O. Box 20126 Lansing, Michigan, 48901-0726 Storing Declinations An NSP-938-B with the No box checked is known as a declination. This individual has declined the opportunity to register or update their voter’s registration. Declinations must be retained in a desig- nated location in the local office for 24 months. Communicating with Central Office Voter Registration Services Coordinator Local office voter registration services coordinators communicate with the central office voter registration services coordinator via email at: MDHHSVotes@michigan.gov. Questions regarding this policy may be addressed through this ave- nue. Local office voter registration services coordinators must contact the central office voter registration services coordinator for the following: • Gain access to the NVRA summary reporting tool through the MDHHS MiLogin - Home Page (michigan.gov). • Request the template for the explanatory letter. • Provide the name, phone number and email address of the local office voter registration services coordinator and back-up coordinator and the county and/or district they represent. • When there is a change in the local office voter registration services coordinator or back-up coordinator, the following information must be submitted:
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Name. Phone and fax numbers. County office. District office, if applicable. REPORTING AND TRACKING Each local office voter registration services coordinator must com- plete the NVRA Activity Reporting System available on the MDHHS MiLogin - Home Page (michigan.gov) The summary report is due by the fifth of each month (or next business day if the fifth falls on a non-work day). Instructions and access to this tool are available from the central office coordinator. The summary report requires coordinators to report the number of completed voter registration forms received by the local/district office. Keep track of the number of completed registration forms for- warded to the governmental clerks each week and enter the monthly total on the report. LEGAL BASE All Programs 42 U.S.C. 1973gg through 1973gg-10 MCL 168.509v
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DEPARTMENT POLICY All Programs Verification means documentation or other evidence to establish the accuracy of the client's verbal or written statements. Obtain verification when: • Required by policy. Bridges Eligibility Manual (BEM) items specify which factors and under what circumstances verification is required. • Required as a local office option. The requirement must be applied the same for every client. Local requirements may not be imposed for Medicaid Assistance (MA). • Information regarding an eligibility factor is unclear, inconsistent, incomplete or contradictory. The questionable information might be from the client or a third party. Verification is usually required at application/redetermination and for a reported change affecting eligibility or benefit level. If the individual indicates the existence of a disability that impairs their ability to gather verifications and information necessary to establish eligibility for benefits, offer to assist the individual in the gathering of such information. Verification is not required: • When the client is clearly ineligible, or • For excluded income and assets unless needed to establish the exclusion. FAP Only FAP groups must verify all countable income before an application or redetermination can be denied for exceeding the income limit. Types of Verification All Programs Use documents, collateral contacts or home calls to verify informa- tion.
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A document is a written form of verification. It may include a photocopy, facsimile or email copy if the source is identifiable. Permanent documents must be obtained only once, unless they are found to be missing from the case record. Examples: birth certifi- cate, passports, divorce papers, death notice. Copies of these documents should remain in the case record. Nonpermanent documents must be current. Examples: driver's license, pay stub, rent receipt, utility bill, DHS-49-F, Medical-Social Questionnaire. Family Independence Program (FIP), State Disability Assistance (SDA), and Medicaid (MA) Documents used to verify citizenship and identity may be originals or copies of the original document. Facsimiles or emails are not acceptable documents for citizenship or identity. Medicaid Verification of identity is not required. MAGI MEDICAID MDHHS must use information currently available in STATE OF MICHIGAN systems to renew eligibility. Do not request information from the beneficiary if the information is already available to MDHHS. This includes completing a renewal form. Current means the following: • Income documents must correspond to the period used to determine eligibility or benefit amount; see BEM 500, Income Overview, 501, Income From Employment, 502, Income From Self-Employment, 503, Income, Unearned, and 504, Income From Rental/Room And Board. • Medical documents must correspond to the period set by the Disability Determination Service (DDS) or to the date(s) stated on the document if DDS approval is not required. • Other nonpermanent documents are generally considered current if dated within 60 days before your eligibility determination. Older documents may be used if available information indicates the document remains current and there have been no changes in circumstances.
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A collateral contact is a direct contact with a person, organization or agency to verify information from the client. It might be necessary when documentation is not available or when available evidence needs clarification. The client must name suitable collateral contacts when requested. Assist the client to designate them. The local office is responsible for obtaining the verification. If the contact requires the client's signed release, use the DHS-27, Release of Information, (DHS-20, Verification of Resources, for inquiries to financial institutions), and specify on it what information is requested. If the information requested could include health information send a DHS-1555 or a DCH-1183, Authorization to Release Protected Health Information, for the individual’s signature. When talking with collateral contacts, disclose only the information necessary to obtain the needed information. Do not disclose spe- cific programs for which the household has applied. Do not release any information supplied by the household or imply that the house- hold is suspected of any wrongdoing. Home calls are not required but may be used to verify factors; see Interviews section in Bridges Administrative Manual (BAM) 115, Application Processing. Obtaining Verification All Programs Tell the client what verification is required, how to obtain it, and the due date; see Timeliness of Verifications in this item. Use the DHS-3503, Verification Checklist (VCL), to request verification. Exception: For Food Assistance Program (FAP) only, if there is a system-generated due date on the verification form such as a MDHHS-3688, Shelter Verification, a verification checklist is not required to be sent with the verification form. Use the DHS-3503C, Verification Checklist for Citizenship/Identity, to request documentation of citizenship or identity for FIP, SDA or MA determinations. The client must obtain required verification, but the local office must assist if they need and request help.
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If neither the client nor the local office can obtain verification despite a reasonable effort, use the best available information. If no evidence is available, use your best judgment. Exception: Non-citizen information, blindness, disability, incapacity, incapability to declare one's residence and, for FIP only, relationship and pregnancy, must be verified. Citizenship and identity must be verified for clients claiming U.S. cit- izenship for applicants and recipients of FIP and SDA. Note: • When verification is scanned or copied and the information is legible, place a copy in the case file. • If the verification is totally or partially illegible, place a copy in the case file. • If partially legible, document the case with actual verification received such as a lease, paystubs. Include additional details such as whether it was reviewed, if it appears to be authentic, and any visible information such as the date of entry into the U.S., shelter expense. Self-Attestation MAGI-related Medicaid Self-attestation is acceptable for most eligibility factors. Citizenship, social security numbers and lawful presence require documentation. Sources available to the STATE OF MICHIGAN, for example, SSA, SAVE, MDHHS vital records, H79, Redetermination & Renewal Verifications (RRV) Service, must be utilized first before requesting documentation from the individual. When electronic verification is not successful, documentation may not be requested of an individual for whom documentation does not exist or is not reasonably available at the time of an application or renewal. Such circumstances include, but are not limited to, individuals who are homeless and victims of domestic violence or natural disasters.
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Citizenship Verification for Medicaid When an applicant for Medicaid claims to be a U.S. citizen or to have qualified immigrant status, and all other eligibility factors are met, certify benefits. Once the case has been open and coverage entered in Bridges, verification of citizenship must be completed. Attempt to verify citizenship through a data match such as the Social Security Administration or a MDHHS vital records match. MAGI- related applicants will have citizenship and identity verified if the application comes to Michigan Department of Health & Human Services (MDHHS) via the Federally Facilitated Marketplace (FFM) or MAGI rules engine. If there is a discrepancy with the information or it is not available then contact with the beneficiary is necessary; see BEM 221, Identity and 225, Citizenship/Non-Citizen Status. Allow the beneficiary 90 days to provide the required verifications. If no documentation is provided at the end of the 90 days, the benefi- ciary should be disenrolled from Medicaid within 30 days. Beneficiaries must be notified of the pending closure and the reason for the closure. If documentation is received prior to the closure date the coverage must continue. Medicaid The Michigan Department of Health and Human Services (MDHHS) program eligibility policy section will evaluate beneficiaries who are unable to provide documentation of citizenship on a case by case basis. MDHHS will attempt to verify citizenship after all other possibilities have been exhausted by MDHHS and the beneficiary. These attempts include but are not limited to data matches, state to state written and/or verbal inquiries, interviews with friends and relatives and the use of computerized records. If you are unable to verify citizenship for a beneficiary send a written request to: Michigan Department of Health and Human Services Bureau of Medicaid Policy and Health System Innovation Eligibility Policy Section P.O. Box 30479
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Lansing, MI 48909 The policy email address is Eligibilitypolicy@michigan.gov All requests must include: • Beneficiary’s name. • Case number and beneficiary ID number. • Specialist name, telephone number and email address. • A brief description of the situation, specify if assistance is needed in determining citizenship or qualified immigration status. • What steps the beneficiary has taken in an attempt to provide the verification. • What steps the specialist has taken in an attempt to verify citizenship or immigration status. • Include the results of the Social Security Administration match and MDHHS vital records match. Obtaining Verifications Never place original documents such as a lease, paystubs, birth certificates in the case file. Verification Sources All Programs Verification Sources of each BEM item lists acceptable verifica- tions for specific eligibility factors. Other, less common sources may be used if accurate and reliable. Use a particular source if it is the most reliable (public records, data matches). Otherwise, use the one easiest to obtain. FIP, SDA and Medicaid Refer to BEM 225 for a list of acceptable documents to use to verify citizenship.
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Sources must be used in the order listed from most reliable to least reliable, not the easiest to obtain. Timeliness of Verifications FIP, SDA, RCA, Child Development and Care (CDC), FAP Allow the client 10 calendar days (or other time limit specified in policy) to provide the verification that is requested. Exception: For CDC, if the client cannot provide the verification despite a reasonable effort, extend the time limit at least once. Exception: For CDC, at redetermination, if a signed redetermination form is received prior to the end of the redetermination month, and verifications are missing or incomplete, send a VCL. Verifications are due by the end of the redetermination month, or within 10 days after they are requested, which ever allows more time. Verifications are considered to be timely if received by the date they are due. For electronically transmitted verifications (fax, email or Mi Bridges document upload), the date of the transmission is the receipt date. Verifications that are submitted after the close of regu- lar business hours through the drop box or by delivery of a MDHHS representative are considered to be received the next business day. Send a negative action notice when: • The client indicates refusal to provide a verification, or • The time period given has elapsed and the client has not made a reasonable effort to provide it. Note: For FIP, SDA and RCA, if the client contacts the department prior to the due date requesting an extension or assistance in obtaining verifications, the specialist may grant an extension to the VCL due date. Note: For FAP only, if the client contacts the department prior to the due date requesting an extension or assistance in obtaining verifications, assist the client with the verifications but do not grant an extension. Explain to the client they will not be given an extension and their case will be denied once the VCL due date is passed. Also, explain their eligibility will be determined based on their compliance date if they return required verifications. Re-
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register the application if the client complies within 60 days of the application date; see Subsequent Processing in BAM 115. Only adequate notice is required for an application denial. Timely notice is required to reduce or terminate benefits. Exception: At redetermination, FAP clients have until the last day of the redetermination month or 10 days, whichever is later, to provide verification; see BAM 210, Redetermination/Ex Parte Review. Medicaid Allow the client 10 calendar days (or other time limit specified in policy) to provide the verification requested. Refer to policy in this item for citizenship verifications. If the client cannot provide the veri- fication despite a reasonable effort, extend the time limit up to two times. At renewal if an individual is required to return a pre-populated renewal form, allow 30 calendar days for the form to be returned. At application, renewal, ex parte review, or other change, explain to the client/authorized representative the availability of your assistance in obtaining needed information. Extension may be granted when the following exists: • The customer/authorized representative need to make the request. An extension should not automatically be given. • The need for the extension and the reasonable efforts taken to obtain the verifications are documented. • Every effort by the department was made to assist the client in obtaining verifications. Verifications are considered to be timely if received by the date they are due. For electronically transmitted verifications (fax, email or MI Bridges document upload), the date of the transmission is the receipt date. Verifications that are submitted after the close of regular business hours through the drop box or by delivery of a MDHHS representative are considered to be received the next business day. Send a case action notice when:
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• The client indicates refusal to provide a verification, or • The time period given has elapsed. Only adequate notice is required for an application denial. Timely notice is required to reduce or terminate benefits. Discrepancies All Programs Before determining eligibility, give the client a reasonable opportu- nity to resolve any discrepancy between his statements and infor- mation from another source. LEGAL BASE FIP 45 CFR 206.10(a)(2)(ii) 45 CFR 233.10(a)(1)(ii)(B) MCL 400.37
CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
SDA Annual Appropriations Act Mich Admin Code, R 400.3151 – 400.3180
MA 42 CFR 435.913(a) 42 CFR 435.916 (a), (b) MCL 400.37 Pub. L. 109-171
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Children’s Health Insurance Program Reauthorization Act of 2009 (CHIPRA), Public Law 111-3. The Patient Protection and Affordable Care Act (Pub. L. 111-148) and the Health Care and Education Reconciliation Act (Pub. L. 111- 152). FAP 7 CFR 273.2(f)
BAM 200 1 of 7 FOOD ASSISTANCE SIMPLIFIED REPORTING BPB 2026-006 3-1-2026
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DEPARTMENT POLICY Most food assistance groups are assigned to the simplified reporting (SR) category. This reporting option increases Food Assistance Program (FAP) participation and provides workload relief. REQUIREMENTS SR groups are required to report to the department by the 10th day of the following month, or the next business day if the 10th day falls on a weekend or holiday, only when: • The group’s actual gross monthly income (not converted) exceeds the SR income limit for their group size. • The group receives a single lottery or gambling winning of $4,500 or more. • A mandatory TLFA participant is working less than 20 hours per week (80 hours per month). No other change reporting is required. If the group has an increase in income, the group must determine their total gross income at the end of that month. If the total gross income exceeds the group’s SR income limit; see Reference Tables Manual (RFT) 250, the group must report this change to the department by the 10th day of the following month, or the next business day if the 10th day falls on a weekend or holiday. Once assigned to SR, the group remains in SR throughout the current benefit period unless they report changes at their semi- annual contact or redetermination that make them become a change reporter. Note 1: FAP groups where all mandatory TLFA individuals are working 20 hours or more per week are SR. When a drop in work hours below 20 hours per week (80 hours per month) is reported, the group will remain SR until the next semi-annual contact or redetermination (whichever comes first). Note 2: Verified information must be acted on even though the group may not be required to report the information. Additionally, information from a prisoner or death match must be processed per
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Bridges Administrative Manual (BAM) 804, Incarceration Matches, and BAM 808, Deceased Recipient Match. SR does not change reporting requirements for any other program. GROUPS NOT ELIGIBLE FOR SR The following groups are not eligible for SR: • Migrants/seasonal farmworkers. • Groups with a 24-month benefit period. • MiCAP. • Groups with a mandatory TLFA participant working less than 20 hours per week (80 hours a month). These groups continue to report changes using the standard Food Assistance reporting criteria; see BAM 105, Rights and Responsibilities, Bridges Eligibility Manual (BEM) 610, Migrants/Seasonal Farmworkers, and BEM 618, Michigan Combined Application Project. DETERMINING THE INCOME LIMIT To determine the group’s SR income limit; see the Simplified Reporting Income Limit, column E, in RFT 250. Disqualified members are not included in the group size when determining the income limit. However, their budgetable income is included in the group’s total gross income (either full or prorated based on the reason for the disqualification) when comparing to the income limit; see BEM 550, FAP Income Budgeting. NOTIFICATION Bridges sends information about simplified reporting including the DHS-1045, Simplified Six Month Review, to groups assigned to the SR category at the following times: • Application. • Redetermination. • When assigned to the SR category as an ongoing case. Bridges sends the simplified reporting information which explains the reporting requirement and provides the gross monthly income reporting requirements for the group based on their circumstances
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at the time of issuance. The DHS-1605, Notice of Case Action, sent at application and redetermination includes the specific income limit for the group based on the group size. This information should be emphasized during the interview with the group to ensure their understanding of the SR requirements. ASSIGNING BENEFIT PERIODS
Applications and Redeterminations Groups meeting the SR category at application and redetermination are assigned a 12-month benefit period and are required to have a semi-annual contact. For applications and redeterminations, SR begins the first month of eligibility. Example 1: On March 19th, a group with earned income applies for FAP. The specialist processes the case on April 2. Benefits are approved beginning March 19. Bridges assigns a 12-month benefit period of March 19 through February 28. The MDHHS-1046, Semi- Annual Contact Report, is sent out the beginning of the fifth month (July) of the benefit period. It is due back from the group on the first day of the sixth month (August). Complete the budget to affect no later than the seventh month’s benefits (September). At redetermination, the group’s reporting requirements are re- evaluated based on their current circumstances. The specialist completes a redetermination in February. The new 12-month benefit period is March 1 through February 28; see BAM 210, Redetermination/Ex Parte Review. Example 2: On September 8th, the specialist processes a September redetermination which currently has a 24-month benefit period. At this time, it is discovered the group is receiving a pension and is no longer eligible for a 24-month benefit period. The group is now SR and required to have a 12-month benefit period. They will receive an MDHHS-1046 at the beginning of February (fifth month). Changes for 24- month Benefit Periods Bridges shortens the 24-month benefit period for ongoing groups who have more than 12 months left in their benefit period and either:
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• Report having earned income. • Report unearned income (other than RSDI and/or SSI). • Report an individual joining the group who is not SDV. Whenever any of the above occur, Bridges does the following: • Sets the end date to 12 full months from the processing date. • Issues a DHS-1605 explaining simplified reporting, household income limit, and the new shortened benefit period end date. • Issues a DHS-1045, Simplified Six-Month Review. For groups whose 24-month benefit period has 12 months or less remaining at the time the change is first reported, Bridges assigns the group to the SR category but does not shorten the benefit period. The current end date must be retained even though the end date is 12 months or less. If the group remains SR eligible at redetermination, Bridges assigns a new 12-month benefit period. Example: On August 7, 2022, Risa reports that their husband returned to the group and receives unemployment income. They are change reporters and have a 24-month benefit period with an end date of May 31, 2023. On August 17, 2022, the specialist processes the change, and the group becomes SR. Bridges issues a DHS-1605 which provides the simplified reporting requirements, and a DHS-1045. The end date remains May 31, 2023, since the group has less than 12 months remaining in their benefit period. Changes for 12- month Benefit Periods Once assigned to the SR category, groups retain their 12-month benefit period regardless of changes, until the next benefit period is established. If the group reports a change which would make the group a change reporter, they will remain a SR until the next semi-annual contact or redetermination. Their report status will change to a change reporter in: • Month six for changes reported in months one through six of the benefit period. • Month 12 for changes reported in months 7-12.
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PROCESSING CHANGES AND CASE ACTIONS
Benefit Increases/ Decreases Timely action (within 10 days or other time frame specified in policy) must be taken if: • Group reports their total gross income exceeds the SR income limit for their group size. • Single Lottery/gambling winning of $4,500 or more are reported by the group or the lottery match. • Information received from a prisoner or death match; see BAM 804, Incarceration Matches or BAM 808, Deceased Recipient Match. • Verified information as defined in BAM 220, Case Actions, is reported. For example, applying for another program. • Individuals who are subject to TLFA work requirements are required to report when hours of employment drop below 20 hours per week (80 hours per month). Changes Reported on MDHHS 1046 When processing the MDHHS-1046, adequate notice is given for all discovered changes. These include changes such as automated system matches (consolidated inquiry, State On-line Query (SOLQ), and/or reported on the MDHHS-1046. Complete the budget to affect no later than the 7th month’s benefits. Changes reported on the MDHHS-1046 and discovered through checking the automated system matches must be acted upon for all other programs according to case action policy in BAM 220, Case Actions. Note: Equifax Verification Services (formerly known as the Work Number) is not an automated system match which must be checked at application, redetermination, semi-annual or mid- certification contact. The group has primary responsibility for obtaining verification. However, if for example, verification of income is not available because the employer uses Equifax
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Verification Services and won’t provide the employment information, it is appropriate to use Equifax Verification Services. If the income information reported by Equifax differs from what the individual reported, verification must be requested or a documented discussion with the individual must be completed. Do not deny or terminate assistance because an employer or other source refuses to verify income; see BAM 130, Verification and Collateral Contacts. SPECIAL INCOME CONSIDERATION Income considered unpredictable such as on-call hours remain budgeted until, based on reporting requirements, the individual determines a change should be reported, or the next redetermination/semi-annual contact, whichever occurs first. Contractual income that is ending prior to the benefit period end date will be considered verified upon initial report. Because the income is averaged over the period it is intended to cover, the end date has already been verified. Post a follow-up to remove the income for the subsequent month. If the group reports their gross income exceeds the Simplified Reporting Income Limit column in RFT 250, but they remain eligible, they will be advised they are not required to report any other changes in income until their next redetermination/semi- annual contact. LOSS OF EMPLOYMENT Specialists must investigate the loss of employment at redetermina- tion/semi-annual contact to determine if a voluntary quit has occurred. If the individual does not meet the work requirement or good cause does not exist, a minimum one-month disqualification must be served; see BEM 233B, Failure to Meet Employment Requirements: FAP. OVERPAYMENT AND SR The only client error overpayments related to simplified reporting that can occur for FAP groups in SR are when the group fails to report that income exceeds the group’s SR income limit, or the
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individual voluntarily reports inaccurate information. For failure to report income over the limit, the first month of the overpayment is two months after the actual monthly income exceeded the limit. Groups report if their actual income for a month exceeds the Simplified Reporting Income Limit column in RFT 250. QC uses the actual income when determining whether a group should have reported; see BAM 715, Client/CDC Provider Error Overpayments. Example: The group’s income for September exceeded the SR income limit. The group should have reported this by October 10th. The decrease would have been effective in November. November is the first month of the overpayment. SR does not affect client errors that occur at application and rede- termination. SR does not affect the determination of agency error overpayments. OQA AND SR To review a case under simplified reporting rules rather than change reporting rules, the following must be true: • The case must be an SR eligible group; see Requirements or Groups Not Eligible for SR in this item. • The benefit period must be properly set; see Assigning Benefit Periods in this item. LEGAL BASE 7 CFR 273.12
BAM 205 1 of 3 REINSTATEMENTS BPB 2022-001 1-1-2022
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DEPARTMENT POLICY All Programs The policies in this item apply to: • All FIP, SDA and CDC groups. • FAP groups whose benefit period ends after the month of the potential reinstatement. • Medicaid groups whose eligibility ends the month of, or later than, the month of potential reinstatement. REINSTATEMENT REASONS All Programs Reinstatement restores a closed program to active status without completion of a new application. Closed programs may be rein- stated for any of the following reasons: • Closed in error. • Closed-correct information not entered. • Timely hearing request. • Redetermination packet not logged in. • Hearing decision ordered reinstatement. • Complied with program requirements before negative action date. • MDHHS-1046 manually sent and due date is after the last day of the 6th month. • Court ordered reinstatement. • MAGI Medicaid eligible for passive renewal may be reinstated if the beneficiary requests health care coverage within 90 days of the closure.
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STANDARD OF PROMPTNESS All Programs Reinstatements due to an agency error must be processed within timeframes outlined in BAM 220 processing case changes. Rein- statements ordered as part of a hearing decision must be processed within timeframes outlined in BAM 600. FIP, SDA, RCA Policy regarding the period for which an application form is consid- ered valid is not applicable to reinstatements. However, if a redetermination was due or overdue at the time of closing or would have been due during the period the program was closed, complete the redetermination within 30 days of the date of reinstatement. PROGRAM BENEFITS All Programs Bridges will determine eligibility and the amount of program benefits for the month of reinstatement and any months during which the program was closed, as if the program had not been closed. The client must update the application form if any changes occurred. Initiate reinstatement by entering the date and reason for reinstate- ment on the Bridges program request screen, under individual infor- mation. Enter any changes in data collection before running EDBC and certifying the reinstatement. Once the reinstatement is certified, any and all benefits due to the client will be issued. The eligibility begin and end dates for each program are determined by the policies indicated below: • CDC - BAM 115 and 220. • MA - BAM 210. • FAP - BAM 400 and BAM 406. Reinstatements that exceed 12 months must be processed by MDHHS exceptions.
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NOTIFICATION All Programs Use a MDHHS-176 to inform the client when a request for reinstatement is denied. LEGAL BASE FIP MCL 400.6,.37,.67 SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016. MA 42 CFR 431.230,.231,.246,.250, 435.916(a) FAP 7 CFR 273.15(k) and (s),.17(a), (b) and (f)
BAM 210 1 of 25 REDETERMINATION/EX PARTE REVIEW BPB 2026-016 7-1-2026
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POLICY All Programs The Michigan Department of Health & Human Services (MDHHS) must periodically redetermine or renew an individual’s eligibility for active programs. The redetermination/renewal process includes thorough review of all eligibility factors. Redetermination, renewal, semi-annual and mid-certification forms are often used to redetermine eligibility of active programs. However, the client must complete a MDHHS-1171, Assistance Application, and program specific supplement form(s) to request a program that is not active at the time of redetermination or a DCH- 1426, Application for Health Coverage and Help Paying Costs, to request Medicaid. Local offices must assist clients who need and request help to com- plete applications, forms and obtain verifications; see Bridges Administrative Manual (BAM) 130, Verification and Collateral Contacts, Obtaining Verification. Medicaid A redetermination is an eligibility review based on a reported change. A renewal is the full review of eligibility factors completed annually. PASSIVE RENEWAL MAGI MEDICAID MDHHS must use information currently available in State of Michigan systems to renew eligibility. Do not request information from the beneficiary if the information is already available to MDHHS. This includes completing a renewal form. Note: Any income information currently available in State of Michigan systems must have been verified within the 12 months previous to the renewal date in order to be used for a passive renewal. If the income information available was verified more than 12 months before the renewal date, then new income information must be requested.
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Individuals must be able to select how many years to opt in to allowing MDHHS to access tax information to determine continuing eligibility, up to a maximum of 5 years. Individuals must also have the opportunity to opt out of allowing the use of tax information. Do not include individuals in the passive renewal process if this question is not answered on the application. Only information that has changed or is missing may be requested from the beneficiary. The beneficiary is not required to take any action, such as signing or returning a notice if there has been no change in their circumstances. If the information is not sufficient to renew eligibility, MDHHS must send a pre-populated renewal form to the beneficiary. Allow the beneficiary 30 calendar days to respond and return the renewal form. MDHHS must notify the beneficiary of their eligibility and the basis for the determination. EX-PARTE REVIEW Medicaid/Medical Assistance (MA) Only An ex parte review (see Glossary) is required before Medicaid clo- sures when there is an actual or anticipated change, unless the change would result in closure due to ineligibility for all Medicaid. When possible, an ex parte review should begin at least 90 calendar days before the anticipated change is expected to result in case closure. The review includes consideration of all MA categories; see BAM 115, Application Processing and BAM 220, Case Actions. Asset Verification Program MA Only Electronic asset detection will occur at the time of an individual's annual renewal and anytime an individual is added to healthcare coverage on an existing case. Asset detection may include the following sources at financial institutions: checking, savings, and investment accounts, individual retirement accounts (IRAs), treasury notes, certificates of deposit
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(CDs), annuities, and any other asset that may be held or managed by a financial institution. REDETERMINATION/ RENEWAL CYCLE All Programs A complete redetermination/renewal is required at least every 12 months. Bridges sets the redetermination/renewal date according to benefit periods; see Eligibility Decisions in BAM 115. Redeterminations/renewals may be scheduled early or are scheduled less than 12 months apart when necessary for: • Error-prone cases, in response to supervisory case readings, quality assurance data or quality enhancement data. • MA only, newborn cases must be renewed no later than the month of the child’s first birthday; see Bridges Eligibility Manual (BEM) 145, Newborns. • Food Assistance Program (FAP) cases with unstable circum- stances assigned a three-month benefit period. Exception #1: Some MA groups do not require a renewal; see No MA Renewal in this item. Exception #2: Some FAP groups are assigned a 24-month benefit period and require only a mid-certification contact in the 12th month; see Mid-Certification Contact in this item. For MA, a com- panion case for a spouse may also be given the extended benefit period once the mid-certification notice has been received and reviewed. Michigan Combined Application Project (MiCAP) cases are assigned a 36-month benefit period. FAP Only Benefits stop at the end of the benefit period unless a redetermina- tion is completed and a new benefit period is certified. If the client does not begin the redetermination process, allow the benefit period to expire. The redetermination process begins when the client files a MDHHS-1171, Assistance Application and MDHHS- 1171-FAP, Supplement- Food Assistance Program; MDHHS-1010, Redetermination and MDHHS-1010-FAP; MDHHS-1171, filing form. See Subsequent Processing in this item.
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Child Development and Care (CDC) Only A redetermination for CDC cannot be completed earlier than the 12-month continuous eligibility period. Medicaid Benefits stop at the end of the benefit period unless a renewal is completed, and a new benefit period is certified. Also, the renewal month is 12 months from the date the most recent complete application was submitted. Example: In a Group 2 Persons Under 21 case, if a member will reach age 21 before the month the case is scheduled to be renewed, an ex parte review (see Glossary) should begin at least 90 days prior to the date the member turns 21; see BAM 220. In a Special N/Support, Title IV-E or Foster Care TMA case, an ex parte review should begin at least 90 days prior to the date the case is scheduled to close; see BAM 220. In a Healthy Michigan Plan (HMP) case, if a beneficiary will reach age 65 before the month the case is scheduled to be renewed, an ex parte review should begin at least 90 days prior to the date the beneficiary turns 65; see BAM 220. No Medicaid Renewal Medicaid Only Do not renew the following: • Special N/Support; see BEM 113. • Title IV-E recipients; see BEM 117. • Special needs adoption assistance recipients; see BEM 117. • Department wards; see BEM 117. • Supplemental Security Income (SSI) recipients; see BEM 150. Note: A review must be completed before closing an individual in one of these categories if the closure is for any reason other than total ineligibility for any MA (such as moved out of state or death). The review must consider eligibility in all other MA categories.
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INTERVIEW REQUIREMENTS FIP, State Disability Assistance (SDA), Refugee Cash Assis- tance (RCA), CDC and FAP Interview requirements are determined by the program that is being redetermined. FAP Only An interview is required before denying a redetermination even if it is clear from the MDHHS-1010 or MDHHS-1171 or other sources that the group is ineligible. Indicate on the individual interviewed/applicant-details screen in Bridges who was interviewed and how the interview was held, such as by telephone, in person etc. If an interview is completed, the client or authorized representative (AR) must be offered a copy of their completed application. The copy must have the Social Security numbers for anyone listed and/or any mention of domestic violence redacted.
Medicaid Do not require an in-person interview as a condition of eligibility. CDC Only There is no redetermination interview requirement for CDC. Telephone FIP Only Note: The specialist must conduct a telephone interview with the head of household at redetermination before certifying continued eligibility. However, conduct an in-person interview if the client requests one. When conducting a telephone interview, ask the head of household a question only the head of household could answer (such as last four digits of their Social Security number, date of birth, etc.) to ensure the identity of the caller. Document the case record with the answer.
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Each adult EDG member must sign the DHS-1538, Work and Self- Sufficiency Rules, at redetermination. Send each adult EDG mem- ber in the home the DHS-1538 at redetermination. Each DHS-1538 must be signed and returned for all adult EDG members before FIP redetermination can be approved. The local office may exempt a relative caretaker or unrelated caretaker ineligible grantee and dependent child member adds from the FIP interview requirements. Member Add at Redetermination FIP Only At redetermination, if an adult mandatory group member is added to the group, the specialist must do the following: • Conduct a telephone or in-person interview with the adult mandatory group member; see Telephone Interviews in BAM 115. • Review the list of FIP requirements; see Interviews in BAM 115. • Send the new adult mandatory group member the DHS-1173, Cash Assistance Rights and Responsibilities, and DHS-1538. Do not approve the redetermination until the DHS-1173 and DHS-1538 are signed and returned. FAP Only The individual interviewed may be the client, the client’s spouse, any other responsible member of the group or the client’s authorized representative. If the client misses the interview, Bridges sends a DHS-254, Notice of Missed Interview. Conduct a telephone interview at redetermination before determin- ing ongoing eligibility. However, conduct an in-person interview if one of the following exists: • The client requests one. • It is determined appropriate. For example, information on the application is suspected to be fraudulent.
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Exception: Do not require an in-office interview if the client is experiencing a hardship which prevents an in-office interview. Instead, conduct the in-person interview at the client’s home or another agreed upon location. Hardship conditions include but are not limited to illness, transportation difficulties, work hours. • The specialist is processing a joint SDA/RCA and FAP redetermination; see Jointly Redetermined SDA/RCA and FAP Cases in this item. Note: When conducting a telephone interview, ask the caller a question only the head of household could answer (such as last four digits of their Social Security number, date of birth, etc.) to ensure the identity of the caller. In-Person State Disability Assistance (SDA) All individuals with an SDA Eligibility Determination Group (EDG) participation status of eligible or disqualified adult who are physically able must be interviewed and must sign and date the MDHHS-1010 or MDHHS-1171 in the specialist's presence. Interviews are usually conducted at the local office but may be held in a group’s home if: • The head of household’s physical condition precludes an office interview. • A home call would result in better information. Jointly Redetermined SDA/RCA and FAP Cases SDA/RCA and FAP Conduct a telephone or in-person interview at redetermination before determining ongoing eligibility. The head of household or authorized representative must sign and date the MDHHS-1010 or MDHHS-1171 in the presence of a MDHHS specialist even if it was already signed if an in-person interview is conducted. Sign and date the application as a witness. Exception: For FAP, do not require an in-office interview if the client is experiencing a hardship which prevents an in-office interview. Instead, conduct the in-person interview by telephone or
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at the client’s home or another agreed upon location. Hardship conditions include but are not limited to illness, transportation difficulties, work hours, etc. SCHEDULING All Programs Bridges generates a redetermination packet to the client on the fourth day of the month before the redetermination is due. The packet is sent to the mailing address in Bridges. The packet is sent to the physical address when there is no mailing address. The packet is also sent to the MA authorized representative on file. Redetermination/renewal forms may include: • MDHHS-1010, Redetermination (all programs) and program specific supplement form(s): • MDHHS-1010-CASH- Cash Assistance. • MDHHS-1010-CDC- Child Development and Care. • MDHHS-1010-FAP-Food Assistance. • MDHHS-1010-HC- Health Care Coverage. • MDHHS-1046, Semi-Annual Contact Report (FAP). • MDHHS-1171, Assistance Application and program specific supplement form(s). • MDHHS-1171-Cash, Supplement- Cash Assistance. • MDHHS-1171-CDC, Supplement- Child Development and Care. • MDHHS-1171-HCC, Supplement- Health Care Coverage. • MDHHS-1171-FAP, Supplement- Food Assistance Program. • MDHHS-2240-A, Mid-Certification Contact Notice (MA and FAP). • DCH-1426, Application for Health Coverage and Help Paying Costs. • OMB 0938-1213, A federal application for Health Coverage and Help Paying Costs.
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• DHS-4574, Medicaid Application (Patient of Nursing Facility). The packet includes the following as determined by the TOA to be redetermined: • Redetermination/review/renewal form indicated above. • Notice of review as determined by policy. • Interview date. • Interview type. • Place and time. • Required verifications. • Due date. • Return envelope. FAP Only If the MDHHS-1171, and the MDHHS-1171-FAP must be manually sent, mail them no later than two workdays before the first day of the redetermination month. If the forms are not mailed within that time, adjust the timely filing date; see FAP Timely and Untimely Filing Date in this item. Clients may be, but are not required to be, interviewed before the timely filing date. CDC Only At redetermination if the CDC asset question is not addressed, the client will need to be contacted to certify the program group's assets do not exceed $1 million. Early Redetermination FIP, SDA, RCA, MA and FAP Redetermination of an active program may be scheduled up to three months before the review date. Redetermination of active programs may be necessary for one of the following reasons: • Case is found to be error prone as a result of supervisory case reading, quality assurance data or quality enhancement data. • Specialist’s schedule requires early redetermination of active program.
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• To align dates to simultaneously process redeterminations for multiple programs. Bridges does this automatically for all programs except certain MA programs such as TMA. Initiate redetermination early by selecting that option from the Bridges left navigation. Enter the case number and select the program(s) to be redetermined early from the list of options that are determined by the case number. CDC Only A redetermination for CDC cannot be completed earlier than the 12-month continuous eligibility period. FAP Only When a redetermination is scheduled early, FAP benefits cannot be terminated prior to the end of the benefit period for failure to com- plete the redetermination process. Children Under 19 (U19) and MIChild Do not shorten a beneficiary's 12-month eligibility period. Once eligible, children under 19 years of age will remain eligible until the next redetermination unless any of the following occurs: • Reaches age 19-aged out. • Moves out of state. • Death. • Request closure. • Eligibility was based on erroneous information. A member may be added to an existing case even though the rede- termination date is less than 12 months in the future. Note: Note: If a child on CHIP (MIChild) becomes eligible for and transfers to a Medicaid program, they must remain on Medicaid for the duration of the 12-month period. Exceptions: Continuous Eligibility does not apply to the following; • Children in TMA. • Children in Presumptive Eligibility • Children in a Group 2 Medically Needy category (spend-down).
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MID- CERTIFICATION / SEMI-ANNUAL CONTACT FAP Only Bridges sends a MDHHS-2240-A, Mid-Certification Contact Notice, for groups assigned a 24-month benefit period during the 11th month of their benefit period and a MDHHS-1046, Semi-Annual Contact Report, the beginning of the fifth month for cases assigned a 12-month benefit period. Note: Manually send from Bridges and track the MDHHS-1046 if it is discovered that a case was not correctly assigned as a simplified reporter by the last day of the fourth month of the benefit period. Groups assigned a 24-month benefit period must submit a complete MDHHS-2240-A, Mid-Certification Contact Notice. A complete MDHHS-1046, Semi-Annual Contact Report, must be submitted by groups with countable earnings and a 12-month benefit period; see BAM 115, Benefit Periods. The MDHHS-1046 and MDHHS-2240A may be completed by the group, the group’s authorized filing representative or by the specialist (during a telephone call, home call or interview with the client). However, the form must be signed by the client or authorized filing representative. A report is considered complete when signed and all of the sections on the MDHHS-1046 or the MDHHS 2240-A are answered completely or the no changes box on the first page is selected and required verifications are returned by the group or group’s authorized representative. If an expense has changed and the group does not return proof of the expense, if required, but all of the sections on the report are answered completely, remove the expense in Bridges before certifying.. 24-Month Benefit Period The mid-certification contact notice must be recorded, data collec- tion updated and eligibility results certified in Bridges by the last day of the 12th month after a completed MDHHS-2240-A and all required verifications are received. Note: Run eligibility even if the group indicates no changes so Bridges will recognize the MDHHS-2240-A has been processed.
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12-Month Benefit Period The semi-annual contact report must be recorded, data collection updated and eligibility results certified in Bridges by the last day of the sixth month of the benefit period to affect benefits no later than the seventh month. The contact is met by receipt of a completed MDHHS-1046 and required verifications. Processing MDHHS-1046 The group’s gross earned income from their most current budget is pre-filled on the MDHHS-1046. If the client’s gross income has changed by more than $125 from the pre-filled amount on the form, they must return verification of past 30 days of earnings with completed MDHHS-1046. If the group indicates their gross earned income has not changed by more than $125, verification of the past 30 days is not required. However, income must be budgeted and eligibility run if the group checks “No” to the questions but supplies proof of income. Note: Run eligibility so Bridges will recognize the MDHHS-1046 has been processed. Medicaid only The MDHHS 2240-A may be used to complete an ex parte review of MA or certify a second 12-month MA period when the group has a 24-month FAP certification. REDETERMINATION PACKET RECEIVED FIP, State Disability Assistance (SDA), Refugee Cash Assis- tance (RCA), CDC and FAP A redetermination/review packet is considered complete when all of the sections of the redetermination form including the signature section are completed. Exception: For FIP, SDA and FAP only, if any section of the redetermination/review packet has not been completed but there is a signature, consider the redetermination/review complete. Complete any missing sections during the interview. When a complete packet is received, record the receipt in Bridges as soon as administratively possible.
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If the redetermination is submitted through MI Bridges, the receipt of the packet will be automatically recorded. Medicaid Only A redetermination/review packet is considered complete when all of the sections of the redetermination form including the signature section are completed and all requested verifications needed for determination are returned. Failure to Record Receipt of Redetermination Packet CDC Only When redetermination packets are not logged by the 10th day of the redetermination month, the DHS-5322, Notice of Potential Child Development and Care (CDC) Closure, will be generated by Bridges to the client. This notice informs the client that CDC benefits will end the pay period that holds the last day of the month. FIP, SDA, and CDC If the redetermination packet is not logged in by the negative action cut-off date of the redetermination month, Bridges generates a DHS-1605, Notice of Case Action, and automatically closes the EDG. FAP only If the redetermination packet is not logged in by the last working day of the redetermination month, Bridges automatically closes the EDG. A DHS-1605 is not generated. Medicaid only Benefits are not automatically terminated for failure to record receipt of the renewal packet. Failure to Record Receipt of the Mid-Certification Contact Notice FAP Only
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If the MDHHS-2240-A is not logged in Bridges by the 10th day of the 12th month, Bridges will generate a DHS-2240-B, Notice of Food Assistance (FAP) Closure, to the client. This notice explains that the client must return the MDHHS-2240-A and all required verifications by the last day of the month, or the case will close. If the client fails to return a complete MDHHS-2240-A by the last day of the 12th month. Bridges will automatically close the case. If the client reapplies, treat it as a new application and Bridges will prorate the benefits. If the completed MDHHS-2240-A and verifications are returned by the last day of the 12th month, process the changes to ensure the client’s benefits are available no later than 10 days after their normal issuance date in the 13th month of the benefit period. Failure to Record Receipt of the Semi-Annual Contact Report If the MDHHS-1046 is not logged in Bridges by the 10th day of the sixth month, Bridges will generate a MDHHS-1046-A, Notice of Food Assistance (FAP) Closure, to the client. This reminder notice explains that the client must return the MDHHS-1046 and all required verifications by the last day of the month, or the case will close. If the client fails to return a complete MDHHS-1046 by the last day of the sixth month. Bridges will automatically close the case. If the client reapplies, treat it as a new application and Bridges will prorate the benefits. If the completed MDHHS-1046 and verifications are returned by the last day of the sixth month, process the changes to ensure the client’s benefits are available no later than 10 days after their normal issuance date in the seventh month of the benefit period. Conducting the Interview FIP, SDA and FAP • Obtain a complete redetermination/review packet from the client.
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• Compare the redetermination/review document to the existing MDHHS-1171 and program specific supplement form(s) or previous MDHHS-1010 and applicable program specific supplements and other case data. Reconcile any discrepancies and ensure anything omitted is completed. • Review the verifications and reconcile discrepancies. • Verbally cover the rights and responsibilities with the client and refer them to view online, the following sections of the PUB- 1010, Important Things About Programs and Services: • Your Responsibilities. • Your Rights. • Resources. • Privacy Details. • Penalties.
FIP Only • Review the Family Self-Sufficiency Plan (FSSP) for compliance. • Identify any barriers to the family's self-sufficiency and strategies for client to overcome them. • Update each FSSP to identify the specific steps the individual will take towards family self-sufficiency. • Review work participation requirements. Identify any potential deferrals listed in; see BEM 230A, Employment and/or Self- Sufficiency Related Activities: FIP. • Review direct support service opportunities, including transportation and child care; see BEM 229, Path Program Referrals & The Application Eligibility Period. • Review penalties for non-compliance; see BEM 233A, Failure To Meet Employment And/Or Self-Sufficiency Related Activities: FIP. • Review FIP time limits; see BEM 234, FIP Time Limits.
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• Explain the prohibited use of FIP to purchase lottery tickets, alcohol, tobacco, or for gambling, illegal activities, massage parlors, spas, tattoo shops, bail-bond agencies, adult entertainment, cruise ships, or other nonessential items. FAP TIMELY AND UNTIMELY FILING DATE FAP Only Timely Filing Date In order to receive uninterrupted benefits (benefits available on their scheduled issuance date), the client must file the redetermination through MI Bridges or file either a MDHHS-1010, Redetermination and MDHHS-1010-FAP, MDHHS-1171, Assistance Application and MDHHS-1171-FAP supplement, or a signed MDHHS-1010-FAP, FAP 1010 supplemental filing form, by the fifteenth of the redetermination month. Exception: If the group’s redetermination materials are mailed late, the timely filing date is 17 days after the materials are mailed. Example: Madison’s FAP redetermination is due in July. The redetermination materials are mailed July 6 with a due date of July 16 on the DHS-3503. Madison returns all necessary items needed to complete the review on July 20. The filing date is timely because the review materials were mailed late. The benefits must be available to Madison on the scheduled issuance date. When processing a redetermination for FAP and FIP, SDA, or MA, consider the FAP redetermination filed timely if it is filed timely for the other program; see FAP Client Failure to Meet Redetermination Requirements in this item. Untimely Filing Date FAP Only Any FAP redetermination form not submitted timely (see above) has the same processing timeframe as an initial application (30 days from the date the redetermination was filed); see FAP Client Failure to Meet Redetermination Requirements in this item.
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VERIFICATIONS DEADLINE FIP, SDA, CDC and MA Verifications are due the same date as the redetermination/review interview. When an interview is not required, verifications are due the date the packet is due. Bridges allows clients a full 10 calendar days from the date the veri- fication is requested (date of request is not counted) to provide all documents and information. If the tenth day falls on a weekend or holiday, the verification will not be due until the next business day. MAGI Medicaid beneficiaries have 30 calendar days to return the pre-populated renewal form. Bridges gives timely notice of the negative action if the time limit is not met. FAP Only Verifications must be provided by the end of the current benefit period or within 10 days after they are requested, whichever allows more time. If the tenth day falls on a weekend or holiday, the verification will not be due until the next business day. Note: The DHS-3503, Verification Checklist, should be sent after the redetermination interview for any missing verifications allowing 10 days for their return. Example: Client returns a complete MDHHS-1010 and program specific supplement on the last day of the benefit period and fails to provide verification of income. Request income verification allowing the client 10 days to return verification. If verifications are provided by the required deadline but too late for normal benefit issuance, benefits must be issued within five work- days. Note: If an expense has changed and the client does not return proof of the expense, but all of the sections on the report are answered completely, end-date the expense from the appropriate data collection screen(s) in Bridges before running EDBC.
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CDC Only If a signed redetermination form is received prior to the end of the redetermination month, and verifications are missing or are incomplete, send a VCL. Verifications are due by the end of the redetermination month, or within 10 days after they are requested, whichever allows more time. COMPLETING THE REDETERMINATION/ RENEWAL All Programs To complete the redetermination/renewal process, do all of the following: • Obtain a MDHHS-1010 and program specific supplement form(s), MDHHS-1171 and program specific supplement form(s), or other review document. • Record packet received by selecting that item from the left navigation in Bridges and entering the date received. • Review, document and verify eligibility factors as required. • MAGI Medicaid uses the H79, Redetermination & Renewal Verification (RRV) Service, to perform income verifications. • Except for Children Under 19 (U19) and MIChild (MCD), check all available automated systems matches to see if income has started, stopped or changed, such as consolidated inquiry, State On-line Query (SOLQ), etc. Note: Equifax Verification Services (formerly known as The Work Number) is not an automated system match which must be checked at application, redetermination, semi-annual or mid- certification contact. The client has primary responsibility for obtaining verification. However, if, for example, verification of income is not available because the employer uses Equifax Verification Services and will not provide the employment information, it is appropriate to use Equifax Verification Services.
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FAP Only If the income information reported by Equifax differs from what the client reported, verification must be requested or a documented discussion with the client must be completed. FAP groups must verify all countable income before a redetermination can be denied for exceeding the income limit. A VCL must be sent giving the group 10 calendar days to provide the income verification. If the group does not provide income verification by the VCL due date, the redetermination must be denied for failure to provide verification. If income verification is provided, the redetermination can be denied for exceeding the income limit, if applicable. Do not deny or terminate assistance because an employer or other source refuses to verify income; see BAM 130, Verification and Collateral Contacts, and BEM 702, CDC Verifications. • Update data collection by recording changes in circumstances and entering verifications received. • Run EDBC in. • Certify EDBC results if appropriate. • Review the need for services and other assistance programs. Generate a verification checklist (VCL) for any missing verifications. Upon Certification • Prepare the case record; see BAM 300. • Send Pub. 280, Reporting Changes - When To Report - How To Report - What To Report.
Exception: Do not send to FAP groups assigned to simplified reporting. • Bridges sends a MDHHS-2240, Report Changes, as needed.
Exception: A MDHHS-2240, Report Changes, is not sent to FAP groups assigned to Simplified Reporting, Children under 19 (U19).
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• Bridges sends a DHS-1605, explaining simplified reporting and household income limit, and a DHS-1045, Simplified Six-Month Review, to FAP groups assigned to simplified reporting. • Bridges produces and sends a DHS-198C, Child Development and Care (CDC) Client Notice, to the client. • Bridges produces and sends a DHS-198, Child Development and Care (CDC) Provider Notice, to the provider(s). • Bridges produces and sends a DHS-1606, Health Care Coverage notice which details the information used to determine eligibility. STANDARD OF PROMPTNESS All Programs Bridges generates a redetermination packet to the client on the fourth day of the month before the redetermination is due. If the fourth day occurs on a holiday or on a Sunday, then the packet is sent on the next business day. This allows time to process the redetermination before the end of the redetermination month. Reinstatements in Month Prior to Redetermination Month If an EDG closes and is due for redetermination the following month and is subsequently reinstated at least three days prior to the cur- rent month’s negative action cut-off date, the redetermination packet will be generated as usual. If an EDG closes and is due for redetermination the following month and is subsequently reinstated on or after three days prior to the current month’s negative action cut-off date, the redetermination packet will be generated at month end. FAP Only The FAP redetermination must be completed by the end of the cur- rent benefit period so that the client can receive uninterrupted benefits by the normal issuance date.
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If timely redetermination procedures are met, but too late to meet the normal issuance date, issue benefits within five workdays. Bridges will issue a payment for lost benefits if the client is not at fault for delayed processing that prevented participation in the first month. CDC CLIENT FAILURE TO MEET REDETERMINATION REQUIRMENTS CDC Only If income reported at redetermination exceeds program eligibility limits, and all other eligibility criteria are met, determine if the increase is temporary excess income or is expected to continue; see BEM 505, Prospective Budgeting/Income Change Processing, Temporary Excess Income. If the increase is temporary, a policy exception and assistance from the Bridges Resource Center (BRC) are required to certify the case. Set the family contribution amount at the highest level. If a case with previously established temporary excess income crosses over redetermination, and all other eligibility criteria are met, a policy exception and assistance from the BRC are required to certify the eligibility. The family contribution will be set at the highest level. A CDC income eligible case that closes for failure to meet redetermination requirements will not be eligible for re-entry into the program if the family's income exceeds the Maximum Monthly Income by Family Size associated with the program entry limit; see RFT 270, CDC Income Eligibility Scale and Provider Rates. FAP CLIENT FAILURE TO MEET REDETERMINATION REQUIREMENTS FAP Only Delays The group loses its right to uninterrupted FAP benefits if it fails to do any of the following:
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• File the FAP redetermination by the timely filing date. • Participate in the scheduled interview. • Submit verifications timely, provided the requested submittal date is after the timely filing date. Any of these reasons can cause a delay in processing the redeter- mination. When the group is at fault for the delay, the redetermina- tion must be completed within 30 days of the compliance date. If there is no refusal to cooperate and the group complies by the 30th day, issue benefits within 30 days of the compliance date. Benefits are not prorated. Subsequent Processing If a client files an application for redetermination before the end of the benefit period, but fails to take a required action, the case is denied at the end of the benefit period. Proceed as follows if the cli- ent takes the required action within 30 days after the end of the benefit period: • Re-register the redetermination application using the date the client completed the process. • If the client is eligible, prorate benefits from the date the redetermination application was registered. Example 1: • On January 5, client returns MDHHS-1010 and program specific supplement for a certification period ending January 31. • On January 31, redetermination is denied for failure to return verifications. • On February 10, client returns required verifications. • Re-register the original redetermination application with the February 10 date and issue prorated benefits from February 10. Example 2:
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• On January 3, client returned MDHHS-1010 and program specific supplement for a certification period ending January 31. • On January 31, redetermination is denied for failure to return verifications. • On February 2, client files a new application. • On February 10, client returns required verifications from January redetermination. • Use the February 2nd date to process benefits. Example 3: • Client has a redetermination due for February with the certification period ending February 28. • On February 28, case closes for failure to return the MDHHS- 1010 and program specific supplement. • On March 10, client returns completed MDHHS-1010 and program specific supplement. • Client must complete a new application for FAP since they returned the completed MDHHS-1010 and program specific supplement after the end of the benefit period. REPORT OF REDETERMINA- TIONS All Programs RD-093 The monthly RD-093, Redetermination Report - Worker Listing, lists the following: • FIP, SDA, MA, and CDC cases that are past due more than one month. • FIP, SDA, MA, and CDC cases that are past due one month. • FIP, SDA, MA, CDC, and FAP cases that are due this month. • FIP, SDA, MA, CDC, and FAP cases that are due next month.
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• FIP, SDA, MA, CDC, and FAP cases that are due in two months. • FAP and MA cases that are due for a mid-certification contact. RD-093, Long Term Care (LTC) Case Identification MA Only The LTC-application indicator (4574) on the RD-093 identifies MA LTC cases. Bridges sends the DHS-4574, Medicaid Application (Patient of Nursing Facility), in the redetermination packet for the MA redetermination when a DHS-4574 was filed at application. RD-093, Deductible Case Identification MA Only The deductible indicator (#) identifies active deductible cases. This indicator will be printed when the member of an MA EDG has a deductible amount. LEGAL BASE FIP MCL 400.32, MCL 400.43, MCL 400.55(f), MCL 400.57d(5) SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 FAP 7 CFR 273.10(g)(2) 7 CFR 273.12(a)(5)(iii)(C) 7 CFR 273.14 7 U.S.C. 2020 MA 42 CFR 435.916(a)
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CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99 Social Security Act, as amended 2016
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DEPARTMENT POLICY Family Independence Program (FIP), Refugee Cash Assistance (RCA), State Disability Assistance (SDA), Medicaid (MA), Child Development and Care (CDC) Food Assistance Program (FAP) Process the following case actions: • Initial applications and reapplications; Bridges Administrative Manual (BAM) 115, Application Processing. • BAM 210, Redeterminations. • BAM 205, Reinstatements. Bridges will evaluate each change reported and entered in the sys- tem to determine if it affects eligibility. Exception: For Medicaid only, the Michigan Department of Health and Human Services (MDHHS) health services side, shares responsibility for medical services authorization (MSA) and certain related determinations when a recipient in managed care becomes a Long-Term Care/Hospital patient; see Bridges Administrative Manual 120, DCH/DHS Coordination, for details. Changes in circumstances may be reported by the client, via com- puter tape matches, through quality assurance (QA) reviews, or by other means. A positive action is a Michigan Department of Health & Human Services (MDHHS) action to approve an application or increase a benefit. A negative action is a MDHHS action to deny an application or to reduce, suspend or terminate a benefit. This includes an increase in a post-eligibility patient-pay amount for MA or an increase in the client pay for a special living arrangement. CDC Only Changes reported by clients may affect eligibility for other programs but may not affect the current CDC eligibility or benefit. Only changes that would positively affect the client's family contribution (FC), or authorized hours, unless a negative action is required or allowed in the following situations:
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Those listed in the CDC EDG Closure Reasons; in BAM 220, Case Actions . • An FC increase tied to a provider change. • A case correction required due to an incorrect eligibility determination (regardless of client or agency error). CDC clients are required to report, within 10 calendar days, changes in: • Group composition/death. • Out of state residency. • Providers or child care setting. • Assets that exceed $1 million. • When income exceeds the income eligibility scale for the family size; see RFT 270, CDC Income Eligibility Scale and Provider Rates. Note: See Bridges Eligibility Manual BEM 703, CDC Program Requirements, Request for Additional Assistance, for policy pertaining to a request for an additional provider, need reason or need hours for an active client during the 12-month continuous eligibility period. NOTICE OF CASE ACTIONS All Programs Upon certification of eligibility results, Bridges automatically notifies the client in writing of positive and negative actions by generating the appropriate notice of case action. The notice of case action is printed and mailed centrally from the consolidated print center. For FAP Only, see Actions Not Requiring Notice in this item. Exception: Written notice is not required to implement a hearing decision or policy hearing authority decision. See BAM 600, Hearings, if a client disputes a case action. There are two types of written notice: adequate and timely. A notice of case action must specify the following: • The action(s) being taken by the department.
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• The reason(s) for the action. • The specific manual item which cites the legal base for an action or the regulation or law itself. • An explanation of the right to request a hearing. • The conditions under which benefits are continued if a hearing is requested. Adequate Notice An adequate notice is a written notice sent to the client at the same time an action takes effect (not pended). Adequate notice is given in the following circumstances: All Programs • Approval/denial of an application. • Increase in benefits. FIP, RCA, SDA, MA, CDC • A recipient or his legal guardian or authorized representative requests in writing that the case be closed. • Factual information confirms a recipient's death. • It is verified that a recipient has been approved for assistance in another state. • It is verified that an eligible child, or in MA, an eligible group member of any age, has been removed from the home as a result of court action. FIP, SDA, and FAP Only An intentional program violation (IPV) disqualifies the only eligible member or reduces/terminates other members' benefits. See the Disqualification section in BAM 720, Intentional Program Violation, for notice procedures and forms. FIP and MA Only Denial of request for medical transportation.
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SDA Only Case closure due to a member's receipt of Supplemental Security Income. CDC Only • The client or provider reports, orally or in writing, that a child is no longer in the care of that provider. • It is verified that a child member of the program group was voluntarily placed in foster care. • Information verifies the provider is no longer eligible to receive payments. MA Only • Case opening with a deductible or patient-pay amount. • Decrease in post-eligibility patient-pay amount. • Recipient removed due to his eligible status in another case. • Addition of MA coverage on a deductible case. • Increase in medical benefits. • At case open with a divestment penalty FAP Only • The change was reported in writing and signed by an eligible group member and the new benefit level or ineligibility can be determined based solely on the written information. Note: When deleting a member, an application the client files on their own, or the updated application of a group they join, is considered a change reported in writing by an eligible member of the former group. • Reliable information indicates the group will leave the state before the next issuance. • Changes reported on a MDHHS-1046, Semi-Annual Contact Report.
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Timely Notice All Programs Timely notice is given for a negative action unless policy specifies adequate notice or no notice. See Adequate Notice and, for FAP only, Actions Not Requiring Notice, in this item. A timely notice is mailed at least 11 days before the intended negative action takes effect. The action is pended to provide the client a chance to react to the proposed action. Actions Not Requiring Notice FAP Only A notice of case action is not sent in the situations below. The action must take effect no later than the month after the change. • Reliable information indicates the group left the state. • Reliable information indicates all members died. Reliable sources generally include a newspaper, friends or relatives of the group, or other agencies. • Supplementation over multiple months to restore lost benefits is completed; see BAM 406, Supplemental Food Assistance Benefits. • From a joint FIP/SDA and FAP application, the FAP benefit began first and the FAP approval letter indicated the benefit might decrease if FIP/SDA were later approved. • The FAP benefit varies from month to month within the benefit period due to changes anticipated when the case was certified, and the group was so notified at that time. • Benefits are reduced for failure to repay a FAP overpayment that resulted from IPV (BAM 720, Intentional Program Violation) or client error (BAM 715, Client/CDC Provider Violation); see BAM 725, Collection Actions. • The FAP certification period has expired, and redetermination application was not filed. • The group voluntarily requests closure in writing.
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Child Care Provider Authorization CDC Only Bridges generates a DHS-198, Child Development and Care (CDC) Provider Notice, to notify CDC providers when: • An authorization is added. • The authorized hours change. • Closing the CDC eligibility determination groups (EDG). • The family contribution changes. A manual DHS-198 must be sent by the specialist when a manual authorization is entered in Bridges. MASS UPDATES All Programs Certain changes result from changes by the federal or state govern- ment and involve mass updates of the entire or major portions of the caseload. Central office usually processes most of the affected cases through Bridges mass update and mails notices to client. Local offices are often required to assist in a mass update, as specified in a program policy bulletin. Mass updates affecting various programs include: • Annual FAP standards update. • Retirement, survivors, and disability insurance (RSDI) updates. • Periodic changes in program benefit amounts. • Other changes in eligibility factors based on laws or regulations. STANDARDS OF PROMPTNESS All Programs The standard of promptness (SOP) is the maximum time allowed to complete a required case action. Cases should be processed as quickly as possible. The SOP sometimes varies by program.
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Change Reported Via Data Matches FIP, RCA, SDA, CDC and MA Case actions resulting from changes reported via data matches (BENDEX, SDX, IRS, enumeration, etc.) must be completed within 45 days of receiving the information. FAP Only Case actions resulting from changes reported via data matches (BENDEX, SDX, IRS, enumeration, etc.) must be completed within 45 days of receiving the information. Exception: For simplified reporting groups, the following data matches are acted upon only at semi-annual or redetermination (whichever comes first): • Wage Match. (BAM 802) • IRS Unearned Income Match. (BAM 803) • IRS Wage and Pension Match. (BAM 803) • State New Hires Match. (BAM 807) • National Directory of New Hires Match. (BAM 813) • Paris Interstate Match. (BAM 814) Exception: For change reporting groups, the following data matches are addressed only at mid-certification or redetermination (whichever comes first): • Wage Match. (BAM 802) • IRS Unearned Income Match. (BAM 803) • IRS Wage and Pension Match. (BAM 803) • Paris Interstate Match. (BAM 814) Exception: For change reporting groups with a state new hires match and/or national directory of new hires match, when to act is determined based on the date of the match and the processing date: • If the date of the match is less than 60 days from the processing date, the following matches must be addressed: State New Hires Match. (BAM 807) National Directory of New Hires Match. (BAM 813)
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• If the date of the match is 60 days or more from the processing date, the following matches are held and addressed at the next mid-certification or redetermination (whichever comes first). State New Hires Match. (BAM 807) National Directory of New Hires Match. (BAM 813)
All Other Reported Changes FIP, RCA, SDA, CDC and MA Act on a change reported by means other than a data match within 15 workdays after becoming aware of the change. FAP Only Act on a change reported by means other than a data match within 10 days of becoming aware of the change if one or more of the following is true: • Additional verification is not required to make the change. • The change has been verified by another program. • The information is required for the group's reporting status. If none of the above bullets are true, the change(s) will be held and addressed at the next semi-annual, mid-certification, or redetermination (whichever comes first). Unless a change is reported that conflicts with information used at the time of application, semi-annual, mid-certification or redetermination, indicating the household may have failed to report eligibility information. Then, verification would be requested for all reporting groups. Benefit Increases: Changes which result in an increase in the household’s benefits must be effective no later than the first allot- ment issued 10 days after the date the change was reported, pro- vided any necessary verification was returned by the due date. A supplemental issuance may be necessary in some cases. If neces- sary verification is not returned by the due date, take appropriate action based on what type of verification was requested. If verifica- tion is returned late, the increase must affect the month after verifi- cation is returned. Example: Rich reports and provides proof of a dependent care expense on March 23rd. Act on the change by April 2nd. May’s
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benefits will be the first month affected because the 10th day after the change is reported falls in the next eligibility month. Affect the April issuance if the action can be completed by March 31st. Example: Rich is a change reporter and reports a dependent care increase on March 21st but did not supply verification. Verification of his new dependent care expense is requested late, on March 23rd. Rich provides the verification on April 2nd. This change will be effective for April’s benefits and a supplement will be needed. Example: Using the previous example, Rich does not supply the dependent care verification until April 6th. Act on the change by April 16th to affect May’s benefits. No supplement is issued for April, due to Rich’s failure to return the verification within 10 days. If verification is required or deemed necessary and the client fails to return the verification within 10 days after the change was reported, but does provide the verification at a later date, act on the change within 10 days after the verification is provided. Benefit Decreases: If the reported change will decrease the bene- fits or make the household ineligible, action must be taken, and a notice issued to the client within 10 days of the reported change. Example: Debra calls on March 22nd and reports a group member left the home which will reduce the group's benefits. Act on the change and issue the benefit decrease notice by April 1st. The change will be effective for May’s benefits. Example: Mary calls on March 19th to report a decrease in her dependent care expense. The specialist send's a VCL requesting verification of the new expense. Even though Mary must be allowed 10 days to return verification of the decreased dependent care expense, act on this change and issue the negative action notice by March 29th. If the verification is not returned within 10 days, begin a second negative action to remove the expense completely. EFFECTIVE DATE OF CHANGE All Programs Bridges evaluates the following dates entered in data collection to determine positive action dates, negative action dates and effective dates: • Circumstance start/change date.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Reported on. • Verification received on. • Date client became aware. FIP, RCA, SDA and FAP Only See Bridges Eligibility Manual (BEM) 505, Prospective Budgeting/Income Change Processing, or policy regarding effective dates for income changes. FIP, RCA and SDA Only See BEM 515 FIP/RCA/SDA Budget, for policy regarding effective dates for member adds. CDC Only Act on reported changes as soon as possible, but act within the standard of promptness; see STANDARDS OF PROMPTNESS in this item. The day a reported change is acted on is not always the day the change must take effect. Example: A client had prior pay periods certified for CDC. The client failed to timely report an increase in income that exceeded the income eligibility scale for the family size. If the income is not temporary excess income, rerun eligibility. Bridges will generate zero approved hours or an overpayment. The client will then be denied the pay period after the change occurred for excess income. Note: Determine if the increase is temporary excess income or is expected to continue; see BEM 505. Positive Actions can be entered on Bridges to affect current, future, and past CDC pay periods. First determine the positive action date. If the change was reported timely (within 10 calendar days), for example a change in providers, the positive action date is the day the change occurred or is expected to occur. If the change was reported late, the positive action date is the day the change was reported. Positive actions take effect on the positive action date. Exception: Family contribution decreases, that are not a result of a provider receiving a higher star rating/quality level are positive actions and affect the first CDC pay period that begins on or after the positive action date.
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Note: For a new or changed authorization to take effect on the positive action date, begin it the first day of the CDC pay period that contains the positive action date. Negative Actions: If timely notice is required, the negative action date must be the first workday at least 11 days after the notice was sent, or the date the change is expected to occur if that is later. If adequate or no notice is required, the negative action date is imme- diate (the day action is taken on the change), but not before the change is expected to occur. The following negative changes entered on Bridges take effect as follows: • Family contribution increases tied to a provider change are a negative action and take affect the first CDC pay period that starts on or after the negative action date. Note: An income eligible child assigned to a 3 star/Enhancing Quality or higher provider will have their FC amount waived. During the 12-month continuous eligibility period a change to a provider with 2 star/Reflecting on Quality or lower rating/quality level (or a change in the currently assigned provider’s star rating/quality level) will result in the FC amount no longer being waived. For additional family contribution and star rating/quality level details; see BEM 706, CDC Payments. • CDC case closures and member removals (for example removing an eligible child) take effect on the negative action date. FAP Only For non-income changes, complete the FAP eligibility determination and required case actions in time to affect the benefit month that occurs 10 days after the change is reported. See BEM 212, Food Assistance Program Group Composition, and BEM 550, FAP Income Budgeting, for policy regarding effective dates for member adds. The benefit month cannot be earlier than the month of the change. Example: A $30 shelter increase reported on May 15th would increase the household’s June allotment. If the same increase were reported on May 28, the household’s allotment would have to be increased by July. (The 10th day following May 28 would be June 7.) However, the first month we can affect is June, provided the action on the shelter change is completed by May 31st.
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PROCESSING CHANGES All Programs Enter all changes in Bridges by changing the affected data ele- ments. Certify the eligibility results in Bridges for all appropriate benefits and benefit periods. Negative Actions A negative action is identified in Bridges with notice reason(s) in eligibility results. Negative actions include: • Decrease in program benefits, including case or EDG closure. • Special living arrangement client pay increase. • Inactivation of an eligible group member. • CDC family contribution increases tied to a provider change. • Change in payment method to restricted payment (no code needed). Termination of a member's medical eligibility (member remains active but not medically eligible). • Medical coverage cancellation or reduction. • Inactivation resulting in a FAP benefit increase is not a FAP negative action. • Patient-pay amount initiated (unless this occurs on the day of case opening). • Post-eligibility patient-pay amount increase. • Changing the PET code to a divestment penalty code; see BEM 405, MA Divestment. FAP Only Reducing a FAP group's benefits at redetermination is treated as a positive action because the change affects the new certification, not the current benefit period.
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CDC Only For CDC when a foster child is adopted by the child's current foster parents during the 12-month continuous eligibility period, CDC should remain open until redetermination with no negative action taken on the CDC EDG. Assistance from the Bridges Resource Center (BRC) is required. During 12-month continuous eligibility, complete a case correction, including those constituting negative actions, when initial eligibility or redetermination was completed in error or when it is discovered that inaccurate information was provided by the applicant. Notice Reasons All Programs The notice reason(s) in Bridges indicates the reason for the action. NEGATIVE ACTION DATE Bridges automatically calculates the negative action effective date. The negative action effective date in Bridges is the day after the timely hearing request date on the Bridges notice of case action. Timely Hearing Request Date The timely hearing request date is the last date on which a client can request a hearing and have benefits continued or restored pending the hearing. It is always the day before the negative action is effective. Immediate Negative Actions (Adequate Notice) An immediate negative action occurs when the negative action requires adequate notice based on the eligibility rules in this item. Adequate notice means that the action taken by the department is effective on the date taken. Exception: For CDC adequate notice means that the action taken by the department is effective on the date of the Circumstance Start/Change Date (CSCD).
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Pended Negative Actions (Timely Notice) A pended negative action occurs when a negative action requires timely notice based on the eligibility rules in this item. Timely notice means that the action taken by the department is effective at least 12 calendar days following the date of the department’s action. ACTIONS NOT ALLOWED BY LOCAL OFFICES Bridges automatically sets all negative action effective dates based on the rules for each program and the date the action is processed in the system. Occasionally there is a need to affect a negative action with less than 12 days' notice (11 days added to the current date). An exception may be requested for the specific program. Fol- low the procedure for requesting exceptions found in BEM 100, Introduction. The program office will validate the need for the exception and forward the request to the appropriate staff to enter the override in Bridges. DELETING A NEGATIVE ACTION All Programs Negative actions must be deleted from Bridges in some situations. Hearing Requests Record the hearing request date and complete all required informa- tion on the Hearings Restore Benefits screen in Bridges. Then follow Additional Steps to Delete a Negative Action in this section; see BAM 600. Requirement Met Before Negative Action Effective Date Enter the information the client provided to meet the requirement that caused the negative action, using the appropriate Bridges screens. Then follow Additional Steps to Delete a Negative Action in this section.
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Additional Steps to Delete a Negative Action Take these additional steps to delete a negative action in Bridges: • Reactivate the program(s) on the Program Request screen in Bridges. • Run eligibility and certify the results. Bridges will automatically recalculate benefits based on the information and dates entered in the system; see effective date of change in this item. BENEFIT SUSPENSION FIP, RCA, SDA and FAP Only Benefit suspension means stopping program benefits for one month due to temporary ineligibility when allowed by policy. Document the reason(s) in the case record. To suspend benefits for one month, check the Temp Inelig box on the initial eligibility results screen in Bridges before continuing to the certification screen. Do not check the box if ineligibility will continue beyond one month. This option is not available in Bridges if the previous month’s bene- fits were suspended. If timely notice is required, the date of the first benefit credited must be later than 11 days from the date the MDHHS-176, Benefit Notice, is sent. FIP, RCA and SDA Only If suspending cash assistance benefits, notify any shelter vendor(s) for the case that vendor warrants will not be produced for that month. The client is responsible to pay any vendors directly. CDC MEMBER ADDS No application is required for a Member Add when adding a child or an adult (P/SP) during the 12-month eligibility period.
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When a client reports a new person in the home, determine if any actions must be taken and document the case. Complete a telephone interview and inform the head of household that they must report if assets exceed $1 million and if income exceeds the eligibility limit by family size on the CDC Income Eligibility Scale; see RFT 270. When adding an adult group member, document the request in case comments and enter the following information in Bridges: • Relationship. • Citizenship/non-citizen status. • Absent parent status (if applicable). • Need reason (if applicable). • All income. • Any other information necessary to determine eligibility. If the adult being added during the 12-month eligibility period does not have a valid need reason, and they are the parent of one or more CDC eligible children, CDC should remain open for the children until the next redetermination. At the next redetermination, both P/SPs must have a valid need reason. When adding a child, inform the client that a new MDHHS- 4025, Child Development and Care (CDC) Provider Verification, is required to add a provider assignment for the child and send the client the form. Document the request for CDC in case comments and enter the following additional information in Bridges: • Citizenship/non-citizen status. • Absent parent information, if applicable. • Age exception if the child is 13 through 18 years old. • Confirm the child meets the immunization requirement. • The child’s income. • Foster care status (if applicable). • Joint custody status (if applicable). If CDC is active and requested for an additional child, and the parent/substitute parents (P/SPs) currently in the home were part of the most recent eligibility determination, changes in income, need reason and hours will not impact CDC eligibility and verifications should not be requested for CDC. The new child’s authorizations should be based on the most recent CDC eligibility determination.
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If CDC is active and requested for an additional child, and that child has a P/SP in the home who was not part of the most recent eligibility determination, the new P/SP must verify all required eligibility factors to make an eligibility decision for the added child. If the reported changes will result in a negative action, other than those on the CDC EDG Closure Reasons list, document the case and address at the next Redetermination. If reported changes result in a positive action, make the changes, document and certify. Note: Currently authorized children should not be negatively impacted, except for valid closure reasons. See CDC EDG Closure Reasons in this item. Example: CDC is open for Child A, and Child A's mother (only P/SP) and her Living Together Partner (LTP) are in the home. The mother and her LTP wish to add a new child-in-common (Child B) to the CDC program. The LTP is a P/SP to Child B, a required program group member, and was not a part of the most recent CDC eligibility decision. Therefore, the LTP must verify all required eligibility factors at member add to authorize CDC for Child B. If the LTP does not have a valid need reason, Child B is not eligible for CDC, and the CDC redetermination would not be extended. CDC Redetermination Extension: When a child(ren) is added to an active CDC program, the redetermination is to be extended, allowing for a full 12 months of continuous eligibility for the newly added child(ren), which will also extend CDC for any other child(ren) already active in the program. CDC can be extended twice before completing a redetermination. A redetermination must be completed prior to granting three or more extensions. If a request for a third extension is received prior to the redetermination, a policy exception must be requested. Policy exception requests should be sent to Policy-CDC@michigan.gov. Upon adding a child to an existing CDC program, the Extend CDC screen will need to be completed by checking the Extend CDC box. This will extend the CDC redetermination date for all active children. For children who turn age 13 after the CDC redetermination has been extended, Bridges will auto remove them from the CDC program once they turn age 14.
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Note: Before adding a provider assignment to a newly added child, obtain a new MDHHS-4025. Example 1: In October 2025, a newborn is added to an existing CDC program with three children already approved. The newborn is added to the case four months after the last Redetermination date (June 2025). CDC will be extended for all existing children on the case. CDC is now approved for all the children through October 2026. The 1010 for the case will now go out in September 2026. Example 2: CDC was originally approved in November 2024. In June 2025, a newborn is added to an existing CDC program with two other children, ages 10 and 12. The 12-year-old does not require constant care. The 12-year-old’s birthday is in October 2025. CDC will continue to be approved for the eldest child until the following Redetermination. CDC will now be approved through June 2026 for all the children. If an additional extension is not requested prior to the June 2026 redetermination, the eldest child will be removed at redetermination due to being over age 12 and not requiring constant care. If CDC is extended, and a child is 13 at the time CDC is extended, CDC will automatically end for that child with the pay period prior to the child turning 14 years old or at the next Redetermination, whichever comes first. Example 3: A family is approved for CDC for two children and was approved in January 2025. In May 2025, the family accepts a Foster Care child and requests this child is added to their active CDC program. CDC will now be approved through May 2026. In August 2025 the foster child is removed from the home and placed with another family. CDC for the family’s other two children will continue to be approved through May 2026. Example 4: A family was approved for CDC in January 2025 with two children. In March 2025 a newborn is requested to be added to CDC (1st extension). All three children will now have their
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redetermination extended to March 2026. Later in the year, a request to add a niece to the active CDC beginning June 2025 was granted (2nd extension). All four children will now have their redetermination extended to June 2026. In February 2026 a foster child was requested to be added to the CDC program (3rd extension request). Send a policy exception request to Policy-CDC@michigan.gov. Note: For Example, #4, if the request to add the foster child came in during the June 2026 redetermination, do not extend CDC but follow the normal redetermination process. If approved, the group’s next redetermination is June 2027. Adding a new member may impact CDC eligibility. If there are changes in eligibility, timely reporting and processing will determine when the change occurs; see Effective Date of Change in this item. SHORTENING A 24- MONTH FAP BENEFIT PERIOD FAP Only Bridges shortens the 24-month benefit period for ongoing groups who have more than 12 months left in their benefit period and either: • Report having earned income. • Unearned income (other than RSDI and/or SSI. • Report an individual joining the group who is not SDV. Whenever any of the above occur, Bridges does the following: • Sets the end date to 12 full months from the processing date. • Issues a DHS-1605 explaining simplified reporting, household income limit and the new shortened benefit period end date. • Issues a DHS-1045, Simplified Six-Month Review. For groups whose 24-month benefit period has 12 months or less remaining at the time the change is first reported, Bridges assigns the group to the SR category, but does not shorten the benefit period. The current benefit period end date must be retained even though the end date is 12 months or less. If the group remains SR
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eligible at redetermination, Bridges assigns a new 12-month benefit period. Example: On August 7, 2022, Risa reports her husband returned to the group and he receives unemployment income. They are change reporters and have a 24-month benefit period with an end date of May 31, 2023. On August 17, 2022, the specialist processes the change, and the group becomes SR. Bridges issues a DHS-1605 which provides the simplified reporting requirements, and a DHS-1045. The end date remains May 31, 2023, since the group has less than 12 months remaining in their benefit period. SSI CASE ACTIONS
SSI Openings and Changes FIP, RCA, SDA and MA Only Bridges generates tasks that provide SSI data reported by the Social Security Administration (SSA) on the State Data Exchange (SDX) system. Bridges acts on specific HR-070 information to prevent benefit duplication or mispayment. SDA Only Take appropriate action based on a Bridges Task that SSI benefits have started or changed. Enter amounts from the SSI AMOUNT and SSI ELIG SDX interface fields from the SDX interface to recalculate SDA eligibility and benefits. Note: Whenever the SSI benefit changes, a task will be generated for SDA cases containing SSI recipients. FIP Only Persons cannot receive FIP and SSI at the same time. Also, central office cannot open a manual SSI case for an SSI recipient who is a certified group member in a FIP EDG. Run EDBC to remove the SSI recipient from the FIP certified group.
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MA Only See BEM 150, MA For SSI Recipients. FAP Only Enter the ongoing SSI benefits as unearned income. SSI APPLICATION DENIALS SSI-Related MA Only The SDX reports SSI denials and appeals. See Exhibit III in BEM 260, MA Disability/Blindness, lists the specific codes needed to identify appeals and disability/blindness denials. Eligibility for MA based on disability or blindness does not exist if the SSA disability determination is final as defined in BEM 260. Enter appropriate appeal information in Bridges. If the client is no longer eligible for disability-related MA, Bridges will explore other MA categories. If the client is not eligible for any, Bridges will close the MA. If the client qualifies for a category but must meet a deductible, Bridges will close MA based on disability and open an active deductible EDG under the new MA category. Timely notice of benefit reduction or closure is sent by Bridges. SSI Terminations MA Only Central office closes SSI MA when SDX indicates SSI benefits are terminated. Bridges sets a redetermination date and continues MA eligibility when SSI stops. Continue the beneficiary's MA coverage until the redetermination is completed. The redetermination does not need to be completed if the beneficiary's SSI is reactivated in a subsequent SDX batch. In most cases this is a local office responsibility; see BEM 150, MA for SSI Recipients.
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DEATH NOTIFICATION All Programs A reliable source must verify a recipient's death before action is taken on a case. Reliable sources generally include death notices in newspapers, friends and relatives of the client, and other agencies. The verification source is entered in Bridges for the date of death. CDC Only Report all deaths of children while in the care of a child care pro- vider; see SRM 172, Child/Ward Death Alert Procedures and Time- frames, for specific reporting instructions. EX PARTE REVIEW MA Only An ex parte review (see glossary) must begin at least 90 days (when possible) prior to the close of any Medicaid Type of Assistance. • When the ex parte review shows that a recipient does have eligibility for Medicaid under another category, change the coverage. • When the ex parte review shows that a recipient may have continuing eligibility under another category, but there is not enough information in the case record to determine continued eligibility, send a verification checklist (including disability determination forms as needed) to proceed with the ex parte review. If the client fails to provide requested verification or if a review of the information provided establishes that the recipient is not eligible under any MA category, send timely notice of Medicaid case closure. • When the ex parte review suggests there is no potential eligibility under another MA category, send timely notice of Medicaid case closure. When it is determined that a recipient will no longer meet the eligibility criteria for FIP-related Medicaid, because of an actual or anticipated change, determine whether the recipient has indicated
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or demonstrated a disability (see glossary) as part of the ex parte review (see glossary). • If the ex parte review reveals the recipient has already been determined disabled for purposes of qualifying for a disability- based Medicaid eligibility category, by the SSA or the department, and the determination is still valid, continue the recipient’s Medicaid eligibility under the disability-based Medicaid category for which the recipient is otherwise eligible. • If, during the ex parte review it is determined a recipient has indicated or demonstrated a disability, request from the recipient additional information needed to proceed with a disability determination. Pending the determination, continue the recipient’s Medicaid. If the recipient fails to provide the information requested after being given a reasonable opportunity to do so, and eligibility under all other categories has been ruled out, send timely notice of Medicaid case closure indicating the person is not eligible for disability based Medicaid as well as FIP related categories. If, following the disability determination process, the recipient is determined to not be disabled for purposes of qualifying for disability-based Medicaid categories and eligibility under all other categories has been ruled out, send timely notice of Medicaid case closure indicating the person is not eligible for disability-based Medicaid as well as FIP-related categories. If, following the disability determination process, the recipient is determined disabled for purposes of qualifying for disability-based Medicaid categories, continue the recipient’s Medicaid under the disability-based Medicaid category for which the recipient is otherwise eligible. Medicaid coverage will continue until the client no longer meets the eligibility requirements for any other Medicaid TOA. CASE CLOSURE All Programs (Except SER) When a recipient is no longer eligible or requests case closure, do all of the following:
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• Enter all appropriate information, including verification sources, in Bridges to document ineligibility, or the client’s request that the program(s) be closed. • Run EDBC in Bridges and certify the eligibility results. • Make appropriate referrals for other programs or services. CDC EDG CLOSURE REASONS The following are valid reasons to end CDC benefits during the 12- month continuous eligibility period: • Client requests closure. • Substantiated welfare fraud or IPV sanction. • Loss of Michigan residency. • Income exceeds the eligibility scale in RFT 270, and the income increase is not Temporary Excess Income; see BEM 505. • Only authorized child ages out or leaves the household; see BEM 240, Age, for age requirements. • Only P/SP on the case leaves the household (no longer resides with the authorized child). • Minor parent, active on legal guardian's case, turns 18. • Assets exceed $1 million. • A case correction that results in closure. CASE ACTION NOTICE FORMS FIP, SDA, RCA, CDC and FAP Bridges sends the appropriate notice based on the case action taken. Notices are sent to Spanish or Arabic-speaking clients using a Spanish-Arabic form, if available, and if the client has indicated Spanish or Arabic as the household’s written language.
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A notice must be generated manually in those situations in which Bridges is not able to generate a notice, as identified in this item. APPLICATION APPROVALS/ DENIALS All Programs The following notices are used to notify the client of an application approval or denial. The DHS-1150, Application Eligibility Notice, is generated for with- drawals entered on the Program Request screen prior to data col- lection/intake. The DHS-1605, Notice of Case Action, is generated by Bridges for automated eligibility determinations. MA Only A DHS-114, Deductible Notice, is generated when MA is approved with a deductible. A DHS-1606, Health Coverage Notice, is generated when Medicaid is approved or denied. See BEM 402, Special MA Asset Rules, for policy on notices to send regarding asset transfer information and the results of an initial asset assessment. POSITIVE CHANGES All Programs Bridges automatically generates a DHS-1605, Notice of Case Action, to notify the client of the results of the Bridges automated eligibility determination. The results for all programs are included on a combined notice. NEGATIVE CHANGES AND CASE CLOSURES All Programs Bridges generates a combined DHS-1605, Notice of Case Action, for all programs. A DHS-1606, Health Coverage Notice, is
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generated for Medicaid. Other notices are either generated by Bridges or must be manually completed and sent in the specific circumstances listed below. FIP, RCA, SDA and FAP Only Bridges generates the following notices when a claim is created: • DHS-4357, Client Notice of Disqualification and/or Recoupment. Note: The DHS-4357 is only generated by the Overpayment Establishment Analyst. • DHS-4358, Notice of Agency or Client Error Overissuance and Recoupment Action. FIP and MA Only Send a DHS-301, Medical Transportation Notice, if a request for medical transportation is denied. MA EXCEPTIONS UNIT Certain Bridges transactions must be processed through the Exceptions Unit in MSA. The MA exceptions unit mailbox is MDHHS-EXCEPTIONS@michigan.gov. The Exceptions Unit Mailbox will accept and assist the Specialist with the following requests: • Correcting Begin/End dates for PETs beginning with MIC, ING, and EXM. • Correcting PETs beginning with ICO (if the provider ID is a LTC facility instead of ICO plan provider ID). • Patient Pay Amount (PPA) changes. • Specialist must include the following information in the email request: • Beneficiary name. • Beneficiary ID. • Beneficiary case number. • Description of what needs to be updated in Bridges and why.
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• Local office staff may need to generate correspondence to support the exception request such as for an increase in a PPA. Security codes are no longer needed. Please allow up to 2 business days for the request to be completed. LEGAL BASE FIP Social Welfare Act, PA 280 of 1939, as amended Mich Admin Code, R 400.902 RCA 45 CFR 400 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016. SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 MA 42 CFR 431.200-.250 42 CFR 435.912-.913, .919 FAP 7 CFR 273.12-.13, .21
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DEPARTMENT POLICY All Programs The paper case record consists of a folder, arranged in packets and identified by a client name, recipient ID or case number, established for a particular client group. The case record contains all forms, documents and other evidence relevant to the group's current and past eligibility. The electronic case file (ECF) consists of scanned documents, arranged by category and identified by a client name, recipient ID or case number, established for a particular client group. The ECF contains all forms, documents and other evidence relevant to the group's current and past eligibility. Policy in this item explains what must be in the case record (both paper and electronic) and provides guidelines for organizing it. All local offices must follow a uniform system of records with the minimum content and organization described in this item. This ensures that material is recorded and filed in a manner readily available and understandable to all Michigan Department of Health and Human Services (MDHHS) staff who use it. Documents (including MDHHS forms), notices and other written correspondence regarding the group's eligibility, benefit status or benefit level that are produced in Bridges can be retained in Bridges and do not need to be copied into the case record. Electronic documents are routed to Bridges for viewing and storing based on levels. Document levels are divided by case level, individual level, or provider level. Individual level documents will be viewable in all cases associated to the individual. Documents provided by the client or produced in Bridges that con- tain pertinent information in determining eligibility must be in the case record. Examples include: • Birth registry verification. • Consolidated inquiry information (CI). • Child support information. • Unemployment benefit information (UCB). • Pay stubs.
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• MDHHS forms returned to MDHHS completed with requested information. For MA only, if a single application form and other documents are used for persons with separate case numbers (example: spouses), the local office has the option to maintain separate case records by copying or cross-referencing the materials. Unless captured in Bridges the case record must document all of the following: • Date of application and, for MA only, date of a request for initial asset assessment, if applicable. • Date and basis for disposition of the application/request. • Facts essential to the eligibility determination. • Amount or level of benefits. • Actions taken by the local office regarding the case. DEFINITIONS Active Case Record Record is pending or open for current benefits. Case Filing Loose documents, verification etc. that need to be placed within a packet in the case record. Case Packet A group of information placed together for easy reference. The first page of each case packet is a DHS-3524 Bridges, Case Record Packet Cover Sheet, that identifies the type of packet; see packet types in this item. Exception: • The first page of the Employment Packet is a DHS-3524 BE, Employment Packet Cover Sheet. • A DHS-1372, Overissuance Packet, is used as the cover sheet for an overissaunce packet.
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Case Record Documents and information related to a given case (one or more programs) arranged in a series of packets and contained in a folder identified by a case name, grantee ID, or case number. Closed File Area A place designated by the local office where closed records and denied records are stored. Note: In many local offices both closed and obsolete records are stored in the same location. Closed Record Complete case record that has no active programs. Case record that is in a holding area (usually called closed files) waiting for either the retention period to expire or for the client to reapply. Example: When an individual/family loses eligibility for all programs the complete case record is sent to closed files. Obsolete Case information that is no longer in use and is not essential to support current eligibility and benefits. Store in chronological order. Example: Jane Doe is active for FAP and FIP, she has been active for a number of years. The documentation used for eligibility in previous years is no longer needed, this information can be placed in the obsolete packet. Keep in mind the original MDHHS- 1171, Assistance Application, and any program specific supplement form(s), (from this concurrent benefit period) along with the current MDHHS-1171 and any program specific supplement form(s) should remain in the eligibility packet. Example: Jane Doe received benefits in Michigan until last year when she moved to Florida. At the time of the move her case was closed and the case record was sent to closed files. Today she moved back to Michigan and applied for assistance. The closed file will be removed from the closed file area and given to the FIS/ES. If she is found eligible for benefits the FIS/ES will send all information not needed for current eligibility to obsolete files.
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Confidential Nature of Case Records Federal and state laws restrict the use and release of client information; see BAM 310, DEPARTMENT POLICY. Record Retention Paper, ECF No case record material can be removed and/or destroyed unless MDHHS policy regarding retention and disposal is met. The Department of Technology, Management and Budget has general instructions for record management at www.michigan.gov/records management. Specific local office requirements are found on the MDHHS-Net under Toolbox / MDHHS Record Retention and Disposal Schedules and Records Management Manual. PACKETS/TABS Paper case records must have information organized into packets. Each case record will have an eligibility packet and a vital statistics packet. The other packet types, such as; child development and care, emergency programs, incorrect issuance (recoupment), legal and medical will be required if it pertains to the case record. The ECF has information organized into tabs. Each record will have an application tab and a vitals tab. Other examples of tabs include income, assets, etc. Documents in the ECF are stored chronologically from oldest to newest. Eligibility Packet Paper The first page of each packet is a DHS-3524, Case Record Packet Cover. Fasten packets in the upper left corner. Generally, material is to be filed chronologically, the most recent information at the back of the packet. Use this packet for information related to current eligibility and benefit amount. File certain documents in the vital statistics packet. Place the following eligibility material (when applicable) in the order listed below:
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• The most recent assistance application such as MDHHS-1171, any program specific supplement form(s), Filing Form, completed DHS-2063B, Food Assistance Benefits Redetermination Filing Record, if returned. These forms must remain in this packet as long as the case is open. If the case closes and reopens, move these forms to the obsolete packet. • Copies of all materials used at the most recent case opening (except vital statistics-related materials). Group these by type (such as: asset-related). Other than income verification, keep these in this packet as long as the case is open. If the case closes and reopens, move any material no longer relevant to the obsolete packet. The application form used in the most recent redetermination. File it in the obsolete packet when it is no longer current. Documentation of client contacts from home calls or office visits relating to current eligibility. Move docu- ments no longer related to current eligibility to the obsolete packet. • Copies of all materials used in the most recent eligibility determination (such as: member add, redetermination) except documents filed in the vital statistics packet. Group these by type. • Copies of all documentation of budgetary needs unless stored in Bridges. Move these to the obsolete packet when no longer current. • Current income documentation. Move documentation to the obsolete packet when no longer current. • Copies of all documentation regarding audits or correspondence with The Quality Assurance Division. • All documentation pertaining to direct supportive services. • Place FIP/SDA worksheets showing an ongoing recoupment amount in the obsolete packet when recoupment is complete; see incorrect issuance packet in this section. • Place FIP/SDA worksheets showing an:
Overpayment amount in the overissuance packet/tab.
Underpayment amount in the eligibility packet. Underissuance:
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DHS-13, Supplemental Payment Authorization.
HDS-521, Notification of Restoration Letter.
DHS-1172s, FIP/SDA Worksheet or LOA2 Worksheet, showing the under-issuance.
DHS-3925, Restoration of Lost Food Assistance Benefit, or LOA2 OI/UI summary.
Plain paper with the under-issuance calculation, if needed.
Correspondence and other documents related to the supplementation. At the local office option, under-issuance materials may be placed I the obsolete packet after the client supplement is issued. ECF The ECF does not contain an eligibility packet/tab. Documents are stored under the appropriate tab. Vital Statistics Packet Paper, ECF Use this packet for documents expected never to (or only infre- quently) change, even after closures and reopenings. Include the following for each group member unless an item is more useful in the eligibility packet: • Adoption records. • Alien registration card. • Birth certificate. • Death certificate. • Divorce decree. • Driver's license or other ID card. • Social Security card. • DHS-8A, Irrevocable Funeral Contract Certification. • Marriage certificate. • Naturalization records. • Passport. • Paternity records. • Power of attorney/guardianship papers. • Prepaid funeral contract.
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• Special MA category verification • Support order (most recent). • Americans with Disability Act (ADA) documentation. • Need for translator or material to be translated; DHS-848, Certification of Translation/Interpretation for Non-English Speaking Applicants or Recipients. State Emergency Relief (SER) Program Packet Paper This packet is required for all State Emergency Relief (SER) requests and approvals; see ERM 405, SER Case Record. ECF The ECF does not contain an SER packet/tab. Documents are stored under the appropriate tab. Medical Paper, ECF Use this packet for all medical reports, forms, correspondence, etc., regarding medical eligibility including items related to current eligi- bility or benefits. File all SSI referral and advocacy-related forms in the medical packet. Any client that has an active or pending pro- gram that is based on a medical determination, such as: State Dis- ability Assistance (SDA), Medicaid due to disability or blindness, or a Family Independence Program (FIP) case where there is a claim of disability, the medical packet and all medical documentation must stay in the active case record. Example 1: If a case closes and the client reapplies for a program that is based on a medical decision the complete medical packet must remain in the active case record and all new medical evidence must be added to the medical packet in chronological order. Example 2: Client is active for a program based on disability and they are approved for Supplemental Security Income (SSI) or Retirement Survivor Disability Insurance (RSDI) (based on their own disability) the medical packet can be sent to obsolete/closed file area. Example 3: Client had a case based on a medical determination Example: SDA or Medicaid based on disability or blindness, or a
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FIP case where there was a claim of disability and the client is no longer active or pending for that program, the medical packet can go to obsolete/closed file area. Examples would include a FAP or Child Development and Care (CDC) only case. However if this client re-applies for any program where a medical determination is necessary, the existing medical packet would need to be placed back into the active case record and the new medical information would be added to the packet in chronological order. Legal Packet Paper, ECF Use this packet for all document, forms, correspondence, client signed agreements, etc., regarding legal matters, bankruptcy and administrative hearings, including items related to current eligibility or benefits. Never obsolete materials in this packet. Note: All hearing decision and orders, court actions, notices of intentional program violation, intentional program violation repayment agreement and all other documents that result in an IPV must never be obsoleted. The Michigan Office of Administrative Hearings and Rules (MOAHR), courts and the Office of Inspector General (OIG) must have documentation on all past IPVs to impose a sequential disqualification. Employment Packet Paper Use this packet for all information pertaining to the following: • Direct support service purchases that have a lifetime maximum. Bridges will track all purchases made in Bridges, however all life time purchases made prior to Bridges will need to be maintained in this packet. • Work participation program information that is not maintained in Bridges and information printed from Bridges and entered into evidence at a work participation program related hearing. • Work participation program penalty tracking information. Administrative law judges (ALJs) will require verification of all prior penalties before giving the next higher penalty.
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ECF The ECF does not contain an employment packet/tab. Documents are stored under the appropriate tab. Child Development and Care Packet Paper Use this packet for all case information related to provision of CDC services. CDC case information in this packet may be obsoleted at case review, however the original application and supporting verifications from the most recent case opening must be maintained in the case record. The retention period for CDC case information is four years after CDC case closure to conform with federal audit requirements. ECF The ECF does not contain a CDC packet/tab. Documents are stored under the appropriate tab. Child Development and Care Provider File Effective January 1, 2013, all license exempt provider enrollments and associated files are completed and maintained by the Child Development and Care (CDC) office at the Michigan Department of Lifelong, Education, Advancement, and Potential (MiLEAP). License exempt provider applications or verifications that are received in the local office should be date stamped and faxed to the CDC office at 517-284-7529. Local offices should retain the information for 90 days from the date it was faxed. After the 90 day retention period, the information can be destroyed. MDHHS is responsible to retain all active license exempt provider files that were enrolled by local offices prior to January 1, 2013. License exempt provider applications or documents should be retained for three years after the date of inactivity or closure.
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Overissuance Packet Paper, ECF Use this packet for documents related to benefit overpayments. All hearing decisions and orders, court actions, notices of intentional program violation, intentional program violation repayment agreements and all other documents that result in an intentional program violation disqualification must never be obsoleted. The Michigan Office of Administrative Hearings and Rules (MOAHR), courts and the Office of Inspector General (OIG) must have documentation on all previous intentional program violations to impose a sequential disqualification. Note: The overissuance packet/tab (OI) is restricted to recoupment specialists only for entry and deletion. Never obsolete these records. Note: Fee referrals/dispositions belong in the current eligibility tab. Never obsolete these records. Cross-reference the legal packet when needed. Group all material chronologically that relates to the same incorrect issuance. This can include: • Overissuance (OI):
ARS and BRS overissuance history.
DHS-234, Release Plan.
DHS-1172s, FIP/SDA Worksheet; see Eligibility Packet in this item.
DHS-1835C, Fraud Investigation Disposition Report.
DHS-2242s, FAP Worksheet, or LOA FAP Worksheet showing the OI amount.
DHS-4355, Agreement to Repay Debt.
DHS-4357, Intentional Program Violation Client Notice.
DHS-4358, Notice of Agency or Client Error Overissuance and Recoupment Action.
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DHS-4358-A, Notice of Overissuance.
DHS-4358-B, Agency and Client Error Information and Repay Agreement.
DHS-4358-C, Overissuance Summary.
DHS-4358-D, Hearing Request for Overissuance or Recoupment Action.
DHS-4701, Overissuance Referral.
Plain paper with the OI calculation, if needed.
OI-related hearing decision, withdrawal or note that the client failed to show for the hearing.
OI-related correspondence and other documents
Debt collection hearing decision and related documents. Do not obsolete overissuance documents until four years after the overissuance event is paid off or written off. Note: Documentation listed above generated by the recoupment specialist or designed staff person must be forwarded to the case record as soon as administratively possible. • Underissuance:
DHS-13, Supplemental Payment Authorization.
DHS-521, Notice of Restoration Letter.
DHS-1172s, FIP/SDA Worksheet, or LOA Worksheet, showing the underissuance.
DHS-2242s, Food Assistance Program Worksheet, or LOA FAP Worksheet, showing the underissuance.
DHS-3925, Restoration of Lost Food Stamp Benefit, or LOA OI/UI Summary.
Plain paper with the underissuance calculation, if needed.
Correspondence and other documents related to the supplementation. At local office option, underissuance materials may be placed in the obsolete packet after the client supplement is issued.
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Note: The incorrect issuance (OI) packet/tab is restricted to recoupment specialists only for entry and deletion. Obsolete Packet Paper, ECF Use this packet for information no longer in use and not essential for current eligibility. This includes forms documenting MDHHS actions which are immediately obsolete (such as, retro MA determination). Place the date the case record became obsolete on the case packet cover sheet prior to sending the material to obsolete files. Note: A purge anytime on or after date can be added on the cover sheet if known. Do not file evidence of ongoing recoupment, legal materials, or ini- tial asset assessment documentation in this packet. Establish a separate obsolete folder if this packet grows too large for the case record. Identify the folder by client name and/or case number and the word obsolete. Initial Asset Assessment Packet Paper, ECF Use this packet for documents and verification related to an initial asset assessment; see BEM 402. Such material includes: • Verification of the value of the couple's assets. • DHS-4574-B, Assets Declaration. • DHS-4585, Initial Asset Assessment and Asset Record. • DHS-4586, Asset Transfer Notice. • DHS-4588, Initial Asset Assessment Notice. Never obsolete materials in this packet. OTHER CASE RECORDS
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Department Wards Department wards are eligible for MA. Case information is main- tained in children's services case records. Retro MA determinations must be filed in those services records; see BEM 117. SSI Cases Establish a case record when central office opens SSI Medicaid based on information from SSA. It will not contain an application or eligibility packet; see BEM 150. Newborns When a separate case is opened for a newborn (such as, mother on Medicaid based on disability or blindness and newborn on Medicaid for newborn), cross-reference the cases. Establish a case record when MSA opens Medicaid for the newborn. File documents in either case record. The newborn's record will not contain an application or eligibility packet; see BEM 145, Newborns. LEGAL BASE FIP 45 CFR 205.60(a)(1) MCL 400.55 (g) CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016. SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180
SER Mich Admin Code, R 400.7001, et seq.
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MA 42 CFR 431.17(b) Food Assistance Program 7 CFR 272.1(f)
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DEPARTMENT POLICY All Programs Local office management resources should be invested in case reading activities. This includes: • Selecting the case. • Completing the review. • Documenting and communicating the findings. • Monitoring and following up. • Planning corrective actions. Overview A process analysis approach to case reading focuses on systems, policy and procedures in an effort to prevent errors rather than just correct them. Case readings collect information to improve the accuracy and effi- ciency of program management and the delivery of services. First and second-line managers, quality analysts, lead workers and other designated local office staff may conduct the readings. Case Review The case review may be either a general, specific or targeted read. A general read is a review of all eligibility factors for the pro- gram(s) read. A specific read is a review of a limited number of eligibility factors identified for a predetermined reason. A targeted read is a review of a limited number of eligibility factors identified by central office for a predetermined reason. The local office determines the need for evaluation and selects the cases for a general or specific read. Process analysis, accuracy of policy implementation, a special project, worker experience, or other reasons may prompt a review. Selection of Cases Depending on the reason for the review, cases are selected at ran- dom using one of the sources listed below. Cases are selected ran- domly by allowing each case an equal chance to be selected. For example, if you are selecting four cases from the RD-093 that lists 20 cases, you could pull every fifth case listed on the report.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Computer-generated reports - list cases with certain identifying characteristics. AL-030 - earned income, automated recoupment, unearned income, etc. RD-093 - redeterminations. MH-132 - approvals and denials. DL-030 - child support rebates. AA-712 - age and school attendance. UB-120 - wage match. HR-070 - SSI information. ED-030 - RSDI information. UB-141 - Unemployment benefits match. • Special Run Reports - used for special projects. • Case Actions - based on the experience of specialists. How To Read a Case A case is reviewed by comparing the actions taken by the specialist to the verification and documentation in the record and determining whether policy was correctly applied in a timely manner. Use form DHS-4331, Assistance Payments Case Reading, to record and communicate the findings. Check the factors listed on the DHS-4331 to determine that all necessary actions were taken. Use the comment section to inform the specialist of any required action and the reason. Post a follow-up for any action to be completed. The comment section is also used to give positive feedback. For some actions, oral communication with the specialist promotes better understanding and offers an opportunity to solicit suggestions for improving systems and processes. Use the Case Reading Guide with the DHS-4331 for consistency in the way factors are reviewed. The guide asks questions for each factor listed on the DSS-4331.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Data Evaluation The information from case reading may be used to identify unmet needs in programs and areas of policy. Local office staff should decide whether policy clarification, policy revision, local office procedural changes or training is appropriate to pursue. General case reading data may also be compiled, summarized and reported upwards. However, a roll-up of case reading data cannot be assumed to be statistically valid due to issues such as lack of a random sample, managers using different selection criteria, and managers using different case reading methods. Targeted case readings may be designed to avoid these problems, through careful planning. INTRODUCTION The case reading guide is intended to help achieve consistency in the way cases are read. The questions are designed to lead the reader to correct case reading results. The case reading guide, along with the DHS-4331, Assistance Pay- ments Case Reading, is a tool to help identify error-prone areas that might require further attention. It is not intended to cover all specific policy situations and exceptions. Likewise, all questions do not apply to every program. A secondary use of this guide is as a self-assessment tool. Michigan Department of Health and Human Services (MDHHS) specialists can use the guide to see whether required case actions were taken. EXHIBIT - INSTRUCTIONS If the question does not apply to the case/program/case action, skip the question. If all questions are answered yes or left blank, no action is required. A no answer to any question in the guide means that some action is required. The required action could be documentation, verification, correct application of policy, clarification of inconsistencies, correct computation of a budget, etc.
BAM 301 4 of 14 AP CASE READING GUIDE BPB 2022-001 1-1-2022
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
A. GENERAL FACTORS
1) Registration/ Application/ Identity BEM 221, BAM 110, BAM 115, DHS-1171 • Is the application signed by the client/representative? Is the application signed by the client's spouse and other adult group members in the home, if physically able? • Is/Are the signature(s) witnessed? • Has the identity of the group members been verified? • Is the application appropriately coded, documented and certified? • Is the application registered timely with the proper date and program code? • Were the registered programs appropriately disposed of within the SOP? 2) Expedited Service (FAP and CDC) BAM 110, BAM 117, BAM 118 • If the household met one of the conditions for expedited services, was the application registered correctly? • If expedited assistance was approved, did the group provide the minimum verification required (identity)? • If the household was eligible for expedited assistance, were the benefits available to the client for FAP or approved for CDC within seven calendar days after the application date?
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3) Authorized Representative BAM 110 • Is the most recent FAP authorized representative who purchases food for the client currently on Bridges. 4) Client Notification Letter(S) BAM 115, MDHHS-176, DHS-1150, DHS-417, DHS-114A, DSS- 4660, NOTICES, SOCIAL CONTRACT, ETC. • Were all appropriate notices sent? • Were the notices completed with manual items, dates, signatures and specific messages where required? 5) Coding BEM 164, 165 AND 545 (MA) BAM 903 • Is the coding consistent with the case record information? 6) Receipt of Benefits BEM 110-156 BEM 222, 547, 554 BAM 110-115, 200, 220, 400, 405, 406, 705, 710, 715, 720, 725 • Were known changes acted on in a timely manner? • Were reported changes reflected in the budget, supplemented or recouped appropriately? • Were the initial benefits issued for the correct period? • Is the MA eligibility begin date correct? • If MA was authorized for a month prior to the month for which the first FIP payment was made, was an MA-only or MA-FAP- only eligibility determination made? • Has receipt of benefits from other programs (FIP, FAP and SDA in the same period, out-of-state, etc.) been checked, to avoid concurrent receipt of benefits? • Are the begin and end dates for the PET codes correct?
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Are the begin and end dates for the patient-pay amount correct? If this is an active deductible case, are the begin and end dates for the deductible amount correct? 7) Pursuit of Benefits BEM 125, 126, 129, 131, 164, 165, 255, 256, 257, BAM 110, 220, 270 • Has the group pursued all potential benefits as required? (RSDI, workers compensation, UCB, etc.) • If the case indicates another responsible party (absent parent/spouse, insurance company, worker's compensation etc.) has a DCH-1354A been completed? If yes, is Bridges coded for Third Party Liability? • At FIP closure or denial, was eligibility for other MA programs (TMA, Special N/Support, Healthy Kids and the Newborn Category, etc.) explored? • If the case contains a pregnant woman or a child, was eligibility under the Healthy Kids categories properly determined? • If the case contains a pregnant woman and she is not eligible for Healthy Kids For Pregnant Women, (BEM 125) was eligibility under Group 2 Pregnant Women (BEM 126) properly determined? • For aged, blind and disabled MA applicants or recipients, was eligibility for QMB, limited QMB and Extended Care properly determined? • If the case contains a disabled, employed person, was eligibility for Freedom to Work properly determined?
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B. HOUSEHOLD COMPOSITION
1) Relationship BEM 215 • If the relationship of each person is not listed on page 3 of the DHS-1171, is it documented elsewhere? • Were questionable relationships verified? • Are all FIP eligible children living with a specified relative or the relative's spouse? 2) Living Arrangement BEM 210, 211, 212, 215, 250 • Was the presence of the FIP eligible child(ren) verified? • Was the absence of a parent(s) verified? • Is it verified that a residential facility placement was temporary, if claimed? Were other questionable absences verified as temporary? 3) Group Composition BEM 210, 211, 212, 213 • Are all mandatory members included in the applicant group, except those who are disqualified or do not meet a nonfinancial eligibility factor? • If there is a disqualified member in the home, is the reason documented in the case and the correct coding on Bridges? • If a disqualification period has ended and the disqualified person has complied with procedural requirements, was the appropriate action taken to add the member to the eligible group? • Do persons listed on the DHS-1171 who are not included in the FAP group purchase and prepare food separately? (This does not include those who meet the criteria for a senior impaired group.)
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• If the household meets the special criteria for separate FAP groups, were the groups determined correctly and the right certification period assigned? • If all FAP group members are recipients of FIP, SA, and/or SSI, has categorical eligibility been correctly determined and coded on Bridges? C. NONFINANCIAL FACTORS
1) Age and School Attendance AGE - BEM 240 • Is the age requirement met for each recipient included in the eligible group? • Is each 18-year-old child included in the FIP group a full-time high school student expected to graduate by age 19? • Was MA eligibility pursued for all applicants under 21 and age 65 or older? School Attendance - BEM 245 • Is each child 16 or over a full-time student or a Work First registrant? (FIP) • Do all food assistance recipients age 18-49, attending post- secondary education, meet student status criteria? 2) Residence/ Citizenship/ Non-Citizen Status BEM 220, 225, 226 • Are all eligible members residents of Michigan? • Do all eligible members intend to remain in Michigan? (Does not apply to FAP, migrants and certain MA programs.) • Does each eligible group member have US citizenship or acceptable non-citizen status?
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
3) Work Registration/ Participation BEM 229, 230A, 230B, 230C, 233A, 233B, 233C. • Do all mandatory clients have the appropriate employment code on Bridges? • Are all deferrals correctly verified and documented using forms similar to the following: DHS-22, Assessment For a Special Needs Child. DHS-26, Daily Schedule, Special Needs Child/Spouse. • Were mandatory registrants referred to Work First using the DHS-2439, Work First Referral, or were clients referred to another employment-related contractor? • Does the case contain the appropriate DHS-4783A and DHS- 4783, Personal Responsibility Plan and Family Contract (Parts I and II)? • If the case contains any act of noncompliance does it contain the following forms: DHS-2444, Notice of Employment-Related Noncompliance. DHS-71, Good Cause Determination. 4) Support (Child And Spouse) BEM 255, 256 • Have the appropriate referrals been submitted? • Have any support disqualifications been processed and coded correctly on Bridges? 5) Enumeration BEM 235 • Does each recipient in the group have a verified SSN on Bridges (special attention to newborns added to FIP case)? Before the first redetermination verification of application for SSN in the case record is sufficient.
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• Has every person for whom cooperation with the enumeration process is refused been disqualified? • If application for a SSN was made at another agency (hospital), did the specialist follow up at redetermination? 6) Disability/ Blindness (MA, SDA) BEM 260, 261, BAM 815 • Has the eligible member's disability been verified? • Have the proper referrals been made? (SSA, MRS, etc.) D. ASSETS BEM 400, 401, 402, 405, 405(A), 406, DHS-1171 • Was the value of reported assets consistent with other case documents, such as DHS-1171, MRS forms, SOS, IRS match? If no, were inconsistencies clarified and documented? • Was the disposition of any asset documented and was divestment considered? • Were any lump sum or accumulated benefits, not counted as income, evaluated as assets? • If there is a responsible relative in the home, was an asset test done? • If the month being tested is an L/H month, have the special MA asset rules in BEM item 402 been applied, if appropriate? • Were all assets evaluated, verified, properly counted and within the asset limit? • Was all asset information recorded on page B of the DHS-1171 or the budget?
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E. NEEDS/EXPENSES
1) Needs BEM 515 BAM 825 • Does the current budget include all eligible members? • If the grantee is an SSI recipient, is the group receiving the correct allowance for the remaining group members? • Is the program type and/or person class coded correctly? • If information in the case indicates the client has a need, was medical transportation explored and documented? 2) Expenses BEM 544, 545, 554, 556 • If the shelter expense includes a housing subsidy, does the food assistance (FAP) budget allow only the client's portion? • Were the correct shelter expenses allowed in the FAP budget? • Is the FAP case properly coded to determine the correct excess shelter allowance for a senior/disabled/veteran (SDV) household member? • For MA, were medical expenses including LTC, personal care, old bills, and current bills used to determine eligibility for past months, the processing month and future months? • For Group 2 MA, was the correct cost of health insurance and Medicare premiums paid by the medical group added to the protected income level? 3) Deductions (Food Assistance) BEM 554 • Are allowable medical expenses deducted for SDV household members? • Are all allowable unreimbursed dependent care expenses being budgeted?
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F. INCOME
1) Earned BEM 500, 517, 518, 530, 535, 540, 541, 545, 549, 550, 552 • Was the reported earned income consistent with other case documents such as DHS-1171, MRS forms, tape matches, MDHHS-38, pay stubs, etc.? If no, were inconsistencies clarified and documented? • If there is a responsible relative in the home, was an income test done and was income properly deemed to the group? • Was all countable earned income verified, and were the correct dates and amounts used? • Was only countable earned income budgeted, including tips? 2) Unearned BEM 500, 517, 518, 530, 535, 540, 541, 545, 549, 550, 552 • Was the reported unearned income consistent with case docu- ments, such as DHS-1171, MRS forms, tape matches, DHS- 32, award letters, DHS-3994, etc.? If no, were inconsistencies clarified and documented? • If there is a responsible relative in the home, was an income test done and was income properly deemed to the group? • Was all the countable unearned income verified, and were the correct dates and amounts used? • Was only countable unearned income budgeted, including child support rebates, refunds and reimbursements? • Was the FIP/SDA countable income included in the food assistance budget? (check for automated recoupment) • If the group had windfall income, was an ineligibility period calculated correctly and the client properly notified? 3) Deductions BEM 500, 517, 518, 535, 536, 540, 541, 554, BAM 200 • Were child care expenses reported, verified and allowed?
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• Are all allowable expenses deducted from self-employment income and rental income? • Was the child support paid by a group member, up to the monthly court-ordered amount (excluding arrearage), allowed as a deduction? • If there is a dependent relative in the home, was the income test done and income properly diverted? • When budgeting child support received by the client, was $50 excluded from each month's support payment (FIP and FIP- related MA only)? G. MISCELLANEOUS FACTORS
1) Case Record Organization BAM 300 • Were materials correctly packeted? • Were obsolete materials obsoleted? BAM 425, 505 • Is a signed DHS-560 in the eligibility packet? • If client requested vendoring, was vendoring initiated? • If warrants were credited, was the provider(s) notified? 3) Overissuance/ Underissuance BAM 405, 406, 700, 705, 710, 715, 720, 725 • If there was an overissuance or underissuance, was the appropriate recoupment/supplement action taken? • Was the entire period of misissuance addressed and corrected budgets completed? • Were the required notices sent to the client? • Was Bridges appropriately coded for the misissuance?
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4) Emergency Assistance SER Manual Note: Some of the questions listed below may be addressed under factors A through F of the reading form. The questions which are unique to SER are addressed here. • Is there a current signed DHS-1514 and DHS-1171 in the case? • Was the emergency request registered timely? • Is the emergency a covered service? • Were repeat request criteria and required payments correctly determined and documented? • Will the payment resolve the emergency? • If the emergency was approved, did the case meet the asset limit? • Was the need verified and documented? • Was all projected income for the 30-day budget period used in doing the budget? • Does the requested need meet the affordability criteria? • If there was excess income and/or cash assets, did the client make the copayment? • Were potential resources explored and necessary repay agree- ments signed? • Was the amount authorized within the maximum allowed? • If an exception was granted, is the necessary documentation in the case? • Was the client sent a DHS-1419?
BAM 305 1 of 9 ASSIGNMENT, REASSIGNMENT AND TRANSFER BPB 2015-005 4-1-2015
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DEPARTMENT POLICY All Programs Assignment, Reassignment and Transfer are automated processes in Bridges. Assignment is the designation of responsibility for processing an application to a specific workload. Reassignment is a change in responsibility for the ongoing mainte- nance of active program groups from one caseload to another caseload. Transfer is a change in the county or district responsible for pro- cessing an application or providing ongoing maintenance. Bridges automatically assigns and reassigns all related assistance payments cases to the same workload or to a workload in the same unit. ASSIGNMENT Automated assignment occurs at the end of the registration process and is based on the local office intake rotation. Local Office Intake Rotation Bridges identifies specialist availability and authorization to process the following special group characteristics: Groups that have a disabled member. Family groups. Migrant groups. Non-English speaking groups. Groups assigned to special policy. Groups in Special Living Arrangements (SLA)s. Local offices can authorize an Eligibility Specialist (ES) or Family Independent Specialist (FIS) as Special Accommodation Assignments Only (SAAO) in one or more of the above group characteristics. Staff authorized as SAAO will be assigned only related cases which contain a group characteristic the person specializes in. Staff authorized for the group characteristic but not
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marked SAAO will be assigned other types of related groups in addition to those with a special characteristic. Local offices can also limit the number of assignments to a workload by indicating a partial workload, in increments of 10 percent. Local Office Assignment Coordinator Each local office must designate an assignment coordinator to maintain its intake rotation in Bridges. The assignment coordinator can change an automated assignment upon request from local office management when unforeseen cir- cumstances result in an inappropriate assignment (for example, the client is related to the specialist, the specialist has to leave work suddenly). REASSIGNMENT Local office management controls the criteria Bridges uses for automated reassignment by establishing individual profiles on the Manage Office Resources (MOR) Profile screen. This screen identifies ongoing specialist authorizations to maintain specific programs and the following special group characteristics: Migrant groups. Family groups. Non-English-speaking groups. Groups in SLAs. Error prone groups. Groups requiring disability reviews. Groups assigned to special policy for demonstration projects. Local offices can authorize an ongoing specialist as an SAAO in one or more of the above group characteristics. Staff authorized as an SAAO will be reassigned only related cases which contain a group characteristic the person specializes in. Staff authorized for the group characteristic(s) but not marked SAAO will be reassigned other types of related groups in addition to those with a special characteristic.
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Local offices can also limit the number of reassignments to a work- load by indicating a partial workload, in increments of 10 percent. The MOR Profile screen also records authorizations by type of program such as the Family Independence Program (FIP), State Emergency Relief (SER), for processing related group intake. Local Office Reassignment Coordinator Each local office must designate a local office reassignment coordi- nator. This may be the case transfer clerk, assignment coordinator or another designated individual. The local office reassignment coordinator: Receives the physical case record from the sending workload. Completes reassignment transactions for specified cases or workload redistribution. Forwards and logs out the physical case record to the receiving workload. Specialist Reassignment Procedures When a case is identified for reassignment, the specialist will receive a Bridges reassignment alert/request from his/her supervisor, manager or local office reassignment coordinator. The specialist needs to complete the following steps: Assemble the current physical case record and file all loose documents in the proper packets. Reconstruct the physical record if it cannot be located; see Lost Physical Case Records in this item. Forward the physical case record to the local office reassignment coordinator. TRANSFER A case record is generally transferred to another local office when:
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A group moves within the state to an area served by a different county or district office, or The case must be serviced in a different county or district office for administrative reasons. Note: A person who lives in a county participating in the transparent county line project may apply and have his/her application processed by any county that is also participating in the transparent county line project. See Transfer Guidelines in this item. Transfers are made through the Manage Office Resources Case Transfer screen. The specialist needs to: Prepare the electronic and physical case record for transfer, and Transfer the case within 10 workdays after the later of: The date the transfer is requested, or The actual date the group moves. Note: The case and EDG numbers do not change when a case is transferred. Exception: Do not transfer out the physical case records of migrant groups who receive Food Assistance Program (FAP) benefits only; see BEM 610 Migrants/Seasonal Farmworkers policy. Prepare and transfer the Bridges electronic record only. The transfer-in office must establish a separate, physical case record for the same certified FAP group. FIP and Medicaid (MA) When a client moves, it may cause health maintenance organization (HMO) disenrollment. The Department of Community Health’s (DCH) enrollment broker, Michigan Enrolls, will contact the client if disenrollment occurs. Clients who have questions about their HMO care may contact DCH at its toll-free number: 1- (800) 642-3195.
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.Prohibited Transfers MA Only The local office services unit with primary responsibility for services must maintain the MA case record when the client is a child in foster care or in an institution funded by DHS. This policy also applies to out-of-state placements. Bridges will prohibit the transfer of a case with pending tasks and reminders. However if necessary, a supervisor can authorize the transferring of a case with pending tasks and reminders. SDA, MA Do not transfer the cases of students residing in dormitory housing at the Michigan Career and Technical Institute (MCTI) to the Barry County DHS office. These cases remain in the county of origin. This is a Michigan Rehabilitation Services (MRS) program that is open to statewide participation. The students stay in the dormitories at MCTI during the school year, but return home on weekends and holidays. DHS and MRS services are provided by the student's home county. Transfer Guidelines MA Only MA case records are not transferred in the following situations: The local offices involved agree that case transfer is not in the best interest of a client and/or program administration.
A single local office should maintain the case records of: All clients in the same fiscal or Low-Income Family (LIF) MA qualified group, and A long term hospital (L/H) patient and his dependent(s) when the dependent(s) is an MA recipient who receives money diverted from the L/H patient. The client enters a hospital in another service area and the stay is expected to last less than 30 days.
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Note: Admission to a hospital’s long-term care unit can reasonably be expected to last more than 30 days. Transfer Procedures All Programs To prepare a case for transfer, do the following: 1. For electronic data management (EDM) hybrid cases, provide what exists of the paper case file to administrative support with the DHS-709, EDM Transfer-out Notice of Hybrid Case File, attached to the top of the file. 2. When a case file containing only electronic documents (ED) is identified to be transferred, the following steps must be completed by the specialist: View Pending Casework screen. Complete pending work such as all EDs, change reports and task/reminders prior to transfer. If all EDs are not able to be completed for example, Disability Determination Service (DDS) determination pending, health plan change may affect treatment; the manager can elect to transfer the case, similar to transferring cases with outstanding tasks/reminders. 3. Once the case is ready to be transferred, the specialist transfers the case in Bridges by: Locating the case or application on the Case Transfer screen. Then locate the case or application to be transferred using the Case/Application search box. Select the Region and Office the case is being transferred to, or use the magnifying glass to search for the correct office. Click Update.
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Specialist Transfer-In Procedures All Programs Do the following upon receiving an alert that a case has been trans- ferred to your workload from another local office: Review the electronic record to determine whether all appropriate actions have been completed. Complete any necessary actions that were not completed. If an interview is required schedule the interview no later than five workdays from the alert date; see interviews in BAM 115. Interview the client if required. Complete a review of the eligibility factors that might have changed because of the move or conduct a full redetermination. However, if the redetermination is due or overdue, it must be completed. Pending Applications and Initial Asset Assessments All Programs Do not deny a pending application or MA initial asset assessment solely because the group moved to another county or district. Transfer the application and documentary evidence to the new local office so that the original standard of promptness can be used. If a group requesting assistance already has an application or MA initial asset assessment pending in another local office, request the case record. Inactive Physical Case Records All Programs The new office will request transfer of an inactive physical case record during the registration process if the last county or district of record is not the same as the registering county or district.
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The former county or district of record must transfer the inactive physical case record within 10 working days of receipt of the transfer request alert. Lost Physical Case Records All Programs Documentation and information needed to support an eligibility determination may be recorded on the electronic case record. How- ever, signed documents, vital statistics, medical and legal packets, and supportive verification and documentation are stored in the physical case record. Transfer-Out Offices When a transfer request is received and the physical case record cannot be located, do all of the following: Check to see if the case file consists entirely of ED's. Notify the new local office that the physical record is lost. Reconstruct the record using available documents and other information. Follow the Transfer Procedures in this item. If the lost physical case record includes a pending application, transfer the pending groups to the new local office. This ensures adherence to the established standard of promptness. If the physical case record is later found, forward it to the new local office indicated in Bridges. This includes inactive cases. Transfer-In Offices When the transfer-out office cannot locate the physical case record, do the following: Have the client sign a new application. Obtain sufficient verifications and documentation to support the eligibility determination.
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Do not close or deny benefits solely because the client is unable to re-verify information that has been coded as previously verified in Bridges. LEGAL BASE FIP Public Act 280 of 1939 as amended SDA Annual Appropriations Act Michigan Administrative Code; R 400.3151-400.3180
Child Development and Care
Child Care and Development Block Grant of 1990 45 CFR Parts 98 and 99 Social Security Act, as amended R 400.5001 - 400.5020, MAC MA MCL 400.32 FAP 7 CFR 272.3
BAM 310 1 of 29 CONFIDENTIALITY AND PUBLIC ACCESS TO CASE RECORDS BPB 2022-015 7-1-2022
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY Family Independence Program (FIP), Refugee Cash Assistance (RCA), State Disability Assistance (SDA), Child Development and Care (CDC), Medicaid (MA), Refugee Medical Assistance (RMA) and Food Assistance Program (FAP) Information contained in all program case records is confidential and may be released only under limited circumstances for five general purposes: program administration, other government officials' access, charitable organization access, general public access, and client access. Policy in this item sets conditions for releasing information for each purpose. Do not discuss with unauthorized persons, either during or after working hours, information about individual clients known through the Michigan Department of Health & Human Services (MDHHS) employment. Prior to releasing information or records, check the case record for any documentation of domestic violence or a completed DHS-970, Affidavit for Withholding Any Information from Disclosure To The General Public; see VICTIMS OF DOMESTIC VIOLENCE in this item. Releases for Program Administration FIP, SDA, RCA, CDC, RMA, and FAP Case record information may be released for purposes directly related to administration of FIP, SDA, RCA, CDC, MA, RMA, FAP, Title XX social services, and other means-tested assistance programs. The release of any such information must be necessary for program administration, not solely to meet the needs of a person or agency. Releases are limited to persons or agency representatives who are subject to standards of confidentiality comparable to those of MDHHS or in accordance with a data share agreement. MA Only Information may only be released for purposes directly connected to administering MA. Those purposes are: • Establishing eligibility for MA.
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• Determining the amount of medical assistance. • Providing MA services for beneficiaries. • Conducting or assisting an investigation, prosecution, or civil or criminal proceeding related to the administration of the plan. For example, referral or response to the MDHHS Office of Inspector General (OIG) for investigative purposes. Consent to release, disclose or use of MA information for reasons other than those directly related to the administration of MA to an outside source, must be in writing from the individual client on a HIPAA compliant release, such as DCH-1183, AUTHORIZATION TO DISCLOSE PROTECTED HEALTH INFORMATION, before any such release, disclosure or use occurs. FIP, SDA, RCA, CDC, RMA, and FAP Program administration means any of the following: 1. Establishing eligibility, determining benefits and providing services to clients. 2. Investigation, prosecution, or criminal/civil proceedings related to administering the program. This includes cooperation with local, state, or federal law enforcement officials and postal inspectors. Note: For FAP only, the request must be in writing and include the: • Identity of the requestor. • Authority to request the information. • Violation being investigated. • Identity of the client about whom the information is requested. 3. Administration of other federal or federally assisted programs which provide assistance, in cash or in kind, or services, directly to individuals based on need. Exception: This does not apply to the release of MA records. 4. Any audit related to program administration and conducted by a government agency authorized to do so. Examples of releasing information for purposes directly related to program administration include, but are not limited to:
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• Response to a social services agency in another state to confirm a client's eligibility status and benefits received in Michigan. • Referral to the Social Security Administration (SSA) to determine a client's SSI eligibility. • Referral to the Michigan Unemployment Insurance Agency (UIA) to verify a client's wage record or eligibility for unemployment benefits. • For FIP, SDA and RCA only: Referral to MDHHS Services programs and sharing of information between Family Independence Specialist (FIS)/Eligibility Specialist (ES) and services staff. • Correspondence with a court (including Friend of the Court), the responsible prosecutor's office, the Internal Revenue Service (IRS), or SSA to locate absent parents or obtain child support. • Request to a doctor, hospital or other agency for medical information needed to determine eligibility. • For FIP, SDA, RCA and FAP only: Referral or response to the MDHHS Children’s Services Administration staff for investigative purposes. • For FIP, SDA, RCA, CDC and FAP only: Referral or response to the MDHHS OIG for investigative purposes. • Referral or response to a court or law enforcement official or MDHHS OIG regarding suspected intentional program violation (IPV). • Referral or response to an administrative subpoena signed by the Director of the Office of Child Support or a court-ordered subpoena regarding child support. • Release of information necessary for the client's participation in employment-related activities required for receipt of program benefits. • Release of the current status of FAP clients to school authorities regarding the National School Lunch Program or the School Breakfast Program.
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• For CDC only, sending notices, or otherwise providing information, to a client’s child care provider when: Child care services are authorized. Changes are made in the authorization information previously given to the provider. An authorization ends. A Child Development and Care (CDC) application is denied. A CDC application is withdrawn. A CDC case is closed.
See Bridges Eligibility Manual (BEM) 704, Information Shared with Providers. Obtaining Client Consent A signed application for assistance provides consent for purposes of program administration. No other written consent is required. If uncertain whether the requested information is necessary to administer programs, inform the client of the request and obtain a signed consent before making the information available. A DHS-27, Release of Information, is the best means to obtain the client's consent. Any consent must contain all of the following: • Client signature. • Current date. • Person/agency to whom the information is released. • Time period covered. • Information to be released (either itemizing or stating a general release of any information). When a serious threat to the family's health or safety exists, prior consent is not needed except when HIV/AIDS status is requested. Notify the client immediately of the information released.
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Access by Government Officials FIP, SDA, RCA, and CDC Only FIP, SDA, RCA, and/or CDC information may be released to the following if necessary to perform their official duties: • Official of a federal or state agency (including law enforcement). • Official of a city, county, or district (including law enforcement). • Member or committee of the Congress or State Legislature. Release information requested by an official's representative if the representative is so authorized by the official and the information is directly related to the official's duties. The official must provide a written statement establishing those facts. Place the written statement in the case record. The request may be initiated in person or via correspondence but must be in writing. Send the requestor a DHS-63, Request for Information Regarding Person Receiving Assistance, to complete and return. A request in any other form must clearly identify the official and the purpose for which the information is to be released. It must also contain sufficient information to identify the client(s). If the validity of a request is questionable, contact the official/agency to confirm that the information is needed to perform official duties. Inform the requestor that they must safeguard this confidential information and must not use it for purposes outside the official's functions or in unlawful ways; see General Public Access to Case Records in this item. The official or representative may read the entire client case record if necessary to perform official duties, but only in the local office during normal business hours. Client case records must not be removed from MDHHS premises. Exception #1: A release regarding an individual's testing for HIV or AIDS is very limited; see HIV and AIDS Confidentiality in this item.
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Exception #2: Do not release information obtained from the Workers' Compensation Agency (Michigan Department of Licensing and Regulatory Affairs) unless subpoenaed by a court, even if the client provides a signed consent to release it to others. Information may be released to the client if requested by the client or the client's legal representative. FIP, SDA, and RCA Only A client's current address may be released to law enforcement officers only if the officer provides all of the following in writing: • Name of the client. • SSN of the client. • Proof that the client is a fugitive felon. • Proof that the apprehension of the felon is within the officer's official duties. • Proof that the request was made in the proper exercise of the officer's duties. FAP Only Upon written request, a client's address, SSN, and, if available, a photograph may be released to law enforcement officers who are acting in their official capacity to apprehend a fleeing felon. The officer must provide the name of the client and one of the following: • Proof that the client is fleeing to avoid prosecution or custody for a crime, or an attempt to commit a crime, that would be classified as a felony (for example, a copy of the felony warrant). • Proof that the client is in violation of probation or parole imposed under state or federal law, and is being sought by the court, the Department of Corrections, or law enforcement. Note: Only release information that is specifically requested by the law enforcement officer (for example, address, SSN, or photograph).
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All programs Client consent is not required when releasing information to government officials, as defined above. For Victims of Domestic Violence, information can only be released to law enforcement officers without client consent if: • The officer can demonstrate a need for the information as part of an existing criminal investigation of the client; and • There is verification of the law enforcement officer's status. See Victims of Domestic Violence in this item for additional information. Case Record Access by Charitable Organizations FIP, SDA, RCA, and CDC Only Limited case record information may be released in response to a request by a charitable organization, provided local office management or community resource coordinator recognize it as having among its purposes the provision of goods or services for individuals in need. The request may be initiated in person or via correspondence, but must be in writing. A DHS-63, Request for Information Regarding Persons Receiving Assistance, may be sent to the requestor to complete. If the validity of a request is questionable, contact the organization to confirm that the information is needed to provide a charitable benefit. Explain to the representative that the purpose of the request must be to provide a benefit to clients and that it is illegal to use the infor- mation acquired for personal, political, commercial, or religious rea- sons. A request may be for particular clients or for a list of clients within a geographic area, age range or the like; see Client Lists in this item.
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Example: A representative of the Toys for Tots organization might request a list of families in the county with children of pre-school age. If the above conditions are met respond to the request by releasing only the following: • Grantee name and address. • First name(s) and age(s) of the child(ren) living with the grantee. Retain completed requests chronologically in a separate file. Record on the back or attach a sheet to indicate the client(s) identified, resulting benefit(s), other facts concerning the inquiry, and any client action taken as a result. If a list of clients was provided, attach a copy. Client consent is obtained via the MDHHS-1171, Assistance Application. The MDHHS-1171-INFO, Information Booklet, contains a section called "Release Information for Program Needs." By signing the MDHHS-1171, an individual certifies that they have received a copy, reviewed, and agree with the sections in the assistance application information booklet which permits limited case information to be divulged to charitable organizations. For requests for client lists see Client Lists in this item.
General Public Access to Case Records All Programs Federal regulations and Michigan law limit general public access to case records. The general public means anyone except the client, the client's representative, a recognized charitable organization, or a local, state, or federal government official whose request is part of official duties. When the client has provided a signed consent to release specific information, that specific information may be given to members of the general public who request it. Information required by court order to be released must be given to the person/agency named in the order.
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MA and FAP Only In the absence of the client's signed consent or a court order, release case record information to only the client, his or her representative, or the following: • For MA, a person/organization whose request is directly connected to administration of the MA program. • For FAP, a person/organization whose request is directly connected to administration of FIP, SDA, RCA, CDC, MA, FAP, Supplemental Security Income and other means-tested programs. No information may be released to anyone else, even to acknowledge the client is a recipient. All Programs The request may be initiated in person or via correspondence but must be in writing. The DHS-63 may be used. If the request is in some other form, it must contain the requestor's home address and occupation as well as enough information to identify the correct client. For requests for client lists see Client Lists in this item. When a request meets the above requirements, provide only the name and amount of monthly assistance the group is currently receiving or last received. Do not provide the group's address or any other case information. Prior to releasing any information, check the case record for a completed DHS-970; see VICTIMS OF DOMESTIC VIOLENCE in this item. Inform the requestor that: • It is unlawful to utter or publish released information unless IPV or wrongful issuance of benefits is alleged. • It is unlawful to use the information for political or commercial purposes. • Violation of confidentiality or improper use of the information can result in a $1,000 fine, two years in prison, or both. Document whether the client was identified, other facts concerning the inquiry, and the information released. Maintain a copy of client's signed consent in the case record.
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VICTIMS OF DOMESTIC VIOLENCE All Programs Confidentiality may be critical to the safety of the client when domestic violence is present. Document clearly in Bridges if an individual is identified as a victim of domestic violence. No information can be released, even to acknowledge the name and benefit amount, if the client has been identified as a victim of domestic violence or has stated that: • The client was physically and/or emotionally abused by a current or former spouse/companion; and • The client fears that being identified will lead to a recurrence of such abuse. A completed DHS-970, or its equivalent, can be used for this purpose. This process prohibits only MDHHS from releasing information. Advise the client that contacting other persons and agencies to request withholding of information is the client's responsibility. Exception: For requests for information from law enforcement officials, see Access by Government Officials in this item. Note: For FAP, when a client/authorized representative (individual interviewed on the client's behalf) requests a copy of an application or redetermination, any domestic violence information must be redacted from their copy. CLIENT ACCESS TO CASE RECORDS All Programs Case materials not separately restricted by law or court order must be available to the client upon request, as indicated in this item. Telephone requests are not sufficient. Send the client a DHS-63 for completion or return. Correspondence that clearly identifies the client is also acceptable. Before providing any materials requested by mail, contact the client to verify that the client made the request.
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Within five workdays after receiving the completed DHS-63 or let- ter, send one copy of any unrestricted materials requested. The client may personally inspect the case record during normal business hours in a designated space and in the presence of a staff member. Original case records must not be removed from MDHHS premises. Give the person one copy of any unrestricted materials requested. Note: The client's authorized representative or legal guardian has the same rights to the case file information as the client. Client Representatives All Programs A representative acting on the client's behalf may examine the case record or request case materials in writing. They may personally inspect the case record during normal business hours in a designated space and in the presence of a staff member. Case records must not be removed from MDHHS premises. To verify the person's status as representative, obtain one of the following: • Court document or MDHHS administrative hearing authority decision indicating that person is the client's attorney at law, legal guardian, or conservator. • The client's written statement specifying that person's authority to view or request case record materials. Note: The client's statement might limit what the representative may view (for example, only certain packets or a particular time period within the case history). • For FAP only, the client's written statement designating the person as the authorized representative. Note: The client may designate the same or a different representative to use the food assistance benefits on the client's behalf.
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Mental Health Documents All Programs The client or representative may review and copy mental health documents in the case record except any portions the department determines would be detrimental to the client or someone else if disclosed. To be withheld, the document(s) or cover sheet must contain a spe- cific statement by the mental health facility or agency from which MDHHS acquired the records regarding the potential harm of disclosure. A general notation (such as, “Not for Further Release or Copy”) cannot prevent client access. Authority to restrict the release of such documents is contained in Section 748(5)(b) of the Mental Health Code (MCL 330.1748). If it is questionable whether access to certain information is permitted, contact the appropriate policy mailbox; see BEM 100. Record the response in the case record. Note: Mental health records that belong to another adult household member can only be accessed by that individual. Example: Reina is an adult household member on Ben's FAP case. Ben's case record contains Reina's mental health records. If Ben requests access to his case record, he cannot receive any information pertaining to Reina's mental health records. Child Support Specialist Records All Programs Child support specialists' records are not considered client records and so are not available for review by or release to the client or representative. This applies even after the information becomes part of the client record or electronic case file. Before releasing case record materials, you must remove all information gathered by the support specialist regarding an absent parent.
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Criminal Investigations All Programs Do not release to the client or representative any information related to a criminal investigation, unless the investigation and any resulting prosecution are complete. If the investigation is an OIG-related investigation, contact the OIG agent to verify whether or not the investigation has been resolved. If the investigation is not related to OIG, contact the appropriate policy email box(es) for assistance in determining whether or not the investigation has been resolved. HIV AND AIDS CONFIDENTIALITY All Programs Information identifying a person in regard to the following is confi- dential: • Testing for, or infection by, human immunodeficiency virus (HIV). • Testing for or diagnosis of acquired immunodeficiency syndrome (AIDS). Do not disclose such information without prior written consent from the individual, his legal guardian, or a parent when the individual is a minor. No other person may give consent for the individual. The individual consents by signing the application (which contains an acknowledgment regarding release of medical information) or comparable written statement. A legal guardian or parent consents by signing a DHS-4609, Medical Information Acknowledgment, or comparable written statement. Release such information only if it is necessary to do one of the following: • Administer MDHHS programs. • Place and/or care for a minor in licensed child care. • Prepare a report required by child protection law.
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• Comply with a court order or subpoena indicating the court has determined that: Other ways of obtaining the information are unavailable or ineffective. Public interest and need for the disclosure outweigh potential injury to the person. See Court Proceedings in this item. Important: Unauthorized disclosure of HIV or AIDS information about an individual is a misdemeanor, punishable by up to one year imprisonment and/or $5,000 fine. It is also subject to a civil action and department discipline. See Administrative Policy Manual Legal (APL) 410, Freedom of Information Act (FOIA), for more details. CHILDREN'S SERVICES REFERRAL DOCUMENTS All Programs Access to records of protective and other services provided to children is severely limited. This includes documents in the case record indicating a referral to services. Remove any document in the case record which mentions such a referral before allowing access by any non-MDHHS person. Do not copy any such referral to satisfy a request for case materials. INFORMATION FOR HEARINGS All Programs The client or authorized hearings representative has a right to examine and receive a copy of any documents or other information to be introduced at an administrative hearing or used in the MDHHS decision regarding a hearing. This includes material from another state or federal agency unless access is restricted by other law (for example Mental Health Code).
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Call the Legal Affairs Administration at 517-373-2082 for help with questionable situations. See also “Client Access to the Case Record” in the “EVIDENCE” section in BAM 600. INTENTIONAL PROGRAM VIOLATION All Programs Provide case records when requested by an agent of the MDHHS Office of Inspector General. The agent may remove the physical case record temporarily from the local office. If that is intended, make copies of all pertinent materials for casework purposes until the record is returned. Court Proceedings All Programs Provide case records without subpoena to the Legal Affairs Administration or to the department's legal representative when MDHHS is the initiator or defendant in a legal action. The legal representative can be a prosecutor or staff of the attorney general (AG). The department's legal representative may remove the case record temporarily from the local office. If that is intended, make copies of all pertinent materials for casework purposes until the record is returned. In matters involving legal representation of MDHHS, provide one copy of case record materials when requested or subpoenaed by the client or the client's legal representative, unless prohibited by law or regulation. Subpoenaed Information All Programs If subpoenaed to produce a case record in court or testify as to its contents, proceed as follows: • Explain to the court (before the hearing, if possible) that case records are confidential by law and request the court to excuse MDHHS.
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• If not excused, read in court the pertinent portions of the statement contained in Exhibit I in this item for the appropriate program(s). Then, if the court orders it, produce the record and/or discuss it. Reminder: Have available a copy of Exhibits II through V to give to the court if requested. If subpoenaed by an attorney other than the client's attorney to appear or to submit a case record, at a place other than a court (for example, copy center or law office), proceed as follows: • Send a copy of the subpoena to MDHHS- Subpoena@michigan.gov. Legal Affairs staff will provide additional instructions. • Call the attorney to explain that you are willing to appear but cannot produce or discuss the case record without the client's signed consent or a court order. • If the attorney insists, appear at the designated place, read the Exhibit I statement, and withhold the record and discussion of it in the absence of the client's signed consent or a court order. • If the attorney notifies MDHHS of a scheduled court hearing, appear at the hearing and read the Exhibit I statement. Then comply with any order the court issues. The above procedures do not apply to actions initiated by MDHHS (for example, to prosecute for IPV, establish paternity or secure support). Provide the case record to the department's legal representative. If the opposing attorney subpoenas the record, contact the MDHHS legal representative for instructions. If there are questions about a subpoena, contact the Legal Affairs Administration in central office through administrative channels. Court-Ordered HIV/AIDS Information All Programs In response to a court order, disclosure about a person who was tested for or infected by HIV, or tested or diagnosed as having AIDS is mandatory. The court is responsible for determining that other ways of obtaining the information are unavailable or
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ineffective and that the public interest and need for disclosure outweigh client confidentiality. If not stated in the court order, before providing the information, remind the court that its order must ensure the following (MCL 333.5131): • Disclosure is limited to those parts of the client's record that the court determines essential to fulfill the objective of the order. • Disclosure is limited to those persons whose need for the information is the basis for the order. • The court must take other measures it considers necessary to limit disclosure. If you have questions about a court order, contact the Bureau of Legal Affairs; see HIV and AIDS Confidentiality in this item. Legal Questions All Programs
Do not communicate with an opposing attorney or representative on any issue of substance after a court suit is filed. Persons seeking to communicate must be referred to the Legal Affairs Administration. If you receive requests for records from an attorney, send the request to the Legal Affairs Administration for direction. Requests for Research All Programs If you have legal questions about releasing information or disclosure of records, complete a DHS-5300, Legal Research Request, form and submit it to the appropriate email box noted on the form.
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Client Lists FIP, CDC and SDA Without prior written consent, MDHHS may furnish a list of clients or release information about groups of clients only if either: • It is directly related to the administration of MDHHS programs. • It is to be used by a charitable organization solely to benefit those clients directly. Additionally, it is not to be used for commercial or political purposes. For client consent requirements see Releases for Program Administration and Case Record Access by Charitable Organizations in this item. All Programs Inform any other requestor that the information can be released only with the clients' prior written consent and that MDHHS will cooperate as follows: • The local office will prepare a release that includes the requestor's identity, the purpose, and the information requested. The release will be sent to the clients, who may consent or refuse. • Only information about those who furnish written consent will be provided. Community Agencies All Programs Many communities have social service exchanges or central registration systems where member agencies send and draw information about specific clients. MDHHS may contribute information only with the client's written consent.
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Freedom of Information Act All Programs The Michigan Freedom of Information Act (1976 P 442) requires MDHHS to provide public access to records that are not exempted by a separate law or a specific provision of the FOIA. Client records are exempt from this Act, except as provided in this item; see APL-410, Freedom of Information Act (FOIA). EXHIBIT I - STATEMENT TO BE READ BY MDHHS STAFF In response to the subpoena, I must bring to your attention that these records are confidential under Michigan statute. State law, at MCL 400.35, establishes the confidentiality of FIP, CDC, SDA, MA and FAP records. The MDHHS has promulgated rules for the use of such records, pursuant to Public Act 306 of 1969, as amended. MCL 400.64 provides exceptions to the restrictions in MCL 400.35. However, those exceptions do not pertain to these records. It further prescribes penalties for violation of the Act. The MA and FAP statutes comply with pertinent federal laws and regulations: • For MA, Section 1902(a)(7) of the Social Security Act, as amended; and Section 431.300-.307 of Title 42, Code of Federal Regulations. • For FAP, Section 11(e)(8) of the Food Nutrition Act of 2008 as amended; and Section 272.1(c) of Title 7, Code of Federal Regulations. Because the case information is confidential, I must decline to release it unless the Court orders me to do so. I have available the relevant sections of the above cited federal law, regulations and state statutes for your review.
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EXHIBIT II - MICHIGAN SOCIAL WELFARE ACT MCL 400.35 & MCL 400.64 MCL 400.35 Records; confidentiality; rules for use. Sec. 35. Notwithstanding section 2(6), records relating to categorical assistance, including medical assistance, shall be confidential and shall not be open to inspection except as prescribed in section 64. The state department of social services may promulgate and enforce rules for the use of the records as may be necessary for purposes related to federal, state, or local public assistance, pursuant to Act No. 306 of the Public Acts of 1969, as amended. MCL 400.64 Applications and records considered public records; inspection; public access; restriction; uttering, publishing, or using names, addresses, or other information; confidentiality; alphabetical index file; inquiry as to name or amount of assistance; making available certain information to public utility or municipality; disclosure of information; violation; penalty; notice of assistance to deserted or abandoned child; documents, reports, or records from another agency or organization. Sec. 64. (1) Notwithstanding sections 2(6), 35, 45(6), and 46(6), applications and records concerning an applicant for or recipient of assistance under the terms of this act, except medical assistance, are public records and are open to inspection by persons authorized by the federal or state government, the state department, or the officials of the county, city, or district involved, in connection with their official acts and by the general public as to the names of recipients and the amounts of assistance granted. General public access is restricted to persons who present a signed application containing the name, the address, and the occupation of the persons signing the application. A person shall not utter or publish the names, addresses, or other information regarding applicants or recipients except in cases where fraud is charged, or wrongful grant of assistance is alleged. A person shall not use the names, addresses, or other information regarding applicants or recipients for political or commercial purposes.
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(2) Records relating to persons applying for, receiving or formerly receiving medical services under the categorical assistance programs of this act are confidential and shall be used only for purposes directly and specifically related to the administration of the medical program. (3) In each county, the department shall maintain an alphabetical index file in its office of cases receiving assistance through the department. When a citizen makes a personal visit to an office during regular office hours and makes inquiry as to the name or amount of assistance being received by a person, the requester shall be given the information requested in the manner prescribed by the freedom of information act, 1976 PA 442, MCL 15.231 to 15.246. (4) Subject to restrictions prescribed by federal regulations governing temporary assistance for needy families or other federal programs, rules of the state department, or otherwise, for preventing the disclosure of confidential information to any person not authorized by law to receive the confidential information, the state department shall make available to a public utility regulated by the Michigan public service commission or a municipality information concerning applicants for, and recipients of, public assistance, the disclosure of which is necessary and the use of which is strictly limited to the purpose of a public utility's administering a program created by statute or by order of the Michigan public service commission and intended to assist applicants for, or recipients of, public assistance in defraying their energy costs. (5) The state department may disclose information regarding applicants for, and recipients of, assistance under this act in connection with the administration of assistance under this act, including the implementation and administration of section 60a, to the extent that the disclosure in regard to applicants for and recipients of federally funded assistance is in accordance with applicable federal law and regulations regarding disclosure of confidential information concerning applicants for or recipients of federally funded assistance. (6) Except as prescribed in section 61(2) and 61(3), a person who violates this section is, upon conviction, guilty of a misdemeanor punishable by imprisonment for not more than 2 years or by a fine of not more than $1,000.00, or both. If an employee of the state violates this section, the employee is also subject to dismissal from
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state employment subject to rules as established by the civil service commission. (7) The county department shall give prompt notice to appropriate law enforcement officials of the furnishing of temporary assistance for needy families in each case where a child has been deserted or abandoned by a parent and assistance is being furnished to the child. (8) Documents, reports, or records authored by or obtained from another agency or organization shall not be released or open for inspection under subsection (1) unless required by other state or federal law, in response to an order issued by a judge, magistrate, or other authorized judicial officer. EXHIBIT III - 42 CFR, SECTION 431.300-.307 Subpart F—Safeguarding Information on Applicants and Recipients 431.300 Basis and purpose. (a) Section 1902(a)(7) of the Act requires that a State plan must provide safeguards that restrict the use or disclosure of information concerning applicants and recipients to purposes directly connected with the administration of the plan. This subpart specifies State plan requirements, the types of information to be safeguarded, the conditions for release of safeguarded information, and restrictions on the distribution of other information. (b) Section 1137 of the Act, which requires agencies to exchange information in order to verify the income and eligibility of applicants and recipients (see 435.940ff), requires State agencies to have adequate safeguards to assure that: (1) Information exchanged by the State agencies is made available only to the extent necessary to assist in the valid administrative needs of the program receiving the information, and information received under section 6103(l) of the Internal Revenue Code of 1954 is exchanged only with agencies authorized to receive that information under that section of the Code; and
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(2) The information is adequately stored and processed so that it is protected against unauthorized disclosure for other purposes. 431.301 State plan requirements. A State plan must provide, under a state statute that imposes legal sanctions, safeguards meeting the requirements of this subpart that restrict the use or disclosure of information concerning applicants and recipients to purposes directly connected with the administration of the plan. 431.302 Purposes directly related to State plan administration. Purposes directly related to plan administration include: (a) Establishing eligibility; (b) Determining the amount of medical assistance; (c) Providing services for recipients; and (d) Conducting or assisting an investigation, prosecution, or civil or criminal proceeding related to the administration of the plan. 431.303 State authority for safeguarding information. The Medicaid agency must have authority to implement and enforce the provisions specified in this subpart for safeguarding information about applicants and recipients. 431.304 Publicizing safeguarding requirements. (a) The agency must publicize provisions governing the confidential nature of information about applicants and recipients, including the legal sanctions imposed for improper disclosure and use. (b) The agency must provide copies of these provisions to applicants and recipients and to other persons and agencies to whom information is disclosed. 431.305 Types of information to be safeguarded. (a) The agency must have criteria that govern the types of information about applicants and recipients that are safeguarded. (b) This information must include at least— (1) Names and addresses; (2) Medical services provided;
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(3) Social and economic conditions or circumstances; (4) Agency evaluation of personal information; (5) Medical data, including diagnosis and past history of disease or disability; and (6) Any information received for verifying income eligibility and amount of medical assistance payments (see 435.940ff). Income information received from SSA, or the Internal Revenue Service must be safeguarded according to the requirements of the agency that furnished the data. (7) Any information received in connection with the identification of legally liable third-party resources under 433.138 of this chapter. 431.306 Release of information. (a) The agency must have criteria specifying the conditions for release and use of information about applicants and recipients. (b) Access to information concerning applicants or recipients must be restricted to persons or agency representatives who are subject to standards of confidentiality that are comparable to those of the agency. (c) The agency must not publish names of applicants or recipients. (d) The agency must obtain permission from a family or individual, whenever possible, before responding to a request for information from an outside source, unless the information is to be used to verify income, eligibility and the amount of medical assistance payment under section 1137 of this Act and 435.940 through 435.965 of this chapter. If, because of an emergency situation, time does not permit obtaining consent before release, the agency must notify the family or individual immediately after supplying the information. (e) The agency’s policies must apply to all requests for information from outside sources, including governmental bodies, the courts, or law enforcement officials. (f) If a court issues a subpoena for a case record or for any agency representative to testify concerning an applicant or recipient, the agency must inform the court of the applicable statutory provisions, policies, and regulations restricting disclosure of information.
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(g) Before requesting information from, or releasing information to, other agencies to verify income, eligibility and the amount of assistance under 435.940 through 435.965 of this chapter, the agency must execute data exchange agreements with those agencies, as specified in 435.945(f). (h) Before requesting information from, or releasing information to, other agencies to identify legally liable third-party resources under 433.138(d) of this chapter, the agency must execute data in exchanges agreements, as specified in section 433-138(h)(2) of this chapter. 431.307 Distribution of information materials. (a) All materials distributed to applicants, recipients, or medical providers must: (1) Directly relate to the administration of the Medicaid program; (2) Have no political implications except to the extent required to implement the National Voter Registration Act of 1993 (NVRA) Pub. L. 103–931; for States that are exempt from the requirements of NVRA, voter registration may be a voluntary activity so long as the provisions of section 7(a)(5) of NVRA are observed; (3) Contain the names only of individuals directly connected with the administration of the plan; and (4) Identify those individuals only in their official capacity with the State or local agency. (b) The agency must not distribute materials such as “holiday” greetings, general public announcements, partisan voting information and alien registration notices. (c) The agency may distribute materials directly related to the health and welfare of applicants and recipients, such as announcements of free medical examinations, availability of surplus food, and consumer protection information. (d) Under NVRA, the agency must distribute voter information and registration materials as specified in NVRA.
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EXHIBIT IV - FOOD AND NUTRITION ACT OF 2008, AS AMENDED (e)(8) Safeguards which prohibit the use or disclosure of information obtained from applicant households, except that - (A) the safeguards shall permit - (i) the disclosure of such information to person directly connected with the administration or enforcement of the provisions of this Act, regulations issued pursuant to this Act, Federal assistance programs, or federally assisted State programs; and (ii) the subsequent use of the information by persons described in clause (i) only for such administration or enforcement; (B) the safeguards shall not prevent the use or disclosure of such information to the Comptroller General of the United States for audit and examination authorized by any other provision of law; (C) notwithstanding any other provision of law, all information obtained under this Act from an applicant household shall be made available, upon request, to local, State or Federal law enforcement officials for the purpose of investigating an alleged violation of this Act or any regulation issued under this Act;- (D) the safeguards shall not prevent the use by, or disclosure of such information, to agencies of the Federal Government (including the United States Postal Service for purposes of collecting the amount of an overissuance of benefits, as determined under section 13(b) of this Act, from Federal pay (including salaries and pensions) as authorized pursuant to section 5514 of title 5 of the United States Code or a Federal income tax refund as authorized by section 3720A of title 31, United States Code; (E) not withstanding any other provision of law, the address, social security number, and if available, on request, to any Federal, State, or local law enforcement officer if the officer furnishes the State agency with the name of the member and notifies the agency that-
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(i) the member-- (I) is fleeing to avoid prosecution, or custody or confinement after conviction, for a crime (or attempt to commit a crime) that, under the law of the place the member is fleeing, is a felony (or, in the case of New Jersey, a high misdemeanor), or is violating a condition of probation or parole imposed under Federal or State law; or (II) has information that is necessary for the officer to conduct an official duty related to subclause (I). (ii) locating or apprehending the member is an official duty; and (iii) the request is being made in the proper exercise of an official duty; and (E) the safeguards shall not prevent compliance with paragraph (15) or (18)(B) or subsection (u); EXHIBIT V - 7 CFR SECTION 272.1(c) (c) Disclosure. (1) Use or disclosure of information obtained from food stamp applicant or recipient households shall be restricted to: (i) Persons directly connected with the administration or enforcement of the provisions of the Food and Nutrition Act of 2008 as amended, or regulations, other Federal assistance programs, federally assisted State programs providing assistance on a means-tested basis to low income individuals, or general assistance programs which are subject to the joint processing requirements in section 273.2(j)(2). (ii) Persons directly connected with the administration or enforcement of the programs which are required to participate in the State income and eligibility verification system (IEVS) as specified in section 272.8(a)(2), to the extent the food stamp information is useful in establishing or verifying eligibility or benefit amounts under those programs; (iii) Persons directly connected with the verification of immigration status of aliens applying for food stamp
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benefits, through the Systematic Alien Verification for Entitlements (SAVE) Program, to the extent the information is necessary to identify the individual for verification purposes. (iv) Persons directly connected with the administration of the Child Support Program under Part D, Title IV of the Social Security Act in order to assist in the administration of that program, and employees of the Secretary of Health and Human Services as necessary to assist in establishing or verifying, eligibility or benefits under Titles II and XVI of the Social Security Act; (v) Employees of the Comptroller General's Office of the United States for audit examination authorized by any other provision of law; and (vi) Local, State, or Federal law enforcement officials, upon their written request, for the purpose of investigating an alleged violation of the Food and Nutrition Act of 2008 as amended, or regulation. The written request shall include the identity of the individual requesting the information and his authority to do so, violation being investigated, and the identity of the person on whom the information is requested. (2) Recipients of information released under paragraph (c)(1) of this section must adequately protect the information against unauthorized disclosure to persons or for purposes not specified in this section. In addition, information received through the IEVS must be protected from unauthorized disclosure as required by regulations established by the information provider. Information released to the State agency pursuant to section 6103(1) of the Internal Revenue Code of 1954 shall be subject to the safeguards established by the Secretary of the Treasury in section 6103(1) of the Internal Revenue Code and implemented by the Internal Revenue Service in its publication, Tax Information and Security Guidelines. (3) If there is a written request by a responsible member of the household, its currently authorized representative, or a person acting on its behalf to review material and information contained in its case file, the material and information contained in the case file shall be made available for inspection during normal business hours. However, the State agency may withhold confidential information, such as the names of individuals who have disclosed
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information about the household without the household's knowledge, or the nature or status of pending criminal prosecutions. LEGAL BASE FIP MCL 400.1 et seq. MCL 400.35 and MCL 400.64 SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 RCA and RMA 45 CFR 400.27
MA 42 CFR 431.300 - .307 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
FAP 7 USC 2020(e)(8) 7 CFR 272.1(c) 7 CFR 273.2(c)(1)(v) FOIA MCL 15. 231 et seq
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DEPARTMENT POLICY Family Independence Program (FIP) and Food Assistance Program (FAP) The Michigan Department of Health and Human Services (MDHHS) is subject to audits and reviews of its performance. Some of these are internal and some are by external agencies. This item identifies some of these review processes and defines the responsibilities of clients, local offices, central office and the corresponding federal agencies in these processes. TYPES OF AUDITS Although many areas of the department are audited, this item addresses audits/reviews regarding financial and work participation. The following audits (referred to as reviews) are used to monitor MDHHS performance in these areas: • Compliance Division Food Assistance Program (FAP) reviews. • Compliance Division Family Independence Program (FIP)/Temporary Assistance to Needy Families (TANF) work participation reviews. • State Management Evaluation Reviews (SME). • Food Assistance Management Evaluations (FAME). These audits are described in detail in this item. Included are the scope and purpose of each audit, frequency of review, the review process and how the findings are used. COMPLIANCE DIVISION REVIEWS FIP and FAP FAP Quality Control Reviews FAP Only Per federal regulations, every state is responsible for conducting FAP Quality Control (QC) reviews.
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Scope and Purpose The purpose of the active case review is to determine if households are eligible and receiving the correct monthly FAP allotment amounts. The purpose of the negative case review is to determine if the decisions and/or procedural processes to deny, suspend, or terminate cases is correct. QC review findings of active cases determine the incidence and dollar amounts of errors. The current (10/2024 for Fiscal Year 25) active case error threshold is $57. The objectives of QC reviews are to provide: • A systematic method of measuring the validity of the eligibility determinations made by the FIS/ES. • A basis for determining error rates. • A timely, continuous flow of information on which to base corrective action at all levels of administration. • The basis for establishing State agency eligibility for bonus awards or State agency liability for excessive error rates. Frequency of Reviews and Selection of Cases for Review Each month a statewide random sample of households is selected from two different categories: active cases and negative cases (households that were denied benefits or whose benefits were terminated (or temporarily suspended). Request for Case Records When a case is selected for review, the QC reviewer will contact the local office designee, if necessary to: • Obtain obsolete paper files. • If necessary, assist the reviewer in locating the recipient or enlisting the cooperation of recipients who are not responding to the reviewer’s letters or required in-person interviews. For FAP active cases, reviews that must be dropped because of recipient “non-cooperation/unable to locate” contribute a substantial increase in the FAP error rate. Federal Food Assistance Program reviewers assume these dropped cases are error cases more than the same number of
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reviewed cases. Thus, cases that are completed even with an error may have less of an impact on the error rate than a dropped review. Therefore, local office help to avoid dropping a review is crucial to the state’s overall error rate. DHS-1599, Review Results Findings Summary, Overview Upon completing the review, the Compliance Division (CD) will electronically provide a DHS-1599, Review Results Findings, sum- mary to the local office with copies to business service center and central office staff. The findings/summary includes: • Detailed case information indicating that the case is correct or in error. • Information for local office follow-up when the information is not pertinent to the sample month. • Report of a dropped review. • In cases of recipient non-cooperation, a request for case closure and the period of ineligibility; see Bridges Administrative Manual (BEM) 105, Rights and Responsibilities. The reviewer may write an “Addendum” that is a subsequent review results finding informing the local office that the results of the review have changed. Changes are reported as a result of new collateral information received by the reviewer or, a federal second party review by the US Department of Agriculture, Food and Nutrition Service. Error Prevention Review Process After the Compliance Division has transmitted its review results to FNS, the error case will be reviewed by the Payment Accuracy Manager and the Error Prevention Strategy Committee (EPSC). A quarterly teleconference meeting is facilitated by the Payment Accuracy Manager. This meeting will include various mandatory participants as determined by the Economic Stability Administration (ESA). The goals of the EPSC are to: • Identify issues that suggest a need to revise or clarify policy. • Identify training needs. • Identify the need for systems modifications.
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• Develop a better understanding of Bridges. • Identify error prevention strategies. Bias of Review Results To comply with the federal requirement to avoid bias in the review, the local office should not review the cases, make changes that would affect the eligibility or benefits for the cases, or contact the household or make a collateral contact prior to the QC review being conducted to make any changes to the case once the sample is pulled/selected. This does not apply to routine case management changes such as filing household reports, acting on reported changes, issuing notices of expiration, or conducting recertification interviews. Normal case management activities should not be initiated or undertaken at an accelerated pace in order to affect the cases under review. Local Office Response to QC Review Error Process Once the DHS-1599, Review Results Summary, for an error case is received, the local office has 10 workdays to submit the DHS-191, Response to Quality Control Review Error, and any supporting documentation. DHS-191 is to be reviewed and signed by the County Director/District Manager. Send the DHS-191 electronically to: • Central Office: DHSAPSpecialists@michigan.gov. • Compliance Division: MDHHS-FAP-QC@michigan.gov
• BSC 1: Contact BSC1 • BSC 2: BSC2-AP-Mailbox@michigan.gov • BSC 3: BSC3-APSpecialist@michigan.gov • BSC 4: BSC4APMailbox@michigan.gov If a recoupment action is required, a copy of the DHS-4701, Overissuance Referral, must be included with the DHS-191. Note: The following link is for internal use only. To view the current Active Case Error Rate, see; FAP Error Rate Reports.
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FAP Negative Case Reviews Federal Policy - FNS 310 Handbook, Quality Control Review Handbook, Chapter 13 Negative Action Record Reviews, 1340 Application Processing Aspects of the Negative Review: Negative actions are reviewed to determine the validity of the agency’s action to deny, terminate, or suspend the FAP group. Certain failures to complete application processing requirements correctly are part of the review and may result in a negative action being determined to be inappropriate and, therefore, invalid. The application processing requirements include: 1. Failure to send an Appointment Letter when required or a Notice of Missed Interview (NOMI) when required, or sending the required letter or notices to an incorrect address; notification to the FAP group must be made accurately. 2. Failure to provide expedited service where appropriate. 3. Denial of action prior to the 30th day when verification was requested. 4. Denial of an application after the 30th day when not properly pended. 5. Failure to act on an application by the 30th day following the date of application. This results in withholding benefits to a household through inaction rather than an actual action. When the 30th day falls on a weekend or holiday, the action must be taken on the next business day following the weekend or holiday to be considered timely. Error Prevention Negative Action Case Review 1. All correspondence to the client regarding a negative action on a FAP case needs to be accurate. Any incorrect reason on the notice results in an error finding even if the household was not eligible for the program for another reason. 2. Confirm the address on the notice is accurate. Sending a notice to a wrong address will result in an error finding
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3. Documentation of any decision made is extremely important. OQA can use the documentation to support a valid finding when the reason on the notice is not exactly clear. 4. Timeliness of denials is extremely important. An application not processed within 30 days is invalid unless it has been properly pended. This means a denial must be processed, in most instances, by the 30th day. If a denial is completed after the 30th day, the denial will be invalid. In the opinion of FNS, prolonging the time to process a denial amounts to withholding benefits to a FAP group. 5. Multiple reasons for a FAP negative action must all be correct to have a valid action. If any reason on the FAP negative action notice is incorrect, the decision will be invalid. 6. OQA is required to advise the county if any follow-up action is necessary on a negative action. Note: The following link is for internal use only. To view the current Negative Active Case Error Rate, see; FAP Error Rate Reports. FIP/TANF Work Participation Reviews FIP Purpose and Scope The purpose of the FIP/TANF review is: • To determine whether the TANF/FIP group includes a work- eligible individual (WEI), and if so, whether the WEI met the work participation requirements in the sample month. These reviews are federally mandated to establish Michigan’s work participation rate. Federal sanctions are applied if the work participation rate is below the federal target. • To provide to the federal government demographic information for the FIP/TANF cases reviewed.
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Frequency of Reviews and Selection of Cases for Review Each month a statewide random sample of households is selected from two categories: federally funded active FIP/TANF cases and federally funded closed FIP/TANF cases. Requests for MDHHS Case Records & MWA Files When a case is selected for review, the Compliance Division (CD) contacts the local office designee to request the case record. MDHHS offices have five business days to complete the DHS-572, OQA TANF Case Review Checklist, and provide the checklist and the MDHHS client case record to CD. The Workforce Development Agency (WDA) has eight business days to obtain the Michigan Works! Agency (MWA) file and provide it to CD. TANF/FIP Case Review Upon receipt of the records and files, CD completes the work par- ticipation desk review. When they have completed their review, the Central Office FIP/TANF Family Program Policy Unit completes a review of the FIP/TANF group’s eligibility based on information pro- vided in Bridges. WDA also reviews the work eligible individual’s current work participation activities within the One Stop Manage- ment Information System (OSMIS). TANF Work Participation Review Committee (WPRC) The TANF Work Participation Review Committee (WPRC) is facili- tated by the Compliance Division and is a partnership between CD, TANF/FIP Family Program Policy, Economic Stability Administration (ESA), WDA, MDHHS local office representative/PATH Coordinator, and MWAs. To assure accuracy and completeness, case review results and action items for all sampled cases are discussed during weekly TANF Work Participation Review Committee meetings/teleconference calls. The goals of the WPRC are: • Assure that federal work participation determinations were accurately made. • Identify and obtain additional documentation that might not have been provided or available at the time of the review.
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• Identify specific reasons that each case did not meet participation requirements. • Identify and work in partnership to eliminate barriers to meeting work participation requirements. • Assure that cases that were in the sample are currently being handled correctly, therefore preventing future errors. DHS-932, Review Results The DHS-932, CD, FIP/TANF Program Policy, and WDA Case Review Results, are emailed to MDHHS offices and MWAs, along with information regarding any follow-up action the local MDHHS office, MWA and CD is required to complete. DHS-584, Response to Review Results Within twelve workdays of receipt of the review results, the local MDHHS office is required to complete the DHS-584, Response to TANF Work Participation Case Review Results, documenting the completion of action items. • DHS-584 is to be signed by the county director/district manager. • Send the DHS-584 and any requested documents to ESA via the DHS-APSpecialists@michigan.gov. STATE MANAGEMENT EVALUATION REVIEW (ME) FAP Only The Food and Nutrition Service (FNS) periodically reviews each state’s administration and operation of the Food Assistance Pro- gram to determine compliance with federal regulations program requirements. Scope and Purpose FNS designates which areas are to be reviewed each year. Typically, these reviews include but are not limited to the following areas:
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• Application processing. • Civil rights complaints. • Benefit issuance. • Benefit recoupment and collection. • Reconciliation and reporting. • State plans for management evaluation (ME) and Quality Control (QC). • Client complaints. • Payment accuracy. • Negative errors. Frequency of Reviews The ME is conducted annually. Central and Local Office Responsibilities Most of this audit is conducted in central office using statewide data. However, one or more local offices may be reviewed. The audit begins with an entrance conference which introduces the auditing staff to the state and explains the areas that will be reviewed during the audit. The actual review typically takes three working days, with one day spent in local offices. Prior to the review, central office selects a local office for review and requests that specific cases be pulled for review. Local offices are usually given time to prepare for the review. Federal auditors are usually assigned to a designated staff person at each local office to provide information relative to the review. Once the review is completed at the local office, an exit conference is held in central office. The results of the review are presented to the department in a writ- ten report. The department then has 60 days to respond regarding corrective actions. Local offices are responsible for correcting any errors cited in individual cases.
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FOOD ASSISTANCE MANAGEMENT EVALUATION (FAME) FAP Only FAME reviews are mandated by FNS and are designed to determine whether local offices are complying with federal regulations and Michigan food assistance policy. FAME reviews do not establish the misissuance rate. Reviews are conducted by FAME from the Economic Stability Administration. The areas reviewed include but are not limited to: • Certification procedures. • Issuance services. • Security/control. • Reconciliation. • Record keeping and reporting. Note: FAME review targets can change each fiscal year according to FNS requirements. Scope and Purpose The objectives of FAME reviews are to provide: • A systematic method of monitoring and assessing program operations. • A basis for local offices to improve and strengthen program operations by identifying and correcting deficiencies • A working relationship between the local office, central office and FNS to develop solutions to identified problems in policy and/or procedures. Frequency of Reviews FAME reviews are conducted annually in large local offices which have over 15,000 cases. Counties aligned under a single director are referred to as management units. Management units of 2,001 to 15,000 cases are reviewed every two years and those with 2,000 cases or less are reviewed once every three years.
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FNS may require the State agency to conduct additional on-site reviews when a serious problem is detected in a project area which could result in a substantial dollar or service loss. FAME Responsibilities FAME contacts the local office to inform them of the date the review is to begin. They: • Read cases which have been selected according to random procedures. • Interview staff responsible for food assistance activities, • Review records, reports and local procedures. The review is documented on a worksheet and identifies: • A description of the deficiency detected. • The cause(s) of any deficiency detected, if known; and • The number and identification (case name and number) of casefiles selected and examined. They forward the review findings to the county director/district office manager and the director of the Business Service Center (BSC) that the local office is assigned to, listing all deficiencies found during the FAME review. The written report contains a general summary of findings, specific case findings and a request for a corrective action response. Review worksheets are retained by FAME and ESA for three years and are made available to FNS upon request. Local Office Responsibilities Local offices must take appropriate corrective action on errors found in the case record within 15 days of receiving the FAME review report. They must then submit a Corrective Action Plan (CAP) to the FAME within 60 days of the FAME report. The local office CAP must address: • Each of the program area deficiencies in the FAME report. • Include the corrective action they will use to correct the deficiency.
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• A timetable for meeting the corrective action. The corrective action may include recommendations for BSC or central office actions which the local office believes would aid in their efforts to correct the deficiency. Local offices are responsible for developing and completing all nec- essary follow-up measures to ensure the effectiveness of their cor- rective actions. Monitoring to fulfill this requirement may take various forms, such as, increased supervisory case readings, spe- cial reviews or spot checks, implementing new local office proce- dures, etc. LEGAL BASE FAP 7 CFR 272.3 (a)(3)
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DEPARTMENT POLICY Cash, Food and Medical Assistance Cash, Food and Medical Benefits are issued to clients based on information entered in Bridges. This item includes time frames and other instructions to open, change or terminate program benefits. DEFINITIONS All Programs Cut-off Date The last date in which a change can be made to affect the next benefit issuance. Cash Assistance Only Availability Date The last number of the grantee’s recipient identification number identifies the date benefits are available. Issuance Systems Benefits are issued using the Electronic Benefit Transfer (EBT) sys- tem. Clients have a Michigan Bridge card where their benefits are automatically deposited; see BAM 401E, Electronic Benefit Transfer Issuance System. Negative Transaction Deadline The last day for a specialist to send a timely notice of negative action to a client or to generate a DHS-1605, Notice of Case Action, with timely notice to the client, to affect the following month’s bene- fits. Pay Period (or Payment Period) The half-month that a warrant/benefit covers. A pay period is either the first through the 15th day or the 16th through the last day of the month.
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Payment (PA) Effective Date The first day of the pay period (1st or 16th of the month) for which benefits will be paid. Single Deadline Date The last workday of the month. This is the last day the grant amount can be changed to affect the following month’s payment amount. Warrant The cash benefit paid by the state to eligible groups in the form of a check. Warrant Date The date printed on the warrant or the date of the EBT deposit. It is the date the client can expect to receive the warrant or be able to access the EBT deposit. CASH BENEFITS Initial, ongoing, supplemental and issuance on closed cash assis- tance benefits of $1,000 or less are electronically deposited into the eligible group’s EBT account. Benefit authorizations over $1,000, and certain other supplemental benefits are issued as warrants. Ongoing semi-monthly benefits are issued on a staggered schedule throughout the month, based on the grantee’s recipient ID ending digit; see RFS 305, for specific issuance dates. Openings At opening, the group is eligible for benefits no earlier than the pay period in which the application becomes 30 days old; see BAM 115, Application Processing. Supplemental Benefits Bridges issues a supplement when benefits are authorized to cor- rect underissuances.
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Immediate Effect Actions When a change with immediate effect causes a benefit increase or decrease (including closures and transfers to MA), enter the change by the single deadline date to affect the following month’s benefit amount. Negative Actions- Requiring Timely Notice When providing the client with timely notice of a benefit decrease (including closures and transfers to MA), complete the change by the negative transaction deadline to affect the following month’s payment amount. Benefits Issued at Closure When Cash programs are closed (including transfers to MA), and the negative action effective date is the second day of the month through the end of a calendar month, both regular benefits for that month will be issued. Closures effective on the first day of the month receive no benefits for that month. Note: Vendoring stops when the FIP/SDA program closes. The grantee will receive the full monthly amount in any benefits issued after the closure effective date. (Recoupment will still be taken from these benefits.) Address Change A client or third-party address change must be entered a before the issuance date to affect that benefit. Vendor Payments BAM 425, Voluntary Vendor Payments, explains entry of vendor payments. Benefit Issuance A case payment history can be obtained through the View Benefits screen. By entering up to a 12-month time period and a specific case number, all payments for the case will be displayed on the screen(s).
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Make a copy of the screen if a paper copy of the information is needed. For payment histories not available in Bridges, fax a request to the Specialized Action Center in Central Office at 517- 432-6079 (professional use only). Include the case name, case number and the period for which the payment history is needed. MEDICAL BENEFITS (Plastic mihealth cards) MDHHS has contracted with Medifax to produce and issue plastic mihealth cards. Each recipient who is eligible for Medicaid will receive a mihealth card. The mihealth card will be used every month that a client is eligible for Medicaid. Openings (mihealth cards) At initial case opening when full or emergency coverage is certified, a mihealth card will be mailed within 48 hours. At initial case open- ing of a deductible when the deductible is not met, no card is mailed. However, a card is mailed the first-time eligibility (full or emergency coverage) is certified. If the case is being re-opened or reinstated, no card will be issued unless requested by the client. The client must call the beneficiary helpline at 1-800-642-3195 to request a card. Replacing an mihealth card Clients must contact the beneficiary helpline at 1-800-642-3195 to request a replacement mihealth card. The replacement card cannot be issued in the local MDHHS office. The address in Bridges will be verified for accuracy. If it is incorrect the beneficiary will be referred to the local MDHHS office for assistance to correct the address. A new card will not be issued until the address has been updated and the beneficiary contacts the helpline again. Beneficiaries should be advised to destroy the original mihealth card if found after a replacement has been issued.
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Medical History Data Inquiry Transaction MA Only Each recipient's medical coverage history is available using the MMIS Preconversion Details or the Medicaid Eligibility screen. FOOD ASSISTANCE BENEFITS Issuance Systems Benefits are issued using the EBT system. Clients have a Michigan Bridge card where their benefits are automatically deposited; see BAM 401E, Electronic Benefit Transfer Issuance System. Initial Benefits Bridges authorizes initial benefits for the month a case opens if that month is part of the eligibility period. These benefits are issued as initial l benefits; see BAM 406. Retroactive Benefits Bridges authorizes retroactive benefits if the group is eligible for a period that is both: • Prior to the month eligibility was determined. • Within 60 days of the application date. If application processing is delayed beyond 60 days from the date of application, Bridges will issue a supplement to correct previous month's benefits which may result in offsetting. These are supplemental benefits; see BAM 406, Supplemental Food Assistance Benefits. Regular Benefits The client’s ongoing benefits are issued based on the last digit of the grantee’s recipient identification number; see RFS 305 for issuance dates.
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Supplemental Benefits Bridges authorizes supplemental benefits when the regular issuance is less than the group is eligible for or for periods when the group was eligible but received no benefits; see BAM 406, Supplemental Food Assistance Benefits. Accessing Benefits Clients use a Bridge card and personal identification number to access food benefits; see BAM 401E, Electronic Benefit Transfer Issuance System. Changes and Closures The cut-off date for a benefit change or case closure is the last workday of the month before the month the change/closure takes effect. Note: Administrative recoupment can reduce benefits to zero. The case remains open, and the client must continue to meet eligibility requirements. Expunged Benefits FAP benefits which have not been accessed for 365 days will be expunged. Once expunged, the client is no longer entitled to these benefits and the benefits cannot be replaced; see BAM 401E, Elec- tronic Benefit Transfer Issuance System. Benefit Issuance History Obtain the client’s food assistance benefit history in Bridges. LEGAL BASE FIP 42 USC 604-(g) Social Welfare Act, P.A. 280 of 1939, as amended SDA Annual Appropriations Act
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Mich Admin Code, R 400.3151-400.3180
MA 42 CFR 435.914 Mich Admin Code, R 400.2(4) FAP 7 USC 2016(a),(j)(1)(A) 7 CFR 273.10(a)(1)(i)(ii) 7 CFR 274.2 7 CFR 274.1(a)(2),(d)(3) 7 CFR 274.7(d)
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OVERVIEW FIP, SDA, RCA and SNAP Electronic Benefit Transfer (EBT) allows clients who receive cash assistance (FIP, SDA etc.), and Supplemental Nutrition Assistance Program (SNAP) to receive their benefits using debit card technology. Benefits are deposited electronically into a cash and/or SNAP account. Clients access their benefits by using their personal identification number (PIN), along with their Bridge card. EXCESSIVE CARD REPLACEMENT RULE Issuance of four or more Electronic Benefit Transfer (EBT) cards has been shown to be a potential indicator of fraud and abuse of SNAP benefits. It may also be an indicator of the potential need for a referral to protective services in situations where benefits are suspected of being misused. In the Michigan Department of Health and Human Services (MDHHS) ongoing efforts to combat fraud and abuse, and to comply with Food and Nutrition Administration (FNA) policy, the following procedure will be implemented: • The EBT vendor, Fidelity Information Services (FIS) will send a card withholding letter to all households when they are at their 4th replacement card within a 12 month period, notifying them that they have reached the number of issued cards threshold, and at their 5th and each subsequent card replacement request their card will not be issued until they have gone into the local office to speak directly to the district manager or county director. • Upon the client’s request for a 5th card, a second card withholding letter will be sent by FIS notifying the client that they have exceeded the number of card requests allowed, and that they must contact their local office to schedule an appointment to speak directly to the district manager or county director in order to get another card. FIS will inform clients calling to request replacements of this requirement. • The district manager or county director will meet with the client in question and review their situation and explanation. Based on this contact, the county director or district manager will
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make appropriate referrals and issue a new EBT card under their authority. The situation, referrals, and approval shall be recorded on the DHS-1054, Authorization to Approve Issuance of Electronic Benefit Transfer (EBT) Card, form. Copies of the authorization document shall be stored in the local office and the case record for seven years either as a hard or scanned copy. Copies will also be forwarded to the appropriate business service center (BSC) director. • Clients that have a disability indicator in Bridges will not receive excessive card replacement letters and will not be subject to the excessive card replacement policy. These clients, however, will be subject to applicable card replacement fees. To meet FNA guidelines, EBT replacement cards must be available for pick up or placed in the mail within two business days following notice by the household to the state agency that the card has been lost or stolen. A copy of the authorization form may be used to locally issue an EBT card as appropriate. PROGRAM INTEGRITY The first line of defense in reducing inappropriate use of Bridge Cards is education. MDHHS provides client and retailer training. The trainings include guidelines for appropriate use of Bridge Cards as well as fraud and abuse information. Michigan offers a toll-free phone line (1-888-678-8914) that is available 24 hours a day, Seven days a week. The phone number is located on the back of the Bridge Card. Clients are also provided with written materials when they become eligible for assistance. DHS Pub-322, How to Use Your Michigan Bridge Card, includes the following information about appropriate use: • Misuse of Food Benefits is a violation of state and federal laws. • Do not sell, trade or give away SNAP benefits, PIN or Michigan Bridge Card. • Do not allow a retailer to buy SNAP benefits in exchange for cash. • Do not use someone else’s SNAP benefits or Bridge Card for households.
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• It is prohibited to use cash assistance to purchase lottery tickets, alcohol, or tobacco. Cash assistance grants cannot be used for gambling, illegal activities, massage parlors, spas, tattoo shops, bail-bond agencies, adult entertainment, or cruise ships. • Clients who purchase any beverages, in any type of container with a deposit, who dump the contents out and return the containers for the deposit, may be disqualified from receiving SNAP benefits. • People who break SNAP rules may be disqualified from the program, fined, put in prison, or all three; and must repay the SNAP benefits. EBT authorized retailers are also provided with training and are required to understand and comply with all federal and state guidelines for EBT acceptance. Retailers interested in accepting the Bridge Card for SNAP benefits purchases must be authorized by FNA. BRIDGE CARD ISSUANCE
Head of Household FIS issues Bridge cards to the program head of household (HOH), unless there is a third-party payee/protective payee for the cash program. The Bridge card is then issued to both the HOH and the third-party payee/protective payee. Bridge cards are automatically mailed by FIS for: • Head of Household changes. • New case openings when a Bridge card has not previously been issued for the same recipient identification number. Note: If a Bridge card has previously been issued for the HOH’s recipient identification number and the client no longer has the card, they must contact FIS to request a replacement card, or a local office over-the-counter card can be issued. Clients will receive the Bridge cards and card mailer with basic information two to five days after the case opening. The DHS-Pub- 322, How to Use Your Michigan Bridge Card, pamphlet will be sent to clients with initial Bridge cards. In the event an initial over-the
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counter-card (OTC) is issued to the recipient in the local office, a hard copy of the DHS-Pub-322 must be provided to the card holder. Bridge cards will be mailed to the local office for clients who are using the county/district office as their mailing address. See Bridge Cards Received by the Local office in this item. Note: SNAP clients must have their Bridge card and access to their benefits to meet the standard of promptness. SNAP benefits are not available to the client until the day after the benefits are authorized. Head of Household Changes If the HOH on a case changes, remaining benefits in the account do not transfer to the new HOH's Bridge card. The previous HOH retains access to the remaining benefits in their account. Any subsequent benefits issued on a case will be added to the new HOH’s Bridge card. If the HOH change is due to death or incarceration (prison) see; Deceased or Incarcerated Household Changes in this item. Deceased or Incarcerated Household Changes If an individual is either deceased or incarcerated (prison) and has ever had access to a Bridge card their access, as well as the authorized representative's access, will be terminated once updated accordingly in Bridges. If the HOH is deceased or incarcerated (prison) and there are other members of the household who are entitled to the benefits, a new HOH will need to be determined from one of the remaining adult group members; see Designation of Head of Household in Bridges Administrative Manual (BAM)115 Application Processing. A DHS-3503, Verification Checklist, will be issued by Bridges to allow the household 10 days to provide their choice of a new HOH. If verification is not received, the EDG will close for failure to verify. Exception: For SNAP only, if a new HOH is not chosen, the EDG will not close. The specialist must choose a new HOH from the remaining group members.
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Once designation of a new HOH is received, enter the new HOH into Bridges. Transfer of Funds If the HOH is deceased or incarcerated (prison), available benefits may be transferred to another group member who is the new HOH. Benefit transfers must be approved by policy. To request the transfer of the benefits, send an email to the appropriate policy email box; see Policy Interpretations in Bridges Eligibility Manual (BEM) 100, Introduction. Include the following information: • Case Name. • Case Number. • Name and Recipient ID of old HOH. • Name and Recipient ID of new HOH. • The reason for the transfer. Note: When issuing an over-the-counter Bridge Card to a new HOH that will receive a benefit transfer due to death or incarceration (prison) of the previous HOH, policy approval must accompany the benefit transfer request. Adjustment Processing It may be necessary for the EBT vendor to review and adjust EBT transactions. The EBT vendor and/or retailer/TPP can initiate an adjustment to resolve error and out-of-balance related to system problems. Client Initiated Adjustment Process The EBT vendor, on behalf of a client complaint, can initiate an adjustment to resolve a transaction error. The adjustment will reference an original settled transaction, which is partially or completely erroneous. The EBT vendor shall have the capability to process the adjustment and have this reflected in the client’s account. Adjustments made by the EBT vendor will cause money to be moved either to or from the client’s EBT account and will impact the daily settlement. Notification of pending debit adjustments must be provided to the department so that notification can be provided to the client. The department will issue the MDHHS-6062, Notice of Electronic Transfer Benefit (EBT) Client Adjustment Determination, within one business day of notification of the decision from the EBT vendor,
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informing the client of the decision and of their hearing rights. Clients have 90 calendar days in which to request a hearing if they do not agree with the determination. Retailer Adjustment Process The EBT vendor, in communication with the retailer, can initiate an adjustment to resolve or correct a transaction for benefits utilized by the client. The EBT vendor shall have the capability to process the adjustment and have this reflected in the client's account. Adjustments made by the EBT vendor will cause money to be moved either to or from the client's EBT account and will impact the daily settlement. The department will issue the MDHHS-6063, Notice of Electronic benefit Transfer (EBT) Retailer Benefit Adjustment Determination, within one business day of notification of the decision from the EBT vendor, informing the client of the decision and of their hearing rights. Clients have 15 days to request a hearing in order to prevent the payment from being taken from the EBT account prior to the final decision. Clients who do not file a hearing request within 15 days may still request a hearing within 90 days of notification but the benefits will be removed from the EBT account. Authorized Representative The authorized representative (AR) is chosen by the client and can only access the SNAP account. Entering the AR’s name in Bridges will automatically generate a Bridge card. The AR’s Bridge card is mailed to the client’s address. It contains the HOH’s and AR’s names. The AR is identified with “ARFS” following the name on the card. It is the client’s responsibility to give the Bridge card and the PIN to the AR. Note: Bridge cards are not issued to the HOH’s spouse unless the spouse is designated as the AR. Clients who no longer want their AR to have access to their SNAP benefits may contact FIS and request them to deactivate or status the AR’s card, thus ending the AR’s access to benefits immediately. Once a card is deactivated it cannot be reactivated, even if the same person is requested again as the AR.
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Changing the AR in Bridges will deactivate the AR’s card, however, not immediately. Advise a client who contacts MDHHS first, to also contact FIS to deactivate the AR’s card. If a client wants to change the AR and the person is not listed in the current MDHHS-1171, Assistance Application, then a DHS-247, Request for Food Assistance Authorized Representative, must be completed: see BAM 110, Authorized Representative. If the AR performs fraudulent activity involving a client’s account, lost or stolen benefits are not replaced. If the fraudulent activity was done with the client’s knowledge, it may result in criminal charges against the client and/or the client’s benefits may be reduced. Third-Party Payee/ Protective Payee Third-party payees/protective payees on cash assistance cases are issued a Bridge card and can only access the client’s cash benefit account. The Bridge card is mailed to the third-party payee/protec- tive payee’s address on Bridges and will contain only the third-party payee/protective payee’s name. When there is a third-party payee/protective payee, the client cannot access the cash account. Clients with a third-party payee/protective payee still have access to the SNAP account. If a group has both an AR and a third-party payee/protective payee, it may be the same person or different people. If it is the same person, that person will receive two Bridge cards, one to access the SNAP account and the other to access the cash benefits; see BAM 420, Third-Party Payee. Cash Third-Party Payee/Protective Payee Changes The following explains who can access the cash account when there is a change to the third-party payee/protective payee: • If the third-party payee/protective payee changes, the new third-party payee/protective payee will be able to access any existing benefits in the cash account with their new Bridge card. • If the third-party payee/protective payee is deleted in Bridges, the third-party payee/protective payee will no longer have access to any benefits. Access will revert to the HOH who will have access to all the benefits in the cash account.
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An over-the-counter Bridge card cannot be issued to a third- party payee/protective payee on a new cash assistance case opening. LOCAL OFFICE ISSUED BRIDGE CARD Local office over-the-counter issued Bridge cards are permanent cards and do not have the client’s name printed on the card. Bridge cards may be issued by the local office upon receipt of an email from the Eligibility/Family Independence Specialist or Supervisor (ES/FIS/Supervisor). The ES/FIS/Supervisor must list the HOH's name and recipient identification and indicate in the authorization that an over-the- counter card is to be issued. A Bridges Case-Search Summary screen print including case number, case name and HOH recipient ID must be retained with the card issuance documentation. Valid photo identification must be presented by the cardholder to receive the card. Note: If issuing an over the counter to a new HOH that will receive a benefit transfer due to the death or incarceration (prison) of the previous HOH, the policy approval email must accompany the request. Food Stamp Authorized Representative (AR) Bridge Card It is not advised to issue an AR an over-the-counter Bridge card because of possible disagreements with the client. Issuing a Bridge card to an AR is only suggested in emergency situations (for exam- ple, the AR has lost their Bridge card, and they need to immediately shop for an individual who is unable to shop). An AR the over-the-counter Bridge card cannot be issued the same day a case is opened in Bridges or on the same day the AR is added to the SNAP case.
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GROUP HOMES
Authorized Retailers Group homes approved as FNA-certified retailers are supplied with the necessary POS equipment for processing EBT transactions in the group homes. New group homes requesting to be FNA-certified must contact FNA to become an authorized retailer. Provide group homes with the address and phone number for the FNA Field Office based on their county. Retailers interested in accepting the Bridge Card for food benefits purchases must be authorized by FNA. To become an authorized retailer, apply online at www.fns.usda.gov/snap or call the Supplemental Nutrition Assistance Program at 877-823-4369. Retailers not authorized by FNA are eligible to participate by accepting the Bridge Card for cash benefits only and must contact retailer operations to receive a survey form and a list of certified third-party providers with which they may contract to provide EBT cash benefit services. If you would like this information mailed to you, or if you have questions regarding your contract, call Retailer Operations at 1-888-529-1693. Group homes acting as FNA-certified retailers permit clients to exchange their benefit dollars for food by swiping their Bridge card through the home’s POS device. The Bridge card transaction is processed between the first and the 15th of the month to reduce the client’s monthly SNAP benefit by half. The group home’s account is increased by the amount deducted from the client’s account. A second transaction is done between the 16th and the last day of the month for the remaining balance, again debiting the client’s account and crediting the group home’s account. Authorized Representatives Those homes that are not approved as authorized retailers may be an authorized representative for the clients in their homes. In these situations, an employee (such as the food buyer) of the group home is identified as the AR for the residents in the home. This person is authorized by the client and the facility to act as an AR, accessing only the client’s SNAP benefits at a FNA retailer location with a
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POS terminal; see Authorized Representatives in BAM 110, Application Filing And Registration. Benefit Access Clients and/or their FSARs access benefits with their Bridge card and PIN at automated teller machines and at POS devices at retailers displaying the Quest ® logo or sign. If the case closes, the cash or SNAP benefits remaining on the Bridge card are still available to the client. They may continue to access these benefits in the account until they are depleted or expunged. If the cash account balance contains enough to pay the transaction plus any applicable client fees; see Fees in this item, the account is debited for that amount. An approval message is sent back to the automated teller machine/POS device where either the purchase is completed, or cash is dispensed. If the cash account does not have sufficient funds to cover the transaction, a denial message is sent back to the access device. Clients can then contact the Interactive Voice Response Unit for information regarding their account. See Customer Service, Interactive Voice Response Unit in this item. Cash Benefits and Availability Dates FIP and SDA clients receive ongoing benefits, early payments (EPs) and supplemental benefits less than $1,000 in their EBT cash account. The ongoing semi-monthly cash assistance EBT deposits are available on the warrant date shown in the issuance deadline schedule in Reference Manuals RFS 305, Bridges Cash And FAP Transaction Deadlines And Issuance Schedules. Supplements and EPs are available the day after authorized. Cash may be obtained only from a client’s cash account. Exception: Benefits on closed cases, EPs over $1000, supplements over $1000 and all replacement benefits are issued as warrants. Benefits can be accessed: • At any automated teller machine that accepts Quest® clients. • At a check cashier displaying the Quest® sign/logo. • By making a purchase at retailers who accept the Bridge card.
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• Through a cash-only POS transaction at a retailer that allows the option. • As cash back when making a purchase through a POS device located in a retail or merchant establishment that accepts the Quest® logo. Note: The amount of cash back allowed depends on the retailer's policy. The client should ask the retailer before shopping. Fees Clients are allowed cash withdrawals from an automated teller machine (ATM) without transaction fees. However, depending on the ATM selected, there may be an ATM fee charged. It is the client's responsibility to pay for these fees. Such fees will be debited from their cash account balance at the time of the transaction. Note: Clients are not assessed a fee for accessing cash benefits with their Bridge card at a POS terminal. Surcharges Unlike fees, an automated teller machine/network surcharge is the charge for using a particular bank’s automated teller machine. Cli- ents are given the option of paying the surcharge before their withdrawal. A question appears on the screen telling the client the cost of using that automated teller machine. If clients do not want to pay the surcharge, they may decline by pressing cancel, and their Bridge card is returned. They can then access another automated teller machine somewhere else with either a lesser surcharge or no surcharge at all. SNAP BENEFITS AND AVAILABILITY DATES All SNAP benefits are deposited into the client’s EBT SNAP account. New openings (including expedited issuances and supplements) are available to clients the day after the client information and benefits are authorized in Bridges. Ongoing SNAP benefits are available on the dates listed in RFS 305, and available on the same day of the month each month. The date depends on the last digit of the client’s recipient ID number.
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Clients access their SNAP benefits: • At any FNA authorized POS retailer. • Through the use of EBT paper vouchers issued by FNA authorized merchants and retail establishments for eligible food items when: • The FNA certified merchant or retail establishment does not have technical equipment to process the EBT transaction of SNAP benefits. • There has been a technical problem that has resulted in the malfunction of the EBT system. Note: Fees are not charged for accessing SNAP benefits. PERSONAL IDENTIFICATION NUMBER (PIN) The PIN is a four-digit code which identifies the user to the EBT vendor. Anyone with access to both the PIN and Bridge card has access to the recipient’s benefits. Clients should be advised to keep their PIN a secret, memorize it, and not write the number on the card. Clients must enter the PIN each time they use an automated teller machine or point-of-sale (POS) device. When the PIN is entered, four stars will show on the screen instead of numbers to prevent anyone from seeing the clients’ PIN. PIN Selection/Change When clients receive their Bridge card, they must call the Interactive Voice Response Unit at 1-888-678-8914, use the ebtEDGE mobile application, or visit https://cardholder.ebtedge.com/, to activate their card and select a PIN. Note: Changing the PIN periodically is a method to increase account security. PIN Lock/Reset Clients have four consecutive attempts to enter the correct PIN. After the fourth incorrect attempt, clients are locked out and cannot use their Bridge card until 12:01 a.m. the next day. The client’s card
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can be reset prior to 12:01 a.m. by contacting the customer service representative and providing the correct personal information. INTEGRATED VOICE RESPONSE UNIT Clients contact the Interactive Voice Response Unit, by calling 1- 888-678-8914 from a touchtone phone. The Interactive Voice Response Unit number is listed on the back of the Bridge card, and is available 24 hours a day, seven days a week. By calling the Interactive Voice Response Unit, the client will be able to: • Select/change a PIN. • Obtain account balance(s). • Hear the last 10 transactions. • Obtain information on where and how to use their card. • Obtain benefit(s) availability dates. • Activate their card.
Customer Service Representatives If clients have questions or difficulties providing the information through the Interactive Voice Response Unit, they are transferred to a customer service representative for further assistance. Examples of services offered by customer service representatives include: • Procedures on how to select, change or reset a PIN. • Explanations of why a card may not be working. • Taking reports of lost/stolen/malfunctioning cards and initiating processes to replace a card. • Reviewing their account balance. • Mailing a two-month account history statement to the caller’s last known address. • Deactivation of an AR’s card. Note: MDHHS staff should never call the Integrated Voice Response Unit/customer service representative for the client.
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LEAVING MICHIGAN
Cash Assistance EBT clients who move out of state can still access the remaining benefits from their Michigan EBT account by using out of state ATM's displaying electronic benefits logo or stores displaying a Quest® sign/logo. SNAP SNAP groups who move out of state can still access their remaining SNAP benefits at participating food retailers. Note: If on the last day of the month a SNAP case has an out of state address in Bridges and the negative action extends into the following month, the system will not issue an ongoing monthly issuance for the closure month; see Adequate Notice in BAM 220, Case Actions. Expungement Benefits on a cash account that have not been accessed for 365 days will be expunged and not available to the client. Benefits on a SNAP account that have not been accessed for 274 days will be expunged and not available to the client. Deceased SNAP HOH Expungement When a date of death has been entered in Bridges for a SNAP head of household (HOH), the HOH's EBT card will no longer be accessible. The remaining funds will be expunged from the account after 62 days from the date the HOH's death was recorded in ebtEDGE. Prior to day 62, SNAP benefits remaining on the deceased HOH's EBT account are potentially eligible to be transferred to an eligible EBT account. See; Transfer of Funds in this item, for additional information. Replacing Expunged Benefits FIP and SDA
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See BAM 505, Returned/Cancelled Benefits, for replacing expunged cash benefits. Exception: Unaccessed cash benefits which are entirely state funded, for example, SDA benefits and FIP benefits on certain cases will not be expunged. Instead, these benefits will be escheated; see BAM 505, Returned/Cancelled Benefits, replacing Escheated Benefits. BRIDGE CARD REPLACEMENT If the Bridge card is lost, stolen or damaged, the client, third-party payee/protective payee and/or the AR must immediately notify FIS by calling the Interactive Voice Response Unit. Any benefit loss that occurs prior to this notification is the client’s responsibility and will not be replaced. Clients contact the Interactive Voice Response Unit, by calling 1- 888-678-8914 from a touchtone phone. The Interactive Voice Response Unit number is listed on the back of the Bridge card, and is available 24 hours a day, seven days a week. Clients must speak to a Customer Service Representative to report lost/stolen/malfunctioning cards who will initiate processes to replace a card. Once a Bridge card is reported as lost or stolen, FIS immediately deactivates the current card and will reissue a new one at the client’s request. Replacement cards are mailed in an inactive status and will not retain the original PIN. Cards will arrive within two to five calendar days. The HOH or AR’s card(s) are mailed to the HOH’s address, and third-party payee/protective payee cards are mailed to the third-party payee/protective payee’s address. If cash and/or SNAP benefits are accessed after the client contacts FIS but before they deactivate the old card, the benefit replacement is the responsibility of FIS and not MDHHS. MDHHS only replaces SNAP benefits when food is destroyed in a domestic misfortune or disaster; see; Domestic Misfortune or Disaster in BAM 502, Food Benefit Replacement. Replacement Fee Clients may receive only one free Bridge card replacement during their lifetime. The client’s authorized representatives or third-
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party/protective payees may only receive one free Bridge card replacement as well. Clients’ available benefits will be reduced to cover the cost of all subsequent replacement cards with no exceptions granted. Even if an error is made with the spelling of an authorized representative or third-party payee/protective payee’s name and it is discovered on a future date, there is no way to reverse the charge or reimburse the client. The available benefit reduction for a card replacement is $5.51 whether the card is mailed by the US postal service or replaced by a local office over the counter card. For SEBT only cards, the replacement fee will be $1.00. Example: Sally has an authorized representative, named Sam. Sam loses his card and receives the one free replacement authorized representative card. If Sam loses the replacement card or Sally changes her authorized representative, her available benefits will be reduced for any future authorized representative cards. Note: Sally is still eligible to receive one free replacement card for herself before her available benefits will be reduced to cover the cost of her replacement card. Benefit Reduction Process The EBT vendor determines if the entire replacement fee is available. If the entire fee is available in the client’s cash account, the fee will be deducted from the available benefits. If not available, they will determine if the entire replacement fee is available in the client’s SNAP account. If neither account has the entire replacement fee available, the fee will be deducted the next time an account has the available balance (starting with the cash account). If the replacement fee is still not available after 365 days, the fee will be expired.
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Bridge Cards Received in Mail by Local Office Michigan EBT Bridge Cards are mailed to the local office for those recipients whose address in Bridges is the local office. If the HOH has an authorized representative, that card is also sent to the local office. Secured Bridge Card File Each local office must establish and maintain a Secured Bridge Card File for all EBT cards received in the mail. A secured file means a locked strongbox or cabinet with limited access during business hours. Card Issuance Clerk Each local office must designate a card issuance clerk to control EBT cards received in the mail using the DHS-61, Daily Record and Disposition of Checks/Warrants/EBT Cards. Bridge Card Disposition EBT Cards received in the mail must be released to recipient as soon as possible. Disposition action must be taken for all cards within 30 calendar days after the card is received. Note: Specialists and the card issuance clerk should make an effort to make sure HOH/Protective Payee/FSAR has been notified before the card is destroyed. In extenuating circumstances (client disability, major illness, etc.) where the client is unable to pick up the card from the local office, the card may be mailed. If the address on Bridges is the local office, the client must be contacted to obtain a valid mailing address. In these instances, the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment, and a prepaid postage return envelope must be included in the mailing with the card. The client should be instructed to enter entire card number, sign, date, and return the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment to the local office. Photocopies of the mailing envelope and the contents should be made and retained by the local office. When the signed DHS-3955-A-EBT, Bridge Card Issuance Log Attachment is
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returned by the client, it should be attached to the corresponding DHS-61. Refer to Destruction of Bridge Cards section in this item for cards not released within 30 days. Bridge Cards Released from Local Office Card Issuance Clerk: 1. Retrieve EBT 9, Michigan EBT Bridge card from secure file and corresponding DHS-61, Daily Record and Disposition of Checks/Warrants/EBT Cards. 2. Review the following columns on the DHS-61 for completeness. • In Case Number column, case number and case name. • In Case Name column, case name and address Note: The following columns on the DHS-61 are not used for EBT cards received in the mail. • Load Number. • Check/Warrant Date. • Check/Warrant Amount. 3. Valid photo identification is preferred by the HOH/Protective Payee/FSAR to receive the card. In the absence of valid photo identification, collateral contact and signature on the DHS- 3955-A-EBT, Bridge Card Issuance Log Attachment by a specialist or supervisor is acceptable. Proper sources of identification are found in BEM 221, Identity. In the event a photo identification is unavailable or the ability to document the client's identity via a collateral contact is unattainable, please use the following: Verify all three below: • Name of Customer. • Date of Birth (DOB). • Home address (or mailing address if homeless).
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Verify A combination of two of the following below: • Case number. • Bridges individual ID. • Last 4 digits of social security number. • Monthly SNAP benefit amount. • Monthly cash benefit amount • Current Medicaid Health Plan the caller is enrolled in. • Name and DOB of one other household member on the case. Note: A Protective Payee or a Food Stamp Authorized Representative (FSAR) can only pick up a card that has their name on it. Cards with the recipient's name cannot be picked up by the Protective Payee or the FSAR. 4. Ask HOH/Protective Payee/FSAR to open mail envelope containing EBT-9, Michigan EBT Bridge card. 5. Request card from HOH/Protective Payee/FSAR to finish release process. • On DHS-61, in Check/Warrant No. column, enter entire EBT Bridge Card number. 6. Complete the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment. • Enter entire number from card on EBT Card Number line. • Enter Case Name (HOH) from the Bridges Case- Search/Summary on Client Name line. • Enter HOH's individual number from the Individual # field on the Bridges Case-Search/Summary on Recipient ID/Case Number line. • On Authorized Rep line, if card is being issued to the FSAP, enter name from Alternate Payee field on Bridges Alternate Payee/Authorized Representative - Summary screen.
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• Record identification type and number on Type of ID Presented and ID number lines, respectively, on DHS- 3955-A-EBT Bridge Card Issuance Log Attachment. In the absence of valid photo identification, Specialists or Supervisor confirms collateral contact ID by signing and dating the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment on Type of ID Presented line. 7. Request HOH/Protective Payee/FSAR to sign on client or authorized Representative Signature line and enter date on Date line of DHS-3955-A-EBT, Bridge Card Issuance Log Attachment. 8. Release new card to HOH/Protective Payee/FSAR and request HOH/Protective Payee/FSAR to sign and print name on the back of the card. Note: Replacement cards for the HOH are not to be given to the FSAR by local office staff. The FSAR should only receive their own card. 9. If needed/requested, assist HOH/Protective Payee/FSAR in selecting a Personal Identification Number (PIN) on the POS device. Note: If the card is a replacement, a new PIN is not required. If the card is for a new case, A PIN can be created on the POS device in the local office or by calling FIS. The DHS-PUB-322, How to Use Your Michigan Bridge Card pamphlet must be provided with each initial over the counter (OTC) Bridge card issued in the local office. 10. Card issuance clerk must sign on Issued by Signature line and enter date on Date line of the DHS 3955-A-EBT, Bridge Card Issuance Log Attachment. 11. Complete the DHS-61 by entering the date in Disposition Date column and indicate in Released to/Address mailed to/Witnessed by column by the person the card was released to. Note: The cardholder is not required to sign the DHS-61.
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12. Attach signed DHS-3955-A-EBT, Bridge Card Issuance Log Attachment to DHS-61. Secured Bridge Card File Maintenance 1. Weekly, the Card Issuance Clerk must verify there is an EBT-9 in secured file for each open (undisposed) line in the Manner of Disposition section on the DHS-61. • Specialists and the Card Issuance Clerk should make an effort to make sure HOH/Protective Payee/FSAR has been notified before the card is destroyed. 2. The Card Issuance Clerk must initial and date in the Checked by column. Destruction of Bridge Card 1. Pull the DHS-61(s) and all corresponding cards which have been in the secured Bridge card file for more than 30 calendar days. 2. Destroy cards by cutting them into at least two pieces. Note: The destruction must be witnessed by one additional employee. 3. Enter the date in Disposition Date column on the DHS-61. 4. Enter "DESTROYED" in the void column on the DHS-61. 5. Both witnesses must sign in Released to/Address Mailed to/Witnessed by column. See Reconciliation, Reconciliation of DHS-61 with the DHS- 3655-A-EBT. Bulk Over-The- Counter Bridge Cards Received by Local Office The local office is responsible for controlling prenumbered documents. These documents are referred to as controlled documents. EBT-9, Michigan EBT Bridge Cards are controlled documents.
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The inventory of each controlled document is maintained using the DHS-4070, Controlled Document Log. All controlled documents received and distributed from the inventory must be recorded. The inventory of unused documents must be stored in a secured place such as a locked file cabinet within a vault, a safe, or a locked file cabinet outside a vault. A working supply is a reasonable number of documents used weekly/daily by the local office and is distributed to the Card Issuance Clerk. If the local office chooses to maintain a working supply of EBT-9 cards, the documents that have been distributed as a working supply must be kept in a locked file cabinet when not being used. Control and accountability for the inventory of EBT-9, Michigan EBT Bridge Cards must be entrusted to an employee, referred to as a Designated Employee, not directly involved with the issuance of the documents. Note: Disregarding the last (random) digit, EBT-9, Michigan EBT Bridge Cards must be used in sequential order. DHS- 4070 Complete the DHS-4070, Controlled Document Log. 1. Local/District Office - Enter name of local or district office. 2. Document Type - Mark the box for Other-Document No. Name - Enter "EBT-9" 3. Date - Enter the month, day and year inventory is received, distributed, or returned. 4. Inventory Received - Complete this section when a supply of EBT-9, Michigan EBT Bridge Cards is received. 5. Document Numbers - Enter the entire beginning and ending numbers of the series of EBT-9, Michigan EBT Bridge Cards received. 6. Total - Enter the total number of EBT-9, Michigan EBT Bridge Cards received. 7. Initials - Verify there are no missing documents. Initial as confirmation.
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8. Inventory Distributed - Complete this section when EBT-9, Michigan EBT Bridge Cards are distributed as a working supply to the Card Issuance Clerk. 9. Document Numbers - Enter the entire beginning and ending numbers of the series of EBT-9, Michigan Bridge Cards distributed. Note: Disregarding the last (random) digit, EBT-9, Michigan Bridge Cards must be used in sequential order. 10. Total - Enter the total number of EBT-9, Michigan EBT Bridge Cards distributed. 11. Initials - Card Issuance Clerk: Receive working supply of EBT-9, Michigan Bridge cards from designated employee. Verify there are no missing cards in sequential order received. Initial as confirmation. Note: Items 12-16 are optional and only need to be completed if the local office chooses to return the working supply to inventory daily. 12. Returned to Inventory - Complete this section when EBT-9, Michigan Bridge Cards are returned to inventory by Card Issuance Clerk. 13. Document Numbers - Designated Employee: receive working supply of EBT-9, Michigan Bridge Cards from Card Issuance Clerk. Enter the entire beginning and ending numbers of the series of EBT-9, Michigan Bridge Cards returned to inventory. 14. Total returned - Enter total number of EBT-9, Michigan Bridge Cards returned to the inventory. 15. Total Used - enter the difference between column 10, Total, and column 14, Total returned. 16. Initials - Verify there are no missing documents in sequential order returned. Initial as confirmation. 17. Balance on Hand - Enter the total number of EBT- 9, Michigan EBT Bridge Cards in inventory.
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Local Office Bridge Card Issuance Initial or replacement Bridge cards can be issued by the local office upon receipt of ES/FIS/Supervisor authorization to issue an over- the-counter Bridge card. Card issuance process should not be initiated until card recipient is present. Valid photo identification must be presented by the HOH/Protective Payee/FSAR to receive the card. In the absence of valid photo identification, collateral contact, and signature on the DHS-3955-A- EBT, Bridge Card Issuance Log Attachment by a specialist or supervisor/manager is acceptable. Proper sources of identification are found in BEM 221, Identity. Note: The local office will not issue a replacement Bridge Card to an AR that has the status reason of "statused by primary". This status reason indicates the client no longer wants the AR to have access to their benefits. Card Issuance Clerk: 1. Receive authorization to issue over-the-counter Bridge card from ES/FIS/Supervisor. A print of the authorization must be retained with the card issuance documentation. Note: When issuing an over-the-counter Bridge card to a new HOH that will receive a benefit transfer due to the death or incarceration (prison) of the previous HOH, the policy approval email must accompany the request. The following card issuance process should not be initiated until the card recipient is present. Exception: In extenuating circumstances (client disability, major illness, etc.) where the client is unable to pick up the card from the local office, the card may be mailed. If the address on Bridges is the local office, the client must be contacted to obtain a valid mailing address. In these instances, the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment and a prepaid postage return envelope must be included in the mailing with the card. The client should be instructed to sign, date, and return the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment to the local office. Photocopies of the mailing envelope and the contents should be made and retained by the local office. When the signed
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DHS-3955-A-EBT, Bridge Card Issuance Log Attachment is returned by the client, it should be attached to the corresponding DHS-3955-EBT, Bridge Card Issuance Log. 2. Review Bridges Case-Search/Summary for completeness and accuracy including case number, case name, and HOH recipient ID. Contact ES/FIS/Supervisor if any information is incomplete or inaccurate. A screen print of the Case- Search/Summary must be retained with the card issuance documentation. 3. If issuing a replacement card, check the status of the previous card using ebtEDGE Administrative Terminal. • If the Food Stamp Authorized Representative (FSAR) card is showing "statused by Primary," on the recipient Card Management display, inform the authorized representative. End of procedure. • If any other status, go to the next step. 4. Pull the next consecutive-numbered OTC Bridge Cars from the working supply. 5. The Card Issuance Clerk must record each issuance on the DHS-3955-EBT, Bridge Card Issuance Log, and complete a DHS-3955-A-EBT, Bridge Card Issuance Log Attachment. Complete the DHS-3955-EBT, Bridge Card Issuance Log: • Enter the date in Column 1, Date of issuance. • Enter Entire number from card in Column 2, Card Number • Enter Case Name (HOH) from the Bridges Case- Search/Summary in Column 3, Recipient Name. If the card is being issued to the FSAR, enter name from Alternate Payee field in Bridges Alternate Payee/Authorized Representative - summary screen. • Enter HOH's individual number from the Individual # field on the Bridges Case-Search/Summary in column 4, Recipient ID/Case Number. • Initial in column 5, Card Issued By.
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Complete the DHS 3955-A-EBT, Bridge Card Issuance Log Attachment. • Enter the entire number from the card on EBT Card Number line. • Enter Case Name (HOH) from the Bridges Case- Search/Summary on Client Name line. • Enter HOH's individual number from the Individual # field on the Bridges Case-Search/Summary on Recipient ID/Case Number line. • On Authorized Rep line, If the card is being issued to the FSAR, enter the name from Alternate Payee/Authorized Representative - Summary screen. • Record identification type and number on Type of ID Presented and ID Number lines, Respectively, on the DHS 3955-A-EBT, Bridge Card Issuance Log Attachment. In the absence of a valid photo identification, the specialist or supervisor confirms collateral contact ID by signing and dating the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment on Type of ID Presented line. 6. Link card to HOH's Recipient Identification number using the ebtEDGE Administrative Terminal. • Print a copy of the screen "Card was successfully replaced" to retain as an attachment to the DHS-3955-A- EBT, Bridge Card Issuance Log Attachment. 7. Request HOH/Protective Payee/FSAR to sign on Client or Authorized Representative Signature line and enter date on the Date line of the DHS-355-A-EBT, Bridge Card Issuance Log Attachment. 8. Release the new card to HOH/Protective Payee/FSAR and request recipient/FSAR sign and print their name on the back of the card. Note: Replacement cards for the HOH are not to be given to the FSAR by local office staff. The FSAR should only receive their own card.
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The DHS-Pub 322 How to Use Your Michigan Bridge Card pamphlet must be provided with each initial over the counter (OTC) Bridge Card issued in the local office. 9. If needed/requested, assist HOH/protective Payee/FSAR in selecting a Personal Identification Number (PIN) on the POS device. If the card is a replacement, a new PIN is not required. If the card is for a new case, a PIN can be created on the POS device in the local office or by calling FIS (the interactive voice response unit) at 1-888-678-8914 from a touchtone phone. The Interactive Voice Response Unit number is listed on the back of the Bridge Card and is available 24 hours a day, 7 days a week. 10. Card Issuance Clerk must sign on Issued by Signature line and enter the date-on-Date line of the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment. 11. Attach the following to the signed DHS-3955-A-EBT, Bridge Card Issuance Log Attachment: • ES/FIS/Supervisor authorization • If applicable, Transfer of Funds policy approval email • Bridges Case-Search/Summary Screen print Retain Packet with the Issuance Log, DHS-3955-EBT, Bridge Card Issuance Log. 12. File Issuance Log with attachments in a secured file. Prior to reconciliation, access to this file should be limited to the card issuance clerks. 13. See Reconciliation, Reconciliation of DHS-3955-EBT with DHS-3955-A-EBT in this item.
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RECONCILIATION
Disposition of Bridge Cards Received in the Mail Bridge cards received in the mail for HOH/Protective Payee/FSAR are released, mailed, or destroyed when held over 30 days. Receipt of these Bridge cards and method of disposition are recorded on the DHS-61. A monthly reconciliation of the DHS-61 and the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment, must be performed by a supervisor or other employee not involved in the card release/mailing process. Reconciliation of DHS-61 with DHS- 3955-A-EBT 1. Pull DHS-61 with attachments from file at least once a month. 2. Verify a DHS-3955-A-EBT, Bridge Card Issuance Log Attachment, is attached for each EBT-9 Michigan EBT Bridge Card, picked up or mailed to the HOH/Protective Payee or FSAR. 3. Review each DHS 3955-A-EBT, Bridge Card Issuance Log Attachment for completeness and accuracy: • Entire EBT Card Number line must be completed. • Client Name line must be completed. • Recipient ID/Case Number line must be completed. • Authorized Rep line must be completed, if applicable. • Client or Authorized Representative Signature and Date line must be completed. • Issued by signature and date line must be completed. • Type of ID Presented line must be completed if card was picked up.
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• ID Number line must be completed if card was picked up. 4. Review each DHS-61 Manner of Disposition for completeness and accuracy. • Date in Disposition Date column must be completed. • Released to/Address mailed/witnessed by column must be completed as follows: Name of HOH/Protective Payee/FSAR card was released to. Address of HOH/Protective Payee/FSAR if mailed. Signature of witnesses (2), if card is destroyed. 5. If above items do not reconcile, resolve discrepancies, as appropriate. Note: If a release is not supported by a signed DHS-3955-A-EBT, Bridge Card Issuance Log Attachment, the reconciler is to contact the HOH/Protective Payee/FSAR to verify the card was received. 6. If the above items reconcile, sign and date the DHS-61 at the bottom of the form, to indicate reconciliation was completed. Following reconciliation, file the DHS-61 and attachments in a secured location. Documents should be retained for seven years. Over The Counter Issued Bridge Cards A monthly physical inventory and a reconciliation of documents distributed must be made with documents recorded in the local office/district office. The DHS-4351 is used for this purpose. A monthly reconciliation of the DHS-3955-EBT, Bridge Card Issuance Log and the DHS-3955-A-EBT, Bridge Card Issuance Log Attachment must be performed by a supervisor or other employee not involved in the card issuance process.
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Reconciling DHS- 3955-EBT and DHS-3955-A-EBT 1. Pull DHS-3955-EBT, Bridge Card Issuance Log, with attachments from secured file at least once a month. 2. Verify a DHS-3955-A-EBT, Bridge Card Issuance Log Attachment, is attached for each line on the DHS-3955-EBT, Bridge Card Issuance Log. 3. Review each DHS-3955-A-EBT, Bridge Card Issuance Log Attachment for completeness and accuracy. • Entire EBT Card Number line must be completed. • Client Name line must be completed. • Recipient ID/Case Number line must be completed. • Authorized Rep line must be completed, if applicable • Client or Authorized Representative Signature and Date line must be completed. • Issued by Signature and Date line must be completed. • Type of ID Presented line must be completed if picked up. • ID number line must be completed if picked up. The Following items are attached to the DHS-3955-EBT, Bridge Card Issuance Log: • Bridges Case Search/Summary screen print. • The "card was successfully replaced" screen print from the ebtEDGE Administrative Terminal. • DHS-3955-A-EBT, Bridge Card Issuance Log Attachment. 4. Generate the EBTMS210-1 MONTHLY CARD STATUS REPORT-COUNTY in EBT Edge to verify the number of cards issued on the DHS-3955-EBT, Bridge Card Issuance Log. Note: Print only the pages for your specific county using the PDF version.
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5. If above items do not reconcile, resolve discrepancies with Card Issuance Clerk, HOH/Protective Payee/FSAR, as appropriate. Note: If a release is not supported by a signed DHS-3955-A-EBT, Bridge Card Issuance Log Attachment, the reconciler is to contact HOH/Protective Payee/FSAR to verify the card was received. 6. Verify that the number of cards issued on the DHS-3955-EBT, Bridge Card Issuance Log, match the ebtEDGE reports. 7. If above items reconcile, sign and date the DHS-3955-EBT, Bridge Card Issuance Log, to indicate reconciliation was performed. 8. Following reconciliation, file the DHS-3955-EBT, Bridge Card Issuance Log and attachments in a secured location. Access to this file should be limited to the reconciler. Note: Documents should be retained for seven years. Reconciliation of Physical Inventory A monthly physical inventory and a reconciliation of documents distributed must be made with documents recorded in the local office/district office. The DHS-4351, Monthly Controlled Document Inventory and Reconciliation, must be used for this purpose. The DHS-4351, Monthly Controlled Document Inventory and Reconciliation, provides the format for performing a reconciliation. This form documents that the local office records of controlled documents used (DHS-4070 and DHS-3955-EBT, Bridge Card Issuance Log) reconciles with the physical inventory. If the above steps do not check out, resolve the problem with the Card Issuance Clerk, Recipient or FSAR, as appropriate. Note: It may be necessary to contact the recipient or FSAR to verify the card was received. If above steps do check out, sign and date DHS-3955-EBT, Bridge Card Issuance Log to indicate reconciliation was performed. DHS-4351 Complete the DHS-4351, Monthly Controlled Document Inventory and Reconciliation.
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• Local/District Office - Enter name of County or District • As of (Month/Day/Year) - enter month, day and year inventory is taken and reconciled to local office records. Physical Inventory 1. Document Type - Mark the box other: Form Number and Name Name- enter EBT-9 2. Number of Documents in Inventory (safe or locked cabinet) - Enter total number of EBT cards in inventory. Beginning Number and Ending Number - Enter the entire beginning and ending numbers of series EBT-9 Michigan EBT Bridge Cards in a safe or locked cabinet. Note: This entry is arrived at by taking physical inventory. 3. Number of Documents in Working Supply - Enter total number of EBT-9 Michigan EBT Bridge Cards in working supply for which that Card Issuance Clerk is responsible. Beginning and Ending Number - Enter the entire beginning and ending number of series of EBT-9 Michigan EBT Bridge Cards in safe or locked cabinet. 4. Total Number of Documents on Hand at the End of the Month - Enter sum of entries on lines 2 and 3. This number must equal the entry on line 10. Reconciliation 5. Number of Documents on Hand at the Beginning of the Month (must equal line 10 from previous month) - Enter the number. 6. Number of Documents Received During the Month - Enter the total number of EBT-9, Michigan EBT Bridge Cards added to inventory during the month from column 6. 7. Number of Documents Used During the Month According to the Accounting Records - Enter total number of EBT-9, Michigan EBT Bridge Cards issued. 8. Number of Documents that Should Be on Hand at the End of the Month (Line 5 plus line 6 minus line 7) - Enter number.
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9. Adjustments (plus or minus) - Enter total number of EBT-9, Michigan EBT Bridge Cards that cannot be located, were legally destroyed, or are adjustments for errors on prior months reconciliations. Explain - Enter series of numbers on EBT-9, Michigan EBT Bridge Cards reported as an adjustment and/or reason for adjustment. Note: The Office of Inspector General must be notified in writing on that same day if any EBT-9, Michigan EBT Bridge Cards are missing. 10. Total Number of Documents on Hand at the end of the Month (line 8 plus or minus line 9 must equal line 4 above) - Enter the number. A value must be entered on the above items 3, 6, 8 and 9. Enter zero, if applicable
Signatures Preparer's Signature and Date - Signed and dated by the person taking the inventory and reconciling the local office records. Reviewer's Signature and Date - Signed and Dated by Supervisor/designee. EBT AUTHORIZATION AND SECURITY To add, change or delete an employee’s access to the FIS ebtEDGE system, complete the DHS 245, ebtEDGE EBT System and either send via email to: DHS_Application_Security@Michigan.gov, or Fax it to 517-335-6146. Email is the preferred method. To reset ebtEDGE, call and create a ticket for the reset at CSC Help Desk at 517-241-9700 or 1-800-968-2644 ID DELETION Local office management responsible for EBT issuance must submit ID deletion on the DHS-245, Michigan User ID Request
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Form FIS ebtEDGE EBT System, within two business days if the EBT Application or POS Device user either: • Leaves MDHHS or the office in which the user requires EBT systems access. • No longer requires access to the EBT systems as a component of their job function. Managers must sign and email appropriate forms to MDHHS Access Security Office in central office. The DHS-246, ebtEDGE EBT Program POS User ID Request Form, must also be completed and the user deleted from the POS device. Retain the DHS-246 in the local office security file. LEGAL BASE FIP 42 USC 604(g) SNAP 7 USC 2016(i) 7 CFR 274.12 Food and Nutrition Act of 2008 MCL 400.14l
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POLICY Medicaid (MA) General lists of MA covered services are located at the end of this item; see EXHIBIT I. In this item MA includes MAGI-related and SSI-related beneficiaries. CHOICE OF PROVIDERS The beneficiary is usually free to select a provider or health care plan. However, there are some situations when the recipient may be restricted to certain providers (such as primary care provider, pharmacy, specialist provider). Reimbursement for services rendered is limited to enrolled providers except for emergencies. HEALTH PLANS Health plans provide Medicaid-covered health care services for an enrolled group of beneficiaries in a defined service area. Enrollment Beneficiaries are given an opportunity to select a health plan. If no selection is made, the beneficiary is automatically enrolled by the state’s contracted enrollment broker, Michigan ENROLLS, with a health plan in the beneficiary’s county of residence. Health plan enrollees are identified by program enrollment type (PET) codes which start with MHP-XXXX. Health plan enrollees will also receive an identification card from their health plan. There are beneficiaries who: • Must enroll in a health plan. • May voluntarily enroll in a health plan. • Are excluded from enrollment in a health plan. Persons Who Must Enroll In a Health Plan The following must enroll in a health plan, unless they are Persons Who May Voluntarily Enroll in a Health Plan or Persons Excluded from Enrollment in a Health Plan.
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• Family Independence Program (FIP) recipients. • Children under 19 (U19) beneficiaries. • Pregnant women (PW) beneficiaries. • Group 2 Under 21(G2U) beneficiaries. • Parent/Caretaker (PCR) and LIF beneficiaries. • Healthy Michigan Plan (HMP) beneficiaries. • Supplemental Security Income (SSI) recipients who do not receive Medicare. • Blind, disabled, and aged MA beneficiaries who do not receive Medicare. • Persons with full Medicaid coverage and Children Special Health Care Services (CSHCS). Persons Who May Voluntarily Enroll In a Health Plan The following may voluntarily enroll in a health plan: • Migrants. • Native Americans. • Persons in the traumatic brain injury program. • Persons with both Medicare and Medicaid eligibility. • Persons eligible for QMB; see BEM 165. Persons Excluded From Enrollment in a Health Plan • PlusCare recipients. • Persons limited to emergency MA coverage (ESO). • Persons enrolled in the Children’s Special Health Care Services (CSHCS) program only. • Persons residing in an ICF/ID (intermediate care facility for individuals with intellectual disability) or a state psychiatric hospital.
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• Persons receiving long-term care (custodial care) in a licensed nursing facility. • Persons receiving MI Choice waiver services for the elderly and disabled; see BEM 106. • Persons receiving private duty nursing services. • Persons with commercial HMO coverage, including Medicare HMO coverage. Note: Letters are mailed out each month to Medicaid recipients who have private HMO coverage. This letter informs recipients that they are being disenrolled from their Health Plan; see EXHIBIT II for further information. • PACE (Program for All-inclusive Care for the Elderly) recipients. • Deductible beneficiaries. • Children in child caring institutions. • Refugee Assistance Program Medical Aid-only recipients. • Repatriate Assistance Program Medical-only recipients. Note: When a person(s) is excluded from health plan enrollment, other members of that person’s family may enroll in a health plan. If a beneficiary enrolled in a health plan enters a long-term care facility for custodial purposes, the health plan may initiate a request for disenrollment from the health plan; see BAM 120. The health plan may request disenrollment by calling: Michigan Department of Health and Human Services Managed Care Plan Division Quality Improvement and Program 517-241-8179 Additional Information about Health Plans For additional information about health plans, contact: Michigan Department of Health and Human Services Comprehensive Health Plan Division
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CCC Bldg. PO Box 30479 Lansing, MI 48909-7979 Michigan Enrolls: 1-888-367-6557 A list of the health plans available in each county is on the Michigan Department of Health and Human Services (MDHHS) website (Medicaid Link). This list is updated monthly. The MDHHS website address is: www.michigan.gov/mdch. Other Insurance Health plan enrollees with other insurance should advise their health plan of their insurance coverage. Covered Services The health plan is responsible for providing and arranging for all medically necessary services covered by Medicaid with the excep- tion of: • Dental care (services rendered by an oral surgeon are included in the health plan capitation rate). • Mental health services including inpatient psychiatric services (the health plan is responsible for up to 20 outpatient visits). • Substance abuse treatment. • Medical transportation for the three services listed above; see BAM 825. • Personal care services. • School-based services. The health plan is responsible for providing up to 45 days of restor- ative health care which is intermittent or short-term, restorative or rehabilitative nursing care. The health plan may also provide services that are not covered by MA.
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MICHIGAN PHARMACEUTICAL BEST PRACTICES MA MDHHS has contracted with Magellan Medicaid Administration, Inc. to be the pharmacy benefits manager for its fee-for-service health programs and pregnancy-related pharmacy services for Maternity Outpatient Medical Services (MOMS) beneficiaries. The pharmacy benefits manager is responsible for all of the following: • Prior authorizing certain drugs. • Processing pharmacy claims. • Approving payment to pharmacies. • Other administrative functions to ensure that appropriate payments are being made. Magellan Medicaid Administration, Inc. does not prior authorize or pay claims for Medicaid contracted health plans. Prior Authorization Drugs that require prior authorization appear on the Michigan Phar- maceutical Products List (MPPL). Physicians or other prescribers may request prior authorization by contacting First Health Services. Magellan Medicaid Administration, Inc. MAP Department 4300 Cox Road Glenn Allen, VA 23060 Telephone: 1-877-864-9014 Fax: 1-888-603-7696 or 1-800-250-6950 Hearing Rights A beneficiary is notified in writing within 10 calendar days of a prior authorization denial. The notice tells the beneficiary how to apply for a MDHHS administrative hearing. The MDHHS hearings application form and a stamped envelope are included with the notice.
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HEALTHY KIDS DENTAL MA MDHHS has contracted with two Dental Health Plans (DHPs) to administer the healthy Kids Dental benefit statewide. The DHPs administer the Medicaid dental benefit to all Medicaid beneficiaries under age 21. The dental services provided through the DHPs include at a minimim, the same dental services provided through fee-for-service (FFS) Medicaid. DHPs, at their discretion may cover additional dental services not covered through FFS Medicaid. Healthy Kids Dental is not limited to persons receiving MA under Children Under 19 (U19). It is for all MA beneficiaries under age 21. Beneficiaries must see a dentist that participates with the beneficiairy's chosen DHP dental network. Beneficiaries may contact their DHP's customer servcie with questions. Enrollment All HKD beneficiaries will initially be automatically enrolled on an alternate basis in one of two DHPs. MDHHS will mail confirmation letters to all beneficiaries who have been automatically enrolled in a DHP. The letter will include the beneficiary’s assigned DHP and information on their right to choose a different DHP. Beneficiaries will be able to contact the Michigan enrollment broker, Michigan Enrolls, for help with their DHP selection. Michigan Enrolls is independent from the DHPs and will provide beneficiaries with choice counseling information, including dental provider participation in each DHP’s network. Beneficiaries will be able to call or send a form to Michigan Enrolls to change their DHP. Any change of DHP made by a beneficiary will be made on a prospective basis. If the beneficiary contacts Michigan Enrolls prior to the last business day of the month, the new DHP enrollment should be effective on the first day of the following month. For example, a beneficiary who calls Michigan Enrolls on October 5, 2018, and selects a different DHP will be changed to the new DHP effective November 1, 2018.
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The beneficiary may change DHPs within 90 days of the DHP enrollment effective date. MDHHS gives beneficiaries the opportunity to change DHPs without cause during each beneficiary’s annual open enrollment period. ID Cards In addition to the MI health card, Healthy Kids Dental beneficiaries will receive a benefit ID care from their assigned DHP. If the card is lost the beneficiary must call their DHP customer service to request a replacement card. The beneficiary’s SSN is on the card, not the MA beneficiary ID number. Retroactive Enrollment The effective date of enrollment in the DHP will be the first day of the month that CHAMPS receives information that the beneficiary has been determined eligible for Medicaid. For example, if CHAMPS is notified that a beneficiary has been determined eligible on October 24, 2018, the beneficiary will have a DHP enrollment effective date of October 1, 2018. Covered Dental Services Healthy Kids Dental provides services that are applicable to persons under age 21. These services include: • Emergency services. • Diagnostic services. • Preventive services. • Restorative services. • Limited adjunctive services. • Endodontic services. • Limited crown coverage. • Prosthodontics. • Removable prosthodontics. • Oral surgery services. • Early and Periodic Screening, Diagnosis and Treatment (EPSDT) services. • All medically necessary services. At a minimum, the DHP’s coverage of these services is the same as for fee-for-service MA. DHPs at their discretion may cover additional services.
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HEALTH PLAN BENEFICIARY INFORMATION MA The health plan may notify the local office specialist of a beneficiary's pregnancy. The health plan will fax a MDCH-2010, Health Plan Beneficiary Information, to 517-346-9888 with the pregnancy information they have for the beneficiary. Review the information from the health plan and update Bridges as appropriate. BENEFIT MONITORING PROGRAM (FEE-FOR- SERVICE) MA State and federal regulations require the Medicaid program to conduct benefit utilization reviews to ensure the medically necessary services are being provided to program beneficiaries. The Benefit Monitoring Program (BMP) is in place to monitor program usage and to identify beneficiaries who may be over- utilizing and/or misusing their Medicaid services and benefits. While in the BMP beneficiaries may be assigned to one or more provider through which they can obtain medical services. For further information or to make a referral contact: Michigan Department of Health and Human Services Benefit Monitoring Program PO Box 30170 Lansing, MI 48909 Phone: 855-808-0312 EPSDT/WELL CHILD PROGRAM MA The Early Periodic Screening Diagnosis Treatment Program (EPSDT) Well Child Program consists of well-child visits, immunizations and early detection and treatment of diseases for beneficiaries under age 21. The objective of this preventive health
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care is early intervention to detect and treat mental or physical disease. The same components of a well-child visit and the same interval schedule are used regardless of whether the child is in a health plan or is fee-for-service. MDCH Publication (795), Michigan Free Health Check-ups for per- sons 21 and younger, explains the well-child visits. http://www.michigan.gov/mdch ENROLLED PROVIDER BILLING PROCEDURES (FEE-FOR-SERVICE) MA Enrolled providers are aware of the covered and excluded services available to MA beneficiaries. Providers must use MA billing procedures to obtain payment for services performed. Billings should be submitted within 12 months from the date of service. Twelve Month Billing Exceptions Exceptions to the 12 month billing policy can be made if the delay is caused by agency error or as a result of a court or administrative hearing decision. Agency errors are limited to: • Delayed Bridges coding, including PET code changes. • Disability Determination Service (DDS) review. • Administrative review. • Delayed eligibility determination. Exceptions cannot be granted due to provider delays in billing or failure of a recipient or provider to obtain prior authorization. Form MSA-1038, Request for Exception to the Twelve Month Billing Limitation for Medical Services, is an internal document and must be completed by local office staff to begin the exception process. The completed MSA-1038 should be sent to: 1038@michigan.gov. A family independence manager, district manager, or other office designee must be copied on the email. A copy of the hearing deci- sion is no longer required; however, the hearing registration number must be indicated on the MSA-1038.
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MDHHS will notify the specialist within 30 days of the decision. If approved MSA will notify providers to bill Medicaid as usual but to enter in the comments section of the claim, “MSA 1038 approval on file”. MEDICAL SERVICES PROVIDER POLICIES MA Local office staff is not expected to be the beneficiary's primary source of information for covered services. The providers of medical services are best equipped to determine medical needs and whether those services are covered by MA as specified in the MA provider manuals. Some basic guidelines: • The provider is required to bill all other insurances prior to billing MA. • Providers must be appropriately licensed and/or certified before entering into an agreement with MDHHS to participate in the MA program. • Enrolled providers receive direct payment for services rendered but must agree to provide services according to the policies published in the MA provider manuals. • Certain medical/dental services require the provider to obtain prior approval from MDHHS; see the MedicaidProviderManual.pdf (state.mi.us) for co-pay information. • The provider is required to accept payments received from MA as payment in full, except for patient-pay amounts authorized by MDHHS and co-payments. • The provider may seek payment from a beneficiary for services not covered if the beneficiary elects to receive the services with the prior knowledge that such services are not covered. • Institutional and nursing home providers holding a beneficiary’s funds in trust are accountable to the beneficiary and may not require the deposit of such funds with the facility. The management of such funds is subject to review by MDHHS.
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Local offices may obtain more information on medical/dental care coverage by consulting the MA provider manuals or contacting MDHHS at: Michigan Department of Health and Human Services Provider Inquiry CCC Bldg. PO Box 30479 Lansing, MI 48909-7979 Phone: 1-800-292-2550 MEDICAL/DENTAL SERVICES IN ANOTHER STATE MA A Michigan MA beneficiary may receive medical/dental care outside of Michigan. The areas beyond the Michigan borders are classified as either borderland or beyond borderland. Borderland and beyond borderland providers must comply with applicable Michigan MA policies and procedures, including prior authorization, to be reimbursed for services. Borderland Areas The borderland areas are the out-of-Michigan counties which are adjacent to the Michigan border and certain cities beyond these adjacent counties. The specific counties and cities which are borderland areas are:
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States, Counties, Cities Ohio Wisconsin • Fulton County • Lucas County • Williams County • Ashland • Green Bay • Rhinelander Indiana Indiana • Elkhart County • Lagrange County • LaPorte County • St. Joseph County • Steuben County • Fort Wayne Wisconsin Minnesota • Florence County • Iron County • Marinette County • Forest County • Vilas County • Duluth
A beneficiary is covered for medical/dental services rendered in a borderland area to the same extent that such services are covered in Michigan. Borderland providers are considered to be Michigan providers. They must be enrolled in Michigan Medicaid and adhere to the same policies as Michigan providers. Beyond Borderland Areas The beyond borderland areas are all areas of the U.S. outside of Michigan which are not borderland areas. Beyond borderland medical/dental services received by a Michigan MA beneficiary will be covered only when: • The beneficiary is temporarily out-of-state and the services are necessary because the individual's health would be endangered if travel to Michigan was required.
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• The beneficiary is temporarily out-of-state and the services are necessary because of a medical/dental emergency (as defined by the program). • The service is prior authorized by MDHHS as more readily available in another state. Prior Authorization Certain services provided by borderland providers require prior authorization the same as services requiring prior authorization by Michigan providers. Except in emergencies, the services of a beyond borderland pro- vider must be prior authorized. The beneficiary's local physician should submit the following to MDHHS: • Documentation of the need for beyond borderland services. • Beneficiary identification. • Eligibility data. The address to submit the above information is: Michigan Department of Health and Human Services Review and Evaluation Division 400 S. Pine Street PO Box 30170 Lansing, MI 48909-7979 The beneficiary's physician and the local office may also make tele- phone inquiries regarding beyond borderland services when it appears that time is of the essence. Phone: 1-800-622-0276 The Prior Authorization and Review Section may request informa- tion from local offices when evaluating the need for beyond border- land services. Prompt assistance from the local offices is appreciated. A copy of the prior authorization decision will be sent to the appropriate local office. Inquiries Refer non-enrolled provider questions about borderland or beyond borderland coverage and billings to: Michigan Department of Health and Human Services
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Provider Inquiry 400 S. Pine Street PO Box 30239 Lansing, MI 48909-7979 Providers may call: 1-800-292-2550 Claims Medicaid will pay non-enrolled Michigan and borderland providers for: • Emergency services, and • Nonemergency services with prior approval. The following occurs when non-emergency services claims are submitted by a non-enrolled provider: • The miscellaneous transactions unit will process the claim and send a letter to the provider with a Medical Assistance Provider Enrollment/Trading Partner Agreement form. • If the provider elects not to complete the Medical Assistance Provider Enrollment/Trading Partner Agreement form, the claim will not be paid. Reimbursement for services not paid by Medicaid is between the beneficiary and the provider. The provider must notify the beneficiary prior to rendering the service that it is not covered by Medicaid. Borderland providers who are not enrolled and all beyond border- land providers should submit claims to: Michigan Department of Health and Human Services Provider Enrollment Medicaid Payments PO Box 30238 Lansing, MI 48909
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PROVIDER INQUIRIES
Eligibility Verification System (EVS) MA Beneficiary information is available to medical/dental providers through an automated system called the Eligibility Verification System (EVS). If the beneficiary is eligible, the following information is available: • Beneficiary name, beneficiary ID number, gender, date of birth. • Benefit plan ID(s) for the date of service (DOS). • PET code information, source provider ID, National Provider Identifier(NPI), provider name, telephone number, address, and the patient pay amount, if applicable. • Medicaid health plan, primary care physician, including the provider name and telephone number. • Third party liability, including the payer name, payer ID, coverage type code, group number, policy number, and policyholder ID. • Pending Medicaid eligibility. Additional information is not available through EVS. CHAMPS Providers may verify beneficiary eligibility using: • CHAMPS Eligibility Inquiry. • HIPAA 270/271 (eligibility inquiry/response) transactions. Refer to the Michigan Medicaid Provider Manual, Beneficiary Eligibility and Directory Appendix Sections for further information. Providers may contact the MDHHS Provider Inquiry Helpline at 1- 800-292-2550 for questions/issues related to the eligibility response.
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The Helpline number can also be used by providers without internet access and out-of-state providers. Providers may also email Provider Support at providersupport@michigan.gov Health Plans MA Send provider questions about Medicaid Health Plans (MHP) to: MSApolicy@michi gan.govCovered Services After consulting the MA provider manuals, providers may call the following number to verify covered services or to receive billing assistance: Provider Inquiry: 1-800-292-2550. BENEFICIARY INQUIRIES
Covered Services MA Fee-for-Service -Refer beneficiary questions about MA covered services or billing problems to: Medicaid Beneficiary Helpline: 1-800-642-3195. Health Plans MA Refer beneficiary questions about MA Health Plans, including available providers in their area and enrollment to: Michigan Enrolls: 1-888-367-6557. Send beneficiary complaints and questions about MA providers to: Medicaid Beneficiary Helpline: 1-800-642-3195. Michigan Department of Health and Human Services Enrollment Services Section
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CCC Bldg. PO Box 30470 Lansing, MI 48909-9753 COMPLAINTS ABOUT PROVIDERS MA Send complaints about enrolled providers to: Michigan Department of Health and Human Services Comprehensive Health Plan Division 400 S Pine PO Box 30479 Lansing, MI 48909-7979
Michigan Department of Attorney General Health Care Fraud Division PO Box 30218 Lansing, MI 48909 24 hour hotline: 1-855-643-7283 (1-855-MI FRAUD) Email: hcf@michigan.gov
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EXHIBIT I - MA COVERED SERVICES The following are general categories of MA covered services. This listing should be used for reference purposes only. Some of the services listed are available only to certain age groups, may be limited in their scope or may require prior approval. Local office staff is not expected to be the beneficiary's primary source of information for MA covered services. The beneficiary should be advised to contact the medical services provider directly whenever information is needed regarding MA covered services. Allergy Testing/Treatment Ambulance Services Chiropractic Services Dental Services Diabetic Patient Education Program EPSDT/Well Child Services Family Planning Services Hearing Aid Dealers Hearing & Speech Center Services Home and Community-Based Waiver Services Home Health Services Hospice Services Hospital Services (Inpatient/Outpatient) Laboratory and X-Ray Services Long-Term Care (LTC) Maternal Infant Health Program Medical Supplies and Equipment Mental Health Services Methadone Maintenance Treatment Nurse-Midwife and Nurse Practitioner Services Orthotics, Prosthetics and Special Shoes Personal Care Services Pharmacy Services Physician Services (MD/DO) Podiatric Services Psychiatric Care School-Based Services Substance Abuse Treatment Services Therapy (Occupational, Physical, Speech) Transportation (BAM 825) Vision Services For questions regarding a specific service, contact Provider Inquiry at 1-800-292-2550.
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EXHIBIT II - NOTICE TO MEDICAID BENEFICIARIES WHO HAVE PRIVATE HMO INSURANCE
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LEGAL BASE MA 42 CFR 431, Subpart B 42 CFR 431.107 42 CFR, Part 440 42 CFR 441, Subpart B 42 CFR 456.3 MCL 400.109, .110 Social Security Act, Section 1927
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DEPARTMENT POLICY FIP, RCA and SDA Only Supplemental benefits are issued to correct an underissuance (i.e., the group received less assistance than they were eligible to receive). Do NOT issue supplements to correct underissuances caused by the client’s failure to report. A supplement correcting an underissuance is offset against an overissuance. The amount of the overissuance is subtracted from the amount of the supplement. This may result in the entire supplement being offset. Do not offset the following overissuances: Agency overissuances of under $125. Overissuances that have an established claim. Notify the client of the result of the offset. See the CLIENT NOTICES section in this item. AUTHORIZING SUPPLEMENTAL PAYMENTS Supplements are authorized in Bridges by certifying eligibility results that include an increased issuance for the benefit month. Authorize a separate supplement for each reason a client is supplemented and for each vendor supplemented. Court Orders and Hearing Decisions When a supplement is required by a court order or an administrative hearing decision, the supplement must be issued within 10 workdays after the court order/hearing decision is mailed. If you correct data in Bridges to implement the court order or administrative hearing decision, enter the first day of the month that the order or decision indicates the change must begin for the circumstances start/change date, report date, date client became aware and date verified for the data. If that correction returns eligibility results that support the order or decision, Bridges will
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automatically calculate the supplement. If not, the supplement must be issued manually. See MANUAL ISSUANCE SUPPLEMENTS in this item. In all other circumstances, process the supplement promptly upon receipt of verification or knowledge of the need. Vendor Supplements Vendor supplements are processed by central office accounting. Benefit Inquiry The View Benefits screen under Benefit Issuance in Bridges lists requested supplements immediately after certification. Supplements are shown as pending until the actual benefit/warrant is posted. Bridges displays the case number, grantee/provider name, type of assistance, service type, pay begin date/end date, benefit type, payment amount, recoupment amount (if any), warrant/available date, status and whether a client or vendor is being supplemented. The benefit number is displayed below the case number when the benefit/warrant is posted. EBT Payments Supplements for $1,000 or less are deposited into the client’s EBT account on the day after authorization.Bridges will display details for these deposits on the first workday after the authorization. Non-EBT Payments Supplements for amounts over $1,000 are issued as warrants. These warrants are issued approximately two days after authoriza- tion. The payment will be extracted daily and Treasury will mail the warrant on the second business day after the transaction is done. EDBC on the Same Business Day If you re-run an eligibility determination and benefit calculation (EDBC) for the same benefit month(s) on the same business day that you calculated a benefit resulting in a supplement and the new results do not indicate there is a supplement, the supplement will not be issued.
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MANUAL ISSUANCE SUPPLEMENTS Supplements that must be handled using the manual issuance pro- cess in Bridges can be completed in the local office for any months prior to the month the case converted to Bridges including the month of conversion. For all other months, manual issuance supplements must be processed in central office as policy exceptions. All manually issued supplements require second party review and approval prior to issuance. REASONS FOR A SUPPLEMENT
Increased Need Supplements are authorized in the following circumstances: A needs increase cannot be reflected in the regular benefit. See BEM 515, Changes in Need, for effective dates. A FIP group that was subject to the immunization penalty reports compliance during the month. A supplement is calculated for the whole month in which immunizations were begun. See BEM 202. The change causing increased need and the dates when it was reported and verified are recorded in Bridges. This information can be compared with Report SP-270. Fair Hearing This is a supplement in the amount ordered in a hearing decision or court order. You must issue the supplement within 10 calendar days after the decision/order is mailed. If Bridges cannot automati- cally calculate the supplement (e.g., the amount ordered is not the result of correcting data in the system), you must request a policy exception. Central office will complete the manual issuance in addi- tion to any other policy exceptions that may be required as a result of the decision/order. Agency Error Agency errors are underissuances resulting from:
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Computer or data entry errors. Inaccurate use or misapplication of policy. Failure to process a grant change on time. Correct the information in Bridges and re-run eligibility to authorize the supplement regardless of whether DHS or the client discovered the error. Excess Recoupment Payment This is a supplement to repay assistance when DHS recoups more than the amount of an overissuance. This process is automated in Benefit Recovery in Bridges. Administrative Decision Sometimes program policy bulletins require the issuance of supple- ments. These unique situations are directed at specific client groups to avoid underissuance due to policy or procedural changes. Typically, these supplements will be automatically generated by Bridges. You will receive specific information when these situations occur. Children’s Clothing Allowance This is a supplement for FIP groups eligible for the children’s cloth- ing allowance for a given year when funding becomes available. Bridges will automatically issue a supplement for active FIP groups with children. Supplements are viewable the day following the pro- cessing date. When a child is added to an active case, issue a manual supplement. Note: When funding is available, an Interim Policy Bulletin will be issued stating the effective month. Conversion This is a manual issuance supplement you will use when the benefit months that require a supplement are for conversion months and months prior to Bridges conversion. This also includes initial benefits and retroactive payments for pre-Bridges months.
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LOCAL OFFICE APPROVALS Bridges will require a second party/FIM review. This is to ensure compliance with court orders and/or correct application of policy. CLIENT NOTICES Clients must be given adequate notice that a supplement has been authorized or denied. Bridges will generate a notice for authorizations that are automati- cally calculated on the system. If manual issuance is required, Bridges does not automatically gen- erate a notice. For pre-Bridges or conversion months, use the LOA2 generated notice(s.) For all other months, a policy exception is required and central office will complete a manual notice in Bridges, or if the notice template is not available in Bridges, using an MS Word template. RECOUPMENT FROM SUPPLEMENTS
EDBC Determined Supplements Bridges will recoup from an EDBC-determined client supplement when all of the following are true: The program has an active claim. The recoupment rate is a percentage, not a dollar amount. The benefit type is initial or supplemental. Bridges reduces the supplement or initial issuance amount by the recoupment percent. This reduction is applied to the overissuance balance of the active program. Manual Issuance Supplements Recoupment amounts are not automatically calculated or deducted from manual supplements. You are responsible for calculating the recoupment amount when issuing a supplement on a case with an outstanding claim.
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Review the claim in Benefit Recovery to determine the correct recoupment percentage to apply. Enter the amount of the supple- ment less the recoupment into the Benefit Amount field on the Request Cash/FAP/SSP Manual Issuance screen in Bridges. The recoupment amount must then be posted to the outstanding claim in Bridges Benefit Recovery by the appropriate accounting staff. LEGAL BASE FIP R400.3105
SDA R400.3170 RCA 45 CFR 400.49
BAM 406 1 of 5 SUPPLEMENTAL FOOD ASSISTANCE BENEFITS BPB 2022-001 1-1-2022
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DEPARTMENT POLICY Supplemental Food Assistance benefit issuances (supplements) must be issued: • When the regular FAP issuance for the current or prior month(s) is less than the group is eligible for, or • For periods when the group was eligible but received no regular benefits. Issuance Supplements are issued through Bridges. The supplemental benefit amount is deposited into the client’s EBT food benefit account. The benefit is available the next day. Bridges will notify the group that a supplement is authorized. Do NOT issue supplements to correct underissuances caused by the client's failure to report. Offsetting Supplements correcting underissuances in previous months may be “offset” against overissuances. This means that the amount of the overissuance is subtracted from the amount of the supplement. This might result in the whole supplement being credited. Offsetting occurs when: • The benefit recovery system shows an overissuance balance, and • A supplement is authorized to correct a previous month(s) underissuance, and • The supplement was ordered by a court or administrative law judge and the order does not specifically prohibit offsetting. Offsetting is done automatically by Bridges. INITIAL BENEFITS Bridges will automatically prorate initial benefits when prorated ben- efits are required based on the date eligibility begins.
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Exception: Migrant/seasonal farmworker groups that were active in the FAP program the month before the application date are eligible for a full application month's benefit. This is true whether the entire group or any member of the group was active the month before the FAP application date. Bridges will not prorate initial benefits for such groups. RETROACTIVE BENEFITS If the application processing is delayed beyond 60 days from the date of application, Bridges will issue a supplement to correct previ- ous months benefits which may result in offsetting (see the “COR- RECTING PRIOR MONTHS BENEFITS” section in this item). CORRECTING THE CURRENT MONTH BENEFIT Bridges will issue a supplement when the current month benefit is less than the group is eligible for. Such situations include but are not limited to the following: • Due to administrative time frames or agency error, DHS fails to effect any increase of the regular current month benefit as required by policy. Exception: When current month and prior month(s) underissuances are due to the same agency error, court order, etc., Bridges will consolidate them and issue a supplement under prior months. • An eligible group requests a hearing within 11 days of the effective date of an immediate negative action affecting current month benefits. Issue the supplement within five days after receiving the hearing request if the negative action resulted from a voluntary report by the FAP group. If not, issue the supplement within ten days of receiving the hearing request.
See BEM 610 for issuing current month supplements for migrant groups.
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CORRECTING PRIOR MONTHS' BENEFITS These supplements are limited to underissuances in the twelve months before the month in which the earliest of the following occurred: • The local office received a request for lost benefits from the eligible group. • The local office discovered that a loss occurred. • The group requested a hearing to contest a negative action which resulted in a loss. • The group initiated court action to obtain lost benefits. Exception: When a disqualification hearing decision is later reversed by a court, individuals are entitled to lost benefits for all of the months they were disqualified. Supplement the underissued group whether it is currently active or inactive. If the group's membership changes before the supplement is issued, issue it to the group containing the majority of the original group members. If no such group can be located, issue the supple- ment to the current group containing the original grantee. When groups requesting a supplement are denied, inform them via MDHHS-176. Groups eligible for the supplementation may elect installments. All prior month supplements are offset against overissuances except those on suspended collection due to an OIG referral. Offsetting is done automatically by Bridges. Correcting Underissuances Due to Agency Error A prior month supplement is issued when an agency error in a prior month caused an underissuance. Agency error includes loss of an application by a Social Security Office. Issue the supplement within ten days after discovery.
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Corrections Ordered by a Court or ALJ A prior month supplement is issued for prior months as ordered by a court or ALJ unless the order specifically prohibits offsetting against overissuances. Issue the supplement within the time frames established by the court or BAM 600. WITHOUT OFFSET Some supplements for prior month underissuances are not appro- priate to offset the supplement against overissuances. Such situa- tions include but are not necessarily limited to the following: • A supplement to correct current month's benefits cannot be processed until the following month due to administrative time frames or agency error. • An ALJ or court orders a supplement to correct an underissuance with no overissuance offset. Correcting Excess Recoupment Bridges will identify and issue a supplement for excess recoupment that has been paid by the client. Replacement Of Benefits Destroyed Issue a supplement to replace food that was destroyed through a verified domestic misfortune or disaster through no fault of the client. Example: Domestic misfortunes or disasters include events which occur such as: • Fires. • Floods. • Electrical outages. The supplement for the current month cannot exceed the eligible group’s monthly allotment. (see BAM 502). LEGAL BASE 7 CFR 273.12(C)(1),.17
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7 CFR 274.12 7 CFR 274.6(a)(1)(iii)
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DEPARTMENT POLICY FIP and SDA In some circumstances benefit payments can, or must, be restricted to someone other than the program group. This involves a protective payee or mandatory vendor payments. A protective payee is a person/agency selected to be responsible for receiving and managing the cash assistance on behalf of the group as a third party. Mandatory vendor payments are shelter payments made by Michigan Department of Health and Human Services (MDHHS), without the client's request, directly to the group's landlord, mortgage or land contract holder. Mandatory vendoring can also include heat and electric payments to a utility company. Restricted payments are required in any of the following circum- stances: • Court-ordered shelter arrearage collection. • Third-party resource disqualification. • Minor parent. • Substance abuse. • Money mismanagement. • A child(ren) receiving FIP has a legal guardian. • Eviction or threatened eviction. Note: Restricted payments apply to only a current eviction or threatened eviction. Third-party payments, not mandatory vendoring, are required if the local office has been informed that the housing unit fails to meet local housing codes. The protective payee should assist the family to locate housing which meets the codes. Restricted payments are a local office option when the grantee has demonstrated a need for assistance in handling benefit payments but does not meet any of the circumstances above; see “Demon- strated Need For Money Management Assistance” in this item. Electronic Benefit Transfer (EBT) EBT allows clients to receive cash benefits (FIP & SDA) electroni- cally. Protective payees are issued a Bridge Card for the client’s
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cash benefits. When there is a protective payee, the client cannot access his/her cash account. Clients still have access to their food assistance benefit account. Shelter Arrearage FIP and SDA Initiate mandatory vendoring when a shelter provider presents a certified copy of a court judgment to collect unpaid rent or the cost of damages to rental property from a member of the eligible group. This applies even if the group was not active when the debt was incurred or the person(s) named in the order was not in the group at that time. Exception: Do not initiate or continue mandatory shelter arrearage vendoring when made aware that the rental property has been found to be in violation of local housing codes by the local housing authority. Assume the court document is valid unless it appears questionable. Send a questionable document to the Office of Legal Services in central office for review. File clear on the person(s) named in the order and do one of the following: • If the person is a FIP/SDA applicant or recipient in your county/district, vendor the arrearage. • If the person has a recipient ID number but is not a current FIP/SDA applicant or recipient, file the order in the case record for possible future action. • If the person was never issued a recipient ID number, return the order to the provider with that explanation. Multiple Court Orders If a second court order affects the same eligible group, pend it until the first order is paid in full. Do not attempt to implement two court orders at once.
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THIRD-PARTY RESOURCE DISQUALIFICATION FIP Restrict payments when the grantee is disqualified for failing to identify a third-party resource; see BEM 257. Use a protective payee, if possible. Exception: The disqualified grantee may continue to receive warrants for the child(ren) as an ineligible grantee if: • No suitable protective payee is found, despite all reasonable efforts; and • Prolonging the search might be detrimental to the child(ren). Note such a circumstance on the DHS-1171; the DHS-223, Docu- mentation Record; or other appropriate document for placement in the Eligibility Packet of the case record. Minor Parent Grantee FIP Restrict payments (via protective payee, if possible) when the eligi- ble group consists of a minor parent grantee and his/her depen- dent child who live: • With the minor parent's legal guardian or other adult relative, or • In an adult-supervised living arrangement (for example, foster care). If possible, the payee should be the responsible adult in the home (such as, relative, legal guardian, or designated staff of the adult- supervised living arrangement). BEM 201 defines and explains these circumstances.
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Money Mismanagement FIP and SDA Restrict payments when the grantee endangers his/her own or an eligible child's health or safety by mismanaging benefits. When money mismanagement might exist (for example, contact from a provider or services specialist), evaluate whether restricted payments are necessary. Complete a DHS-838, Documentation of Money Mismanagement, and file it in the case record. Evaluate possible money mismanagement when the client: • Requests SER benefits, and required payments have not been made. • Fails to meet basic obligations (for example, shelter, heat, utilities or health care). • In FIP only, fails to properly feed and clothe a child. • Incurs debts for nonessential items, limiting the ability to pay essential bills. Restricted payments are appropriate only if money mismanage- ment resulted from the grantee's negligence. This does not include the following situations: • Someone in the group had an emergency which required spending available money. • Bills for essential items exceeded the grant and other income. • A payment was withheld over a legitimate dispute with the provider (for example, landlord) as to whether the terms of an agreement were met. Determining the Restricted Payment Type A decision to use mandatory vendoring or send the entire grant to a third party should reflect the seriousness of the money mismanage- ment. However, use mandatory vendoring if undue time is required to find a payee.
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Substance Abuse SDA Restrict payments when substance abuse is a contributing factor to the disability; see BEM 261. Use a protective payee, if possible. If a protective payee cannot be obtained, use vendor payments for shelter, heat, and electric to the extent possible. Eviction or Threatened Eviction FIP and SDA Restrict payments when verification indicates the eligible group is being evicted, or threatened with eviction, from its current rental unit for nonpayment of rent. This applies even if the case was not active when the debt was incurred or the person(s) named was not in the eligible group at that time. The verification must clearly identify the client. It includes but is not limited to: • A court order, other court judgment, or court filing document clearly stating that rent is in arrears. • A notice of intended eviction that cites nonpayment of rent as the reason. • An application for SER (or in Wayne County, Emergency Services) for a shelter deposit and/or first month's rent by a homeless shelter resident whose homelessness was caused by nonpayment of rent. Note: Local offices may grant exceptions to mandatory vendoring in order to address extenuating circumstances (for example, illegal eviction document or unresolved landlord-tenant dispute). Legal Guardian FIP When there is a legal guardian of a child(ren) receiving FIP, the legal guardian must be a protective payee for the FIP.
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Demonstrated Need for Money Management Assistance FIP and SDA In very limited and compelling circumstances, the local office may assist a grantee in managing money through restricted payments, even though there is no current money mismanagement. Demon- strated reasons may include: • Developmental disability. • History of mental disorders. • Chronic money mismanagement during past periods of assistance. See Determining the Restricted Payment Type above. Protective Payee FIP and SDA Either a specialist or the client may suggest a third-party manage the group's cash benefits. It may be a relative or friend of the group, a volunteer worker, a member of a private agency that provides protective service or money management counseling or, at the local office director's option, a services worker. The protective payee was formerly referred to as the third-party payee. Exception: In a minor parent case, the grantee's legal guardian or other supervising adult must be appointed protective payee unless that person is unable to manage the benefit payments; see BEM 201. Determine whether the suggested payee is suitable. Ensure that the person is all of the following: • Concerned with the group's welfare. • Willing to receive and manage the grant. • Willing to help the group learn to manage money. • Able to keep adequate records and receipts of how the grant is spent. The following cannot be a protective payee: • Members of the eligible group.
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• Local office director or management staff. • FIS/ES determining the group's financial eligibility. • Anyone handling financial matters of the group. • Special investigative or resource staff. • Provider of goods or services to the group (for example, landlord, grocer). Vendoring in Restricted Cases FIP and SDA Mandatory vendor payments are usually authorized when only the shelter, heat or utility obligation is mismanaged or when a protective payee cannot be found. Mandatory vendoring is limited to the monthly combined shelter, heat and utility expenses and must leave a minimum $2.00 cash grant (such as, grant amount after deducting income, vendor pay- ments and any recoupment amounts). To receive vendored payments, providers must furnish their federal employer ID number, Michigan temporary ID number or social security number, and enroll as a provider. In money mismanagement cases, initiate third-party payments to a protective payee (not vendoring) in the following situations: • The provider refuses to furnish his tax ID number (see above) or enroll as a provider. • MDHHS is notified by the government agency/unit which enforces the local housing code that: The rental unit does not meet standards for such housing, and/or The landlord has not followed the community's housing code policies and procedures. • The landlord, without good cause, refuses to cooperate in available weatherization or conservation programs determined necessary to reduce energy consumption to an acceptable level. Stop mandatory vendoring when MDHHS learns and verifies that the property reverted to the State of Michigan due to unpaid taxes; see “Reviews” in this item.
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Heat and Electric Vendoring For FIP, heat/electric vendoring cannot be mandatory. However, urge the client to enroll in voluntary vendoring to help correct money mismanagement; see BAM 425. For SDA, mandatory heat/electric vendoring is a local office option. Setting Vendor Priorities FIP and SDA If the total does not allow the minimum $2.00 cash benefit, decide what to vendor to best meet the group's needs. In money misman- agement cases, the following order of priority is suggested: 1. Shelter arrearage. 2. Shelter. 3. 2nd shelter (for example, mobile home lot rental). 4. Heat (or combined heat and electric). 5. Electric. 6. Heat arrearage. 7. Electric arrearage. Note: Priority vendoring negates certain voluntary vendoring requirements. See the “VENDOR PAYMENTS” section in BAM 425. Notices of Restricted Payments FIP and SDA Send the group a DHS-898, Money Management Evaluation Notice, when evaluating the need for restricted payments. After the evaluation, send another DHS-898 if you determine that restricted payments are not necessary. When starting or stopping third-party payments, send: • A DHS-3797, Protective Payee Appointment Notice, to the payee, and • A DHS-3869, Protective Payee Assignment, to the client.
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FIP Give the group timely notice before starting restricted payments. Calculate the pended begin date for third-party payments. SDA In SDA, restricted payments are not negative actions. Therefore, give the group adequate notice. Reviews FIP and SDA Review restricted payment status when appropriate but at least at every determination. Schedule the review with other case reviews when possible. The client, however, has the right to request and be granted a review of the restricted payment status every six months. Review the status immediately if vendoring must stop because the property reverted to the State of Michigan; see Vendoring in Restricted Cases in this item. For money mismanagement cases, examine the progress of the protective payee and/or client in managing the group's money. For third-party resource disqualifications, examine the payee's money management ability and the client's willingness to cooperate in identifying a third-party resource. See the DISQUALIFICATION section in BEM 257. In minor parent cases, examine how the supervising adult has man- aged the benefit payments. Resuming Restricted Payments FIP and SDA Restricted payments stop automatically at closure and due to certain coding changes. When reinstating a case or processing such a coding change, resume restricted payments. The following factors apply: • A new money mismanagement evaluation is not required. • Reflect the current living situation in the budget.
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• Mandatory vendoring documentation in effect at the closure or coding change is sufficient. Interoffice Transfers FIP and SDA Transfer of a case to another local office might result in a new pro- tective payee or provider(s), but it does not affect the requirement for restricted payments. Continuity of the restricted payments must be ensured. Time Limits FIP and SDA In third-party resource disqualifications, continue restricted pay- ments until the person's cooperation is verified. See Removing a Third-Party Resource Disqualification in BEM 257. In minor parent cases, continue restricted payments until the client no longer meets the minor parent definition in BEM 201. In money mismanagement cases, restrict payments for 24 months (consecutive or otherwise) or until the problem is resolved, which- ever occurs first. If it appears the problem will last beyond 24 months, notify Services staff to arrange for protection of the children and/or a guardian. Note: Restricted payments may continue beyond 24 months if the court denies or refuses to accept a guardianship petition. Hearings FIP and SDA The group may request a hearing to dispute a decision to begin or continue restricted payments or to dispute the selection of a protec- tive payee. Continue restricted payments until the hearing matter is resolved. LEGAL BASE FIP P.A. 280 of 1939, as amended P.A. 235 of 1995
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P.A. 109 of 1997 R 400.3106 SDA Annual Appropriations Act Michigan Administrative Code; R 400.3151-400.3180
R300.4151 - 400.3180MAC
BAM 425 1 of 8 VOLUNTARY VENDOR PAYMENTS BPB 2014-015 7-1-2014
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DEPARTMENT POLICY FIP and SDA Only Voluntary vendoring is a voluntary payment system whereby DHS sends part of the client's FIP/SDA grant directly to the provider(s) of shelter, heat and/or electricity. One-half of the vendored amount(s) is withheld from each semi-monthly warrant. Cases with ineligible grantees other than SSI recipients, are not eli- gible for voluntary vendoring. Clients may request vendoring at any time via the DHS-560, Vendor Payment Request, which must be completed before vendoring begins. Vendor payments must be at least $2.00. All clients with an expense for shelter (rent, mortgage, land contract or other), heat or electricity are expected to complete and sign the DHS-560 to show whether they want vendoring. This applies even if the only obligation is a previous unpaid bill. Reminder: Signing the DHS-560 is not a condition of eligibility. Make a note of refusal on the DHS-560 or DHS-1171, Assistance Application. Have a DHS-560 completed: At application, and When a client wishes to start or stop vendoring, and When the client moves. The existing DHS-560 remains in effect until a new one is completed and signed, even if the information is changed in Bridges. Note: Unless a new DHS-560 is obtained after interoffice case transfer, incorrect provider information will remain in the case record. A new DHS-560 is not needed to reinstate a case. Encourage clients to continue their enrollment in voluntary vendor- ing. However, stop voluntary vendoring promptly when a client makes a written request (via DHS-560 or otherwise).
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The total vendored amount must leave at least a $2.00 grant. If less than $2.00 remains, see Setting Vendor Priorities in the VENDOR PAYMENTS section in this item. VENDOR PAYMENTS
Providers Shelter providers seeking vendored payments must first: Furnish their federal employer ID number, Michigan temporary ID number, or social security number; and Enroll in the Model Payments System (MPS); see BAM 435. Shelter The client may specify any monthly amount to be vendored. Clients in manufactured (mobile or modular) homes may choose to have home purchase and lot rental payments vendored separately. Rent To have rent vendored, the client must first complete the DHS-560 section indicating he agrees/objects to release of his name and address to the local housing code enforcement authority. Note: Enforcement authorities include the Michigan Department of Community Health. Vendor payments are not affected if the client objects to the information release. In Bridges under Wrap Up, Issuances-Details and answer Yes to vendor assignment. On the Cash Vendor Assignment Details page, select the Vendor Type Shelter and enter the Vendor Amount. The local office is to complete a DHS-4493, Local Agency Code Compli- ance Referral, attach the CF-090 and forward them to the housing authority. Vendored Rent NOT Authorized in Certain Situations Do not authorize vendored rent in the following situations: The local housing authority notifies DHS that
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The dwelling fails to meet the housing code, or The landlord has failed to cooperate with housing code policies and procedures. The landlord rejects energy conservation measures offered by DHS or a positive billing company that were determined necessary to reduce consumption to an acceptable level. The landlord is delinquent on payment of property taxes. Title to the rental property reverts to the State for nonpayment of property taxes. The housing authority uses an DHS-4494, Housing Code Compli- ance Notice, to notify DHS that: A rental unit does not meet the housing code. A rental unit previously out of compliance now meets the housing code. Stop vendoring within five workdays if notified of noncompliance with a housing code or an energy conservation program offered by DHS. Do not reauthorize vendoring to that rental unit (even when another client occupies it) until notified by the housing authority or energy provider that compliance has been established. Note: The local office is responsible for maintaining a list of rental units out of compliance. Heat and Electric The minimum amount vendored is determined by the number of recipients receiving cash benefits; see the Table of Monthly Energy Required Payments in ERM 301. Clients may choose to vendor more than the required amount for their eligible group size to ensure the minimum required payments are being made based on the household size. Only one heat provider and one electric provider may be vendored for the case at any one time, except for arrearage vendoring. The amount(s) withheld are sent directly to the provider twice a month. (Refer to Wizards in Bridges for an explanation of entries for vendoring.)
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Setting Vendor Priorities Bridges allows up to six vendor situations. However, if the total would leave a grant of under $2.00, assist the client to choose the most important. The following is a suggested order of vendoring pri- orities: Note: A shelter judgment arrearage vendor takes priority over all other vendors. 1. Shelter arrearage. 2. Shelter. 3. 2nd shelter (such as mobile home lot rental). 4. Heat. 5. Electric. Supplements and Lost, Stolen, Returned or Replaced Warrants Vendor supplements are processed by Central Office accounting. To replace a lost or stolen single-client vendor warrant (not a con- solidated vendor warrant) see BAM 500. To rewrite a returned single-client vendor warrant see BAM 505. Treasury Offsets The Department of Treasury may withhold, or offset, money from a vendor warrant when the provider has an outstanding debt to the State. A vendor payment which is offset by Treasury against a debt owed by the provider to the State is legally considered to have been paid to the provider. Refer providers with questions regarding the offsets to the MI Trea- sury Vendor Offset Program at (517) 636-5270. Tax ID Number Pended Payments The Department of Treasury identifies MPS enrolled providers whose tax ID numbers (federal employer or Michigan temporary ID) are incorrect on MPS or not registered with Treasury. DHS holds the vendor payments for 30 days or until the problem is resolved, whichever is earlier.
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Note: The provider and client are also notified; see Provider/Client Notices in this item. The Payment Information Unit (PIU) in central office processes incorrect and unregistered tax ID numbers. The provider is requested to furnish the correct number or confirm the information on file within 14 days of the pended payment. If the problem is not resolved timely, a supplement is issued to the client to replace each pended vendor warrant. Money held by DHS beyond the negative action date is issued to the provider, regardless of the reason vendoring stops. When payment is made, the warrant number and amount, warrant date and payee are also posted. Providers who contact the local office with a tax ID number problem should be referred to the PIU:
Department of Human Services Payment Information Unit P.O. Box 30037 Lansing, MI 48909 (800) 444-5364 PROVIDER/ CLIENT NOTICES Bridges generates an DHS-4327-M, Vendor Payment Notice, to the provider and/or client for vendoring actions. Both providers and clients are notified of the following: Vendoring begins. The Vendor Action (client request, money mismanagement) determines the DHS-4327-M content. The vendored shelter amount changes. Vendoring stops and is not started again to the same provider the same day. Vendor payments are held due to a tax ID problem. Only clients are notified of the following: A change in the eligible group affects the heat/utility allowance. Vendoring to a particular provider starts, then stops (or stops, then starts) the same day.
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No notice is sent for other corrections in vendor data. VENDOR WARRANTS
Individual Vendor Warrants The Department of Treasury issues individual vendor warrants for each client with vendoring. The vendored amount is withheld from the client's regular semimonthly warrant and usually sent to the pro- vider within four days after the regular warrant. Each vendor warrant includes half of the client's monthly vendor payment. A stub attached to the vendor warrant states: Case name. Case number. FIS/ES workload number. Client's address. Client's billing account number Pay period (for example, Jan. 1st half) the warrant is issued for. Message identifying the warrant as a vendor payment. $1.00 processing fee deducted (shelter judgments only). Consolidated Vendor Warrants Shelter, heat and electric providers with a signed agreement with DHS receive consolidated vendor warrants for multiple clients. The vendored amounts are withheld from the clients' regular semi- monthly warrants. The total heat and electric deductions or shelter payments of all cli- ents with vendoring to the provider are combined into weekly war- rants as follows: 1st week - First semimonthly payments for clients with case numbers ending in 0-4. 2nd week - First semimonthly payments for clients with case numbers ending in 5-9. 3rd week - Second semimonthly payments for clients with case numbers ending in 0-4.
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4th week - Second semimonthly payments for clients with case numbers ending in 5-9. CAP NOTICE
Client Cap Notice DHS-4327-Y Clients whose allowances are vendored to the provider will continue to have their allowances vendored to their provider after reaching the fiscal year cap. DHS-849 payments for usage over the cap can only be authorized by exception. EXHIBIT - SAMPLE LETTER TO SHELTER PROVIDER WHEN A VENDOR WARRANT IS CREDITED
PROVIDER DATE Client
Vendor payments which you have been receiving for shelter on behalf of the above named cli- ent will stop for a one month period effective (date) . Payments for this period are the responsibility of the client.
If you have any questions about this letter, contact the specialist whose workload number appears below.
LOCAL OFFICE
LEGAL BASE FIP P.A. 280 of 1939, as amended P.A. 368 of 1996 SDA Annual Appropriations Act
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Michigan Administrative Code; R 400.3151-400.3180
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DEPARTMENTAL POLICY State Disability Assistance (SDA) Only Special living arrangement (SLA) provider payments for SDA recipi- ents are made in Bridges. The following SLAs are eligible for pro- vider payments: • Homes for the Aged (HFA). • Adult Foster Care (AFC) (only if receiving domiciliary or personal care). • County Infirmaries (CTI) (only if receiving domiciliary or personal care). Note: AFC and CTI residents not certified for domiciliary or personal care are considered in independent living; see BEM 515. A type of care determination, which affects the payment rate, must be made before the provider can be paid; see BEM 615. Refer to BEM 616 for client eligibility information. Liaison With Facility SLA facilities send notices of admission, extended stay and dis- charge to the local office where the facility is located. If the client's residence county continues to handle the SDA case, the local office where the facility is located forwards all eligibility and payment information to the residence county. Payment for SLA Facilities Bridges requires that: • The facility is enrolled as a provider. • There is an active SDA case or SDA was active for the period being authorized. • The SDA/SLA provider has an active assignment on the eligible SDA case. The provider must submit a DHS-768, Invoice/Adjustment Request.
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Provider enrollment and payment authorization information are entered in Bridges. Payment is then made to the provider based on the number of days billed by the provider compared to authorization information; see Authorizing SDA/SLA Provider Payment in this item. The provider payment does not include the client incidentals allow- ance. Incidentals are placed on the client’s Bridge Card by elec- tronic benefits transfer (EBT). Provider payments go directly to the provider. Authorizing SDA/SLA Provider Payments After the case has been opened in Bridges, authorize the provider payment. The authorization timeframe is only for the time period the client was in that provider's facility. An invoice (DHS-768) must be sent to the provider for each month in the authorization. The invoice allows the provider to bill for services provided. Note: It is recommended you send enough invoices (DHS-768) to the provider to cover the authorization period for a year (at least 12) at opening. Authorizations are entered in Bridges, located in data collection, wrap up, SDA provider assignment. Authorizations are for whole months or portions of months. The authorization must reflect: • The assigned provider. • Dates the client resided in the facility. If the end date is unknown it is appropriate to align the authorization date with the redetermination date. • Service Code based on type of care and provider type. An authorization can be entered only if: • Bridges shows either that SDA is currently active or that it was active for the period being authorized. • The authorization begin date is no more than 10 days prior to the date of application (registration).
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• The authorization end date is within the previous or next 12 months. If appropriate it should coincide with the redetermination date. AUTHORIZATION CHANGES
Incorrect Services Codes In Bridges, if an incorrect service code has been entered or if pay- ment has been made for any portion of the authorization period, enter the correct information and rerun Eligibility. See Underpay- ments to Providers and Overpayments to Providers in this item for correction procedures. Change Client Pay Bridges will determine the client pay amount when the clients income information is entered or changed. The CSCD entered will determine the effective date of the change. A client pay amount can be changed monthly but is always effective for a calendar month. Increases in client pay amount require timely notice and decreases require adequate notice. Authorizations may never be changed ret- roactively to increase a client pay amount. Retroactive Adjustments Authorizations can be changed retroactively if incorrect and the change is for a period within the past 12 months. Submit requests for changes older than 12 months through the exception process. Unpaid Portions Unpaid portions of authorizations can be changed for any of the following reasons: • To enter an earlier end date because the client died or moved from the facility. • Change in the client pay amount. • Incorrect type of care. • Incorrect authorization dates.
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• Wrong provider authorized. Paid The only change that can be made to a paid authorization is to decrease the client pay amount or increase the type of care. DHS-768 Invoice/ Adjustment Request) To receive payment a provider must complete and submit a DHS- 768. Each DHS-768 covers a calendar month, a new DHS-768 must be submitted for each additional month or portion of a month. Example: If the client is in care from 6/24-7/29 they must provide 2 separate invoices, one for 6/24 to 6/30 and a separate one for 7/1 to 7/29, as care was provided in 2 different calendar months. The completed DHS-768 should be mailed to: Michigan Department of Human Services Economic Stability Administration, Suite 1402 P.O. Box 30037 Lansing, MI 48909 Authorization Terminations End an authorization when the client: • Is no longer eligible for SDA. • Is no longer eligible for provider payment due to income (also see Repayment Agreements in this item). • Leaves the facility. End the authorization by entering an end date The end date is: • The date the client is no longer eligible for SDA. • The date the client is no longer eligible for facility payment. • The day before the client leaves the facility. If the client enters another facility, complete another authoriza- tion. If the client dies, the end date is the date of death.
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Bridges will automatically end an authorization when the: • Address is changed. • Case is closed. • End date is reached. End an authorization when a client remains eligible for SDA, but is no longer eligible for the provider payment paid by the department. Clients with Budgeable Income Enter the client income in Bridges and Bridges will deduct the cli- ent's net countable income from the provider payment. Bridges determines if the per diem provider payment exceeds the client pay for that period before authorizing payment. Bridges will not authorize provider payment if it is less than the client pay. Repayment Agreements Clients who have signed a repayment agreement must repay the department for SDA benefits, including provider payments, when the potential benefit is received ; see BEM 272, SDA Repay Agree- ments. Bridges determines if continuing eligibility exists and if not will close the case. Central office or the fiscal unit determines the amount to be recovered based on the monthly provider and incidentals payments. They will check Bridges for provider payments actually made during the repay agreement period and for pending payments which cannot be stopped. These payments will be included in the recovery calculations. PROVIDER INFORMATION
Bridges Provider Enrollment Provider Management Unit enrolls providers in Bridges using Form DHS-2351-X,Bridges Provider Enrollment/Change Request.. Providers must be enrolled before an authorization for provider payment can be entered in Bridges. Each facility must be enrolled.
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After enrollment, Bridges will assign a provider ID number and send out notice Each time a provider payment authorization is started, stopped or changed in Bridges, the affected provider will be notified. Use SDA Provider Assignment inquiry to resolve any questions about current authorizations or authorization history. DHS-769, Invoice Error Notice When the DHS-768 does not contain all required information, payment will not be approved. A DHS-769, Invoice Error Report will be sent to the provider to notify them the reason the payment can not be made. The provider can choose to correct the returned invoice or submit a new one. SDA/SLA PAYMENT INFORMATION
SDA/SLA Warrants Provider payments are made through Bridges based on invoices submitted by providers. Payrolls are run weekly. A consolidated warrant is issued for each facility and includes payments for all invoices processed that week. Invoices may be submitted any time after the pay end date. Each weekend a payroll tape is processed and forwarded to the Depart- ment of Treasury for warrant issuance. Mailing is scheduled for the following Thursday. Warrants are usually delayed when a holiday occurs. SDA/SLA Provider Warrant Rewrite BAM 500 and BAM 505 include information on requesting a warrant rewrite. Warrant rewrites are included in the weekly payroll. The disposition code is posted the day the rewrite is entered, but the voucher number and location are not assigned until the payroll is run and are therefore not posted until the rewritten warrant is issued.
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WARRANT CREDITING AND REDIRECTING The Reconciliation and Recoupment Section (RRS) in the Bureau of Accounting will request provider warrant intercept and crediting to recover any overpayment. This occurs whenever a provider over- payment remains unresolved after RRS issues a final overpayment notice to the provider. OVERPAYMENTS/ RECOUPMENT
Overpayments to Clients Client overpayment, including provider payment, which is not a result of incorrect facility billing or an error in the type of care autho- rized, is recouped from the client; see BAM 705. This includes FIP or SDA overpayments resulting from failure to notify the department of changes in living arrangements. Overpayments to Providers Overpayments to providers which are a result of incorrect billing for periods for which services were not provided or for incorrect type of care authorizations, are recouped from the provider by the Bureau of Accounting. Contact the facility, inform them of the overpayment and request repayment. If the facility does not cooperate or refuses, submit a memo to the Reconciliation and Recoupment Section. Include a brief explanation of the overpayment circumstances and all of the following informa- tion: • Provider name and ID number. • Case name(s) and number(s). • Overpayment amount(s). • Overpayment period(s). • Appropriate documentation. • Account number and cost center. Refer to the Warrant Crediting and Redirecting section in this item for warrant intercepts resulting from recoupment efforts.
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UNDERPAYMENTS/ ADJUSTMENTS
Underpayments to Clients BAM 405 contains information on authorizing supplements to SDA clients for underpayment of incidentals and special needs. Underpayments to Providers If a provider is underpaid for care provided, such as, client pay decreases, or type of care increases, issue a DHS-768 to the pro- vider to rebill for that month. The provider completes the form using the correct information for the entire month. Inform the provider to identify a changed invoice by placing CORRECTION at the top of the form. SLA POLICY EXCEPTION PROCESS
Local Office Local office directors or district managers may authorize exception requests due to administrative error in the following situation: The client: • Made timely application for assistance. • Cooperated in the interview and verification processes. • Left the facility before the application could be approved. A cover memo explaining the situation and requesting exception unit authorization input, may be sent directly to: Economic Stability Administration Grand Tower Building-Suite 1402 P.O. Box 30037 Lansing, MI 48909 Central Office A policy exception and authorization exception input request are required for:
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• An authorization for provider payment for a period more than ten days prior to the SDA application (registration) date. Central office will provide notification of decisions made on exception requests. Notify the client of the exception decision. Problem Resolution Contact FIP-SDA-RAP@michigan.gov or the local office Economic Stability Specialist to resolve SDA/SLA related difficulties. LEGAL BASE SDA Annual Appropriations Act Michigan Administrative Code; R 400.3151-400.3180
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DEPARTMENT POLICY The policy and procedures in this item apply to Family Independence Program (FIP), State Disability Assistance (SDA), Medicaid (MA), and State Emergency Needs (SER) only; see BEM 704 and 706 for CDC, ASM 065 for Adult Community Placement (ACP), and ASM 221 for Adult Protective Services (APS). Providers must be enrolled in Bridges and SIGMA Vendor Self Services (VSS) to be paid for services rendered. Exception: Child Development and Care (CDC) licensed exempt- related and unrelated providers do not have this requirement; see CDC providers in this item. Prior to Bridges enrollment, refer providers to the VSS website, http://www.michigan.gov/SIGMAVSS or 888-734-9749. A SIGMA Vendor Code (SVC) will be required to complete the DHS-2351-X, Provider Enrollment/Change Request. Bridges will assign a provider ID number when enrolled. The ID number is used when authorizing a payment to the provider. The provider's name, Tax ID Number (TIN), address, SVC, and Address ID assigned to their payments address in VSS must correspond with their Bridges enrollment information to avoid a payroll error and to prevent a payment from being issued to an incorrect provider or mailed to an incorrect address. CENTRAL OFFICE PROVIDER ENROLLMENT The Provider Management Unit (PMU) is responsible for completing enrollments and making revisions or corrections to all provider service types. Energy-Related Service Providers Suppliers of non-heat electricity, natural gas, deliverable fuel and other household fuel types, along with energy-related home repair providers are enrolled as a Low-Income Home Energy Assistance Program (LIHEAP) provider. The provider must complete and submit a DHS-355, Participation Agreement for Michigan's Low-Income Home Energy Assistance
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Program, form to the PMU for a provider to be enrolled as a LIHEAP provider and to receive payment on behalf of a client. Revisions or corrections to a provider's enrollment must be submitted in writing, by the provider, on a DHS-355 or their business letterhead and sent directly to the PMU. Non-Energy Service Providers To enroll or make changes to the enrollment of non-energy utility providers of water, sewer, burial, home repair, and shelter, (includes home ownership), submit a completed DHS-2351-X, Provider Enrollment/Change Request, to PMU. Medical Service and Medical Photocopying Service To enroll or make changes to the enrollment of a Medical Service or Medical Photocopying Service provider, submit a completed DHS-2351-X, Provider Enrollment/Change Request, to PMU. Adult Foster Care, Homes for the Aged, and County Infirmaries Adult Foster Care (AFC), Homes for the Aged (HFA), and County Infirmaries (CI) receiving payment for care must be enrolled by PMU; see BAM 430. Submit a completed DHS-2351-X, Provider Enrollment/Change Request to PMU. Special Living Arrangement (SLA) provider payment cannot be authorized unless the provider is enrolled with the appropriate eligibility type. SLA provider payment authorizations cannot be authorized beyond the eligibility type end date if an end date has been entered. After all enrollments, PMU will respond to the emailed request with the provider ID and service begin date. Child Development and Care (CDC) Providers See BEM 704 and BEM 706 for further enrollment and payment information. Licensed CDC providers are maintained by PMU and must registered in SIGMA VSS to receive payment. License exempt CDC providers are enrolled and maintained by Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP). License exempt related and unrelated providers do not require an SVC due to payment issuing to the parent. When assigning this provider type, disregard the Bridges pop up requiring an SVC by clicking OK.
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Provider Management Unit Use the Search Enrolled Provider inquiry to determine if the provider has already been assigned a provider ID number in Bridges. If an ID number has previously been assigned, reference that number on the DHS-2351-X. For all state employees, use the Jira Portal to send all requests to PMU. For all non-state employees, email all requests to the PMU. Jira Portal URL: https://brg-jira- prd.state.mi.us/servicedesk/customer/portal/141 PMU E-mail: MDHHS-Provider-Management@michigan.gov Mailing Address: Provider Management Unit Economic Stability Administration 235 S. Grand Avenue, Suite 1402 Lansing, MI 48933-1805 Phone: 517-284-2953 SERVICE PROVIDERS Multiple Provider ID Numbers Some providers may be assigned to more than one provider ID number. This occurs when the company wants to differentiate between several business locations. Multiple provider ID numbers may be assigned to the same business or individual when the provider chooses to be enrolled and paid under a Federal Employer Identification Number (FEIN). Multiple provider ID numbers cannot be assigned when the provider chooses to be enrolled and paid under a Social Security Number (SSN). An individual who would like to obtain a FEIN should contact the Internal Revenue Service or the U.S. Post Office to obtain a Form SS-4, Application for Employer Identification Number. It may take several weeks to obtain a FEIN. When a provider has been assigned multiple provider ID numbers, local office staff must review the enrolled name, address and tax identification number carefully before authorizing payment, to ensure that the correct provider ID number is used.
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Multiple Names and Addresses A situation may occur where the owner of the business or property requests that the payment be issued to and/or mailed to another individual or business. For energy and non-energy service providers, payments are issued to the individual or business enrolled in Bridges and mailed to the physical address, or the address entered in the mailing address section. The provider's SVC and Address ID in Bridges must match the SVC and Address ID in VSS to ensure the payment is sent to the correct address. Adding Eligibility Type(s) to Enrolled Providers A provider may offer more than one service type using the same provider ID number. Additional service types may be added at any time to a provider ID number. The Search Enrolled Provider inquiry is used to determine the current service types. CHANGES TO PROVIDER ENROLLMENT Updating Enrollment Information The provider must request changes to the provider file (for example, name or address) in writing. The request should include the new information, the provider's tax identification number and the provider ID number. Submit a completed DHS-2351-X, with the written request from the provider to PMU. All changes are completed by PMU. PROVIDER ENROLLMENT TERMINATION Provider Enrollment Terminations - Central Office All terminations are completed by PMU. When provider enrollment termination is needed, submit the DHS- 2351-X to PMU. Energy-related providers must submit their termination request on company letterhead or by completing the DHS-355.
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When it is necessary to end date a provider ID number due to multiple provider ID numbers, PMU will enter the correct provider ID number in the comment section of the Provider Service Details screen of the end-dated provider ID number. Send a DHS-2351-X to PMU to reactivate any end-dated provider ID number. Note: Energy-related service providers must complete and submit a DHS-355 to have their enrollment re-established. All Other Providers Home for the Aged provider enrollments must be terminated by PMU. When notification is received from public health that the license/certification is terminated, forward notification to PMU. Computer updates from Adult Foster Care licensing will automati- cally enter an end date for license closures for SLA, AFC and CI facilities. PROVIDER ENROLLMENT FILE Maintain forms used to enroll or change provider information on the provider enrollment file in a secure location. Also include any docu- ments with information upon which a provider enrollment or change is based.
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DEPARTMENT POLICY FIP, RCA, SDA, SSP, CDC, SER, and Medical Services warrants. Michigan Department of Health and Human Services (MDHHS) replaces warrants reported lost, stolen, not received, or destroyed. 1778 PROCESS A payee on the warrant claiming it was lost or stolen must complete and sign a 1778, Affidavit Claiming Lost, Destroyed, Not Received or Stolen State Treasurer's Warrant. Use the MDHHS Forms Library to access a link to the Michigan Department of Treasury (Treasury) form 1778: 1. From Inside MDHHS select Work then Forms and Policy and then Forms & Templates/Learn More. 2. Click DHS: Forms 1500 - 1999. 3. Select the 1778, Affidavit Claiming Lost, Destroyed, Not Received or Stolen State Treasurer’s Warrant Process and then click OK. 4. Click the hyperlink to treasury form and complete. Lost or Stolen Warrant For stolen warrants, clients must also be encouraged to file a police report. Replacement is made only after recovery of the warrant amount; see Stop Payment and Replacement in this item. Note: Do not complete a 1778 for client or vendor warrants lost or stolen after endorsement. These warrants can only be replaced if they are returned to Treasury, or they are cancelled by Treasury after 6 months. Warrant Not Received Clients and providers sometimes request replacement of warrants never received which they do not believe were lost or stolen. Deter- mine in Bridges, Benefit Issuance, whether the warrant was issued.
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If the warrant was issued, obtain the warrant number, warrant date, amount, and Warrant Status. • If Bridges indicates it was returned/cancelled to Treasury; see BAM 505, Returned Benefits. If the warrant was issued and not returned/cancelled it might be late in mail delivery. Instruct the payee to contact the post office to verify delivery. • If delivery is verified but the payee claims nonreceipt, consider the warrant lost; see Lost or Stolen Warrant in this item. • If delivery cannot be verified, consider the warrant not received. The payee can complete a 1778 on the day after the fourth mail delivery day following the warrant date; see Stop Payment and Replacement in this item. Note: For CDC only, the payee can complete a 1778 on the day after the 10th mail delivery day following the warrant date. If the warrant was not issued, ask a local office designated staff to contact the Bridges Resource Center (BRC). Destroyed Warrant When the local office receives a destroyed or mutilated warrant, the fiscal unit supervisor can complete and sign the 1778 on behalf of the payee and attach the warrant remains. Destroyed warrants do not require a police report. Stop Payment and Replacement The payee must complete a 1778 to initiate a stop payment and request a replacement warrant. Ask the payee to review the form or, if requested, read and explain the contents. The payee and a notary must sign each copy of the 1778 in ink. Copy signatures are not acceptable. In limited circumstances that prevent 1778 completion in the local office (for example, out-of-state provider), forward it to the individual for notarized signature and return. Exception: Destroyed or mutilated warrants do not require payee signatures; see Destroyed Warrant in this item.
BAM 500 3 of 8 WARRANTS LOST, STOLEN, NOT RECEIVED, OR DESTROYED BPB 2024-018 7-1-2024
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After the 1778 is completed, enter the stop payment and replace- ment request in Bridges (even if the warrant has been cashed). Change status to one of the following: • Stop requested by worker. • Forgery analysis requested (if it is a paid warrant). • Promptly send 2 copies to: Payment Processing Unit Grand Tower Building 235 S. Grand Avenue, Suite 1015 Lansing, MI 48909 • File a copy in the case record. • Send a copy to the local fiscal office. • Give a copy to the payee. Original Warrant Found Remind the payee when completing the 1778, if the original warrant is found, it must be returned to the local office. If one is returned to you, forward it to the local fiscal office to be voided; see BAM 505, Returned Benefits. Client Requested Warrant Replacement When the client requests a warrant replacement and the request is processed, the specialist will receive an alert when the stop pay- ment is completed. The specialist is then able to replace the war- rant. Note: Forged warrants are replaced by the Payment Processing unit. The Payment Processing Unit denies the replacement if it is deter- mined that the payee cashed the warrant or benefited from its cash- ing. When Payment Processing informs the local office of the denial, notify the client via MDHHS-176, Benefit Notice. Vendor Warrant Replacement A vendor warrant is replaced only after recovery of the amount issued, unless the warrant was voided or undeliverable; see BAM 505, Returned Benefits. A police report is not necessary.
BAM 500 4 of 8 WARRANTS LOST, STOLEN, NOT RECEIVED, OR DESTROYED BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• If the warrant is issued to the same payee for the same amount, the specialist can process the replacement. • If the warrant is issued to a different payee but is for the same amount, only central office can process the replacement. Note: For SER, if the warrant is issued for a different amount, the specialist can reprocess the warrant (for example, reregister the SER using the original SER date). 1354 PROCESS Often, a stop payment is requested after the original warrant was cashed and paid by Treasury. MDHHS and Treasury are responsible to recover the funds before a replacement warrant is issued. To replace a payment that has been cashed complete a 1354, Affidavit Claiming Forged Endorsement on a State Treasurer’s Warrant Process. • Payment Processing sends a copy of the warrant and a cover memo to the local fiscal office. • The local fiscal office will complete the 1354, Affidavit Claiming Forged Endorsement on a State Treasurer’s Warrant, attach the cover memo, a photocopy of the warrant and forward to the specialist for completion. • The specialist schedules a local office appointment with the payee to explain the 1354 process and to have the payee view the warrant copy signature. • If the payee fails to keep the appointment, or refuses to sign the affidavit, return the 1354 with the memo to the local fiscal office with an explanatory note. The local fiscal office returns the 1354 to the Payment Processing Unit. • If the payee admits endorsing the warrant, obtain a signed statement to that effect. Return the 1354 with the memo to the local fiscal office. The local fiscal office returns the 1354 to the Payment Processing Unit. • If the payee claims the signature on the warrant copy is forged, both the payee and a notary public must sign each copy of the 1354 in ink. Only original signatures are acceptable.
BAM 500 5 of 8 WARRANTS LOST, STOLEN, NOT RECEIVED, OR DESTROYED BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• File a photocopy of the signed 1354 and warrant in the case record, and give the payee a photocopy of only the 1354. • Return the 1354 and warrant copy to the local fiscal office for mailing to the Payment Processing Unit. Forgery/Recovery If the client and/or provider disagrees with the decision not to issue a replacement warrant, the client may request a hearing by completing a DHS-18, Request For Hearing. If it is determined that the warrant can be rewritten, Payment Pro- cessing replaces the warrant. Note: Administrative Hearings will deny requests for hearings requested by providers. CONSOLIDATED VENDOR, MEDICAL SERVICE AND SER HEAT/ELECTRIC WARRANTS Stop payment/replacement procedures apply to: • Consolidated vendor warrants issued to cover more than one client’s heat/electric vendored amount. • Medical services warrants. Determine the status of these warrants in Bridges. The provider must complete the 1778 to initiate a stop payment and request a replacement warrant. Follow procedures in the Stop Pay- ment and Replacement section of this item. Instead: • Promptly send 2 copies to:
Provider Management Payments Unit (PMPU)
Financial Services, Accounting Division
Grand Tower Building
235 S. Grand Avenue, Suite 1004
Lansing, MI 48909
• File a copy in the case record.
BAM 500 6 of 8 WARRANTS LOST, STOLEN, NOT RECEIVED, OR DESTROYED BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Send a copy to the local fiscal office. • Give a copy to the provider. When the warrant replacement request is processed. The specialist receives an alert when the stop payment is completed. The special- ist is then able to replace the warrant. Before authorizing payment, verify that the provider information in Bridges is correct. If necessary, correct the information; see BAM 435, Provider Management.
If the stop payment cannot be effected because the warrant was cashed, follow procedures in 1354 Process section of this item. Note: Forged warrants are replaced by the Payment Processing unit. WARRANT STATUS When a warrant is reported lost, stolen, not received or destroyed, check the Warrant Status to determine if a warrant was issued: • If the warrant status shows returned/cancelled, do not proceed with a stop payment. • If the warrant status shows tax offset, do not proceed with a stop payment. This status indicates the warrant was pulled by Treasury; see Warrants Pulled By Treasury in this item. • If the warrant status is paid, this indicates the warrant has been cashed. If the payee still claims they did not receive and cash the warrant, proceed with the 1778 affidavit; see Stop Payment and Replacement in this item. Once the Forgery Analysis has been requested, follow the 1354, Affidavit Claiming Forged Endorsements On A State Treasurer’s Warrant Process in this item. • If the warrant status was an Electronic Funds Transfer (EFT) and shows as paid, do not proceed with a stop payment. This indicates payment was made via an EFT. EFT payments are deposited electronically into an account at a financial institution designated by the provider. If the provider indicates that they
BAM 500 7 of 8 WARRANTS LOST, STOLEN, NOT RECEIVED, OR DESTROYED BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
did not receive this payment, they must resolve the matter with their financial institution. Note: An EFT warrant shows in Bridges as a warrant number starting with 0. • If the warrant status is EFT payment returned/cancelled, this status indicates that an electronic funds transfer (EFT) was returned/cancelled to Treasury and rewritten. • If a warrant is issued and is still outstanding, see 1778 process in this item. Warrants Pulled By Treasury Treasury may pull a warrant in order to offset monies owed the state by the provider. Warrants pulled by Treasury will have a warrant status of tax offset in Bridges. Treasury notifies the provider in writing of the reason for this action. Providers who contact the local office regarding a warrant pulled by Treasury should be advised to refer to this letter and contact Treasury at 1-800-950- 6227 if they have any questions. Residual Warrant If the amount of the warrant pulled was greater than the amount owed to the state, Treasury will issue a new warrant called a resid- ual warrant for the remaining balance to the provider. Rewrite Or Cancel Residual Warrant Returned To Local Office Residual warrants do not appear in MDHHS systems. When one of these Treasury warrants needs to be rewritten, cancelled or stop payment request initiated, do the following: • The local fiscal office prepares the DHS-2362, Services Warrant Rewrite/Disposition Request and sends to the specialist. • The specialist completes the DHS-2362 indicating if the residual warrant is to be rewritten or cancelled. The DHS-2362 must be signed by the specialist and a manager and returned back to the local fiscal office to forward to the Payment Processing unit.
BAM 500 8 of 8 WARRANTS LOST, STOLEN, NOT RECEIVED, OR DESTROYED BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Payment Processing will request that Treasury rewrite or cancel the residual warrant. Rewrite Or Cancel Residual Warrant Returned To Treasury To determine if a residual warrant was issued by Treasury, contact the Specialized Action Center at 1-800-444-5364. If issued, request the warrant number and verify if it has been returned. If a residual warrant was not issued, inform the provider and end procedure. If a residual warrant was issued and the provider did not receive the benefit, advise the provider to contact Treasury at 1-800-950-6227. LEGAL BASE FIP Social Welfare Act, PA 280 of 1939, as amended Uniformed Unclaimed Property Act, PA 29 of 1995, as amended Mich Admin Code, R 400.3104 SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180
CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
SSP 20 CFR 416 Social Security Act, §1616 [42 USC 1382e]
BAM 502 1 of 2 FOOD BENEFIT REPLACEMENT BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY Food Assistance recipients may be issued a replacement of Food Assistance Program (FAP) benefits when food purchased with FAP benefits has been destroyed in a domestic misfortune or disaster and reported timely. See BAM 401E, Electronic Benefit Transfer Issuance System, for policy regarding replacement of Bridge cards. Limits There is no limit to the number of replacements for food purchased with food assistance benefits and destroyed in a domestic misfor- tune or disaster. Individual Responsibilities Replacements and reauthorizations are processed only if the individual reports the loss timely. Timely means within 10 days if the loss is due to domestic misfortune or disaster. However, if day 10 falls on a weekend or holiday and it is reported on the next workday, it is still considered timely. Once the individual reports the loss, they must be given or sent a DHS-601, Food Replacement Affidavit, and a VCL giving them 10 days to return the DHS-601. Approval and Denial of Replacements The request for replacement must be completed within 10 days of the request, or within two working days of receipt of the signed DHS-601, whichever is later. If approving or denying a replacement, send the individual a MDHHS-176, Client Notice, within 10 days of the individual's request. Domestic Misfortune or Disaster Domestic misfortunes or disasters include events which occur through no fault of the individual, such as fires, floods or electrical outages. Verify the circumstances through a collateral contact, a community agency, utility company or a home visit, and note it on the DHS-601.
BAM 502 2 of 2 FOOD BENEFIT REPLACEMENT BPB 2025-022 10-1-2025
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Except for households certified as part of Emergency Food Assistance for Victims of Disasters, replacement issuance shall be provided in the amount of the loss to the household, up to a maximum of one month's allotment, unless the issuance includes restored benefits which shall be replaced up to their full value. Discuss with the individual the amount of food originally purchased with FAP benefits that was lost as a result of the domestic misfortune or disaster. Replace the amount the individual states they have lost up to the value of the current month’s allotment. The individual must complete the DHS-601 describing the loss. Note: If FNS has declared a disaster, the group may receive either disaster benefits or replacement of food, but not both. EXHIBIT
Replacement Circumstancesa When Individual Must Request Limit on Replacementsb Specialist Time Period Follow-Up Food of current participant originally purchased with FAP benefits destroyed in a domestic misfortune or disaster. Within 10 days of the domestic misfortune or disaster. Or the next workday if day 10 falls on a weekend or holi- day. None. Disaster must be verified. Individual must attest to amount of food loss on DHS-601. Within 10 days of the request, or within two working days of receipt of the signed DHS- 601, whichever is later. None. Note: Cannot receive both a replacement and FNS declared disaster allotment. a. If a circumstance does not fit those described on the chart a replacement is not allowed. b. If a replacement is approved or denied, the group must be informed via the MDHHS-176.
LEGAL BASE 7 CFR 274.6 7 CFR 280
BAM 505 1 of 7 RETURNED/CANCELLED BENEFITS BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY This item details procedures for handling FIP, RCA, SDA, State SSI Payment (SSP), CDC, SER, and Medical Services warrants and cash EBT benefits. WARRANTS FIP, RCA, SDA, and SSP Returned and cancelled warrants can be rewritten. Note: A regular assistance warrant payable to a deceased client may be rewritten only if the case remains active under another payee. A vendor warrant to a deceased provider (for example, landlord) can be rewritten to either the executor of the provider's estate or to the client. In some circumstances, the client may not be eligible for the warrant to be rewritten. Initiate closure when any of the following occurs: • The post office returned a warrant to Treasury as undeliverable. • The warrant remains uncashed for over 30 days, and there has been no contact from the client. • The client fails to contact you by the disposition deadline for a warrant returned/cancelled or delivered to the local office. Warrants Returned to Treasury Warrants returned to Treasury are voided. If undeliverable, MDHHS central office will forward the envelope and enclosures and send to the local office for follow up. Check the View Benefits in Bridges, when a payee requests replacement of a warrant not received, to determine if it was returned/cancelled. • Returned/cancelled warrants are replaced, by using the Rewrite Warrants screen in Bridges; see replacing warrants/benefits in this item.
BAM 505 2 of 7 RETURNED/CANCELLED BENEFITS BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• If the warrant was not issued, ask a local office designated staff to contact theBridges Resource Center (BRC). . • If the warrant was issued but not returned/cancelled; see Warrant Not Received in BAM 500. Warrants Returned to the Local Office The local fiscal office processes returned warrants. Forward any warrants received to that office. The local fiscal office notifies the specialist via a DHS-2362, State Treasurer’s Warrant Rewrite/Disposition Request, of client and vendor warrants that are returned or delivered to the local office. The DHS-2362 authorizes warrant disposition. Determine whether the warrant should be: • Voided and returned to Treasury. • Voided and rewritten. • Mailed to the client. • Picked up by the client at the local office. Note: Representatives picking up a warrant for a client must have the client’s signed statement of permission. Complete the DHS-2362. If the warrant must be voided and rewritten, see below for the correct rewrite procedure. Return the completed DHS-2362 to the local office designee within 10 workdays. REPLACING WARRANTS/ BENEFITS
Local Office Replacement Authorize replacement of a warrant/benefit using the DHS-138 or Bridges. A replacement warrant must be for the exact amount as the original warrant/benefit. The replacement warrant will reflect current Bridges information. Update payee and address information, if necessary, before replacing the warrant or requesting warrant rewrite.
BAM 505 3 of 7 RETURNED/CANCELLED BENEFITS BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Note: A warrant returned to the local office must be voided and returned to Treasury by the local office designee before it is rewritten. Notify the local office designee of the disposition via DHS-2362. The specialist must wait until the warrant status shows cancelled before authorizing the rewrite via DHS-2362; see Warrant Returned to the Local Office in this item. Clients can expect warrants/benefits replaced via Bridges to arrive at the current mailing address in 7-10 days after the replacement is authorized. Replacing Expunged Benefits Replace expunged benefits through the Re-Issue Expunged Bene- fits in Bridges. Replacing Escheated Benefits Escheated benefits are replaced by Treasury, not by MDHHS. Refer clients who request replacement of escheated benefits to Treasury’s Unclaimed Property Division at (517) 636-5320 or online at Michigan’s Money Quest under Unclaimed Property on the Michigan Department of Treasury Web site. Escheated benefits are identified in Bridges, Benefit Issuance as Tax Offset. Inserts and Other Enclosures When warrants are released or rewritten, be sure clients receive all enclosures (such as, informational inserts) included with the original warrant. Closure After Uncashed/ Returned Warrant When a warrant is uncashed for over 60 days, or was sent back to Treasury, the specialist receives the following: • The envelope and enclosures. Notations on the envelope usually indicate why the warrant was undeliverable or otherwise returned. • Report PH-280, Uncashed Client Warrants.
BAM 505 4 of 7 RETURNED/CANCELLED BENEFITS BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Initiate case closure within two workdays of receiving the above information if there has been no client contact. Update the case with unable to locate. If the envelope notations indicate ineligibility for previous warrants/benefits, begin the recoupment process. If the client contacts the specialist during the timely notice period, stop the case closure and replace the warrant/benefit if requested. Exception: Do not initiate case closure if the warrant sent back to Treasury is an SSP or a vendor warrant. Contact the provider or client to determine the correct address. Unclaimed Warrant Returned to the Local Office Close the case when a warrant is returned to the local office and the client fails to contact the specialist by the warrant status due date. PH-280 Processing The PH-280 helps document case actions in response to uncashed, undeliverable and voided warrants. Note in the worker action column next to each: • The date of the case action. • The disposition of the uncashed warrant. • Whether the warrant was replaced. • If not replaced, the reason. Upon receipt of the PH-280, forward the previous month's report to your manager. MEDICAL SERVICE AND SER OR HEAT/ELECTRIC VENDOR WARRANTS Special procedures apply when replacing medical service warrants, SER warrants or heat/electric vendor warrants authorized in Bridges. The Provider Management Unit (PMU) in central office will notify the specialist by memo when a warrant has been returned to Treasury.
BAM 505 5 of 7 RETURNED/CANCELLED BENEFITS BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Before authorizing a replacement warrant, verify that the provider information in Bridges is correct. Correct the information, if neces- sary; see BAM 435, Provider Management. To authorize a replacement warrant: • Complete the requested information on the memo. • File a copy in the case record. • Return original memo with attachments back to PMU. CHILD DEVELOPMENT AND CARE WARRANTS A Child Development and Care (CDC) warrant returned to Treasury or the local office can be rewritten, cancelled or released, using a DHS-2362, Services Warrant Rewrite/Disposition Request. When a warrant includes multiple clients, and multiple specialists, only one DHS-2362 will be issued. The specialist of the first case listed on the warrant is responsible to rewrite or cancel the warrant. The specialist can only rewrite a CDC warrant to the original payee and for the original amount. The specialist can rewrite warrants that have been returned to Treasury using the Rewrite Warrant screen. Central office must rewrite the warrant if the rewrite amount is for less than the original warrant. Rewrites for a higher amount are not allowed, the provider must rebill for the higher amount. Rewrites to a different provider are not allowed. If payment was made to the wrong provider, follow the new provider assignment process. Warrants Received by the Local Office When a warrant is received in the local office, the local office designee completes the DHS-2362 retains the warrant and forwards the DHS-2362 to the specialist. The specialist must determine within 10 working days if the warrant is to be rewritten, cancelled or released by completing the DHS- 2362 indicating the appropriate action code.
BAM 505 6 of 7 RETURNED/CANCELLED BENEFITS BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
The specialist retains a copy in the case file and forwards the com- pleted DHS-2362 to the local office designee. Warrants Undeliverable and Returned to Treasury When a warrant is returned to Treasury, the warrant status on the View Benefits screen will be automatically updated indicating that the warrant has been returned/cancelled. A Task and Reminder is generated to the specialist and designated local office designee staff person. The local office designee forwards the DHS-2362 to the specialist. Within 10 working days the specialist completes the DHS-2362 indi- cating if the warrant is to be rewritten or never replaced. See instructions for completing the DHS-2362 on the form. A rewritten warrant will be issued with the next scheduled CDC payroll if entered by the corresponding CDC deadline date; see BEM 711, CDC Payment Schedule. Note: An EFT payment that is rewritten will be re-issued as a paper warrant. For a warrant to be rewritten for a lesser amount: • Complete the DHS-2362 and obtain the manager's signature. • File a copy of the DHS-2362 in the case record. • Forward the original to the local office designee. The local office designee will forward the DHS-2362 to the Reconciliation and Recoupment Section in central office for processing. For a warrant that is not to be rewritten: • Complete the DHS-2362. • Forward the DHS-2362 to the local office designee. • File a copy in the case record. Note: The local office can rewrite a warrant cancelled in error.
BAM 505 7 of 7 RETURNED/CANCELLED BENEFITS BPB 2024-018 7-1-2024
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Uncashed Warrants Over 180 Days Old Warrants that remain uncashed after 180 days will have a warrant status of cancelled on the View Benefits screen. These warrants may be rewritten by the local office using the Rewrite Warrant screen in Bridges. LEGAL BASE FIP Social Welfare Act, P.A. 280 of 1939, as amended MCL 567.221 et seq. Mich Admin Code, R 400.3103 SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016 SSP 20 CRF 416 Social Security Act, §1616 [42 USC 1382e]
BAM 600 1 of 50 HEARINGS BPB 2026-014 5-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY All Programs This item applies to all assistance programs including Summer EBT (SEBT) Clients have the right to contest a Michigan Department of Health and Human Services (MDHHS) decision affecting eligibility or benefit levels whenever they believe the decision is incorrect. MDHHS provides an administrative hearing to review the decision and determine its appropriateness in accordance to policy. This item includes procedures to meet the minimum requirements for a fair hearing. Efforts to clarify and resolve the client’s concerns must start when the hearing request is received and continue through the day of the hearing. NOTICE REQUIREMENTS All Programs The application forms and each written notice of case action must inform clients of their right to a hearing. These include an explana- tion of how and where to file a hearing request, and the right to be assisted by and represented by anyone the client chooses. The client must receive a written notice of all case actions affecting eligibility or amount of benefits. When a case action is completed, it must specify: • The action being taken by the department. • The reason(s) for the action. • The specific manual item(s) that cites the legal base for an action, or the regulation, or law itself; see Bridges Administrative Manual (BAM) 220, Case Actions. Exception: Do not provide a notice of case action when implementing a hearing decision or policy hearing authority decision. The decision serves as notice of the action.
BAM 600 2 of 50 HEARINGS BPB 2026-014 5-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Medicaid (MA) Only A client and the client’s community spouse are each entitled to an explanation of specific factors in the determination. Follow instruc- tions in Bridges Eligibility Manual (BEM) 402. Special MA Asset Rules. HEARING REQUESTS All Programs All clients have the right to request a hearing. The following people have authority to exercise this right by signing a hearing request: • An adult member of the eligible group; or • The client’s authorized hearing representative (AHR). Requests for a hearing must be made in writing and signed by one of the persons listed above. The request must bear a signature. Faxes or photocopies of signatures are acceptable. Michigan Office of Administrative Hearings and Rules (MOAHR) will deny requests signed by unauthorized persons and requests without signatures. Exception: For Food Assistance Program (FAP) only, a hearing request may be written or oral. If oral, complete the DHS-18, Request for Hearing, note on the DHS-18 the request was oral. Also note on the hearing summary that the request was oral. A hearing request with a client signature may name an AHR who is authorized to stand in for or represent the client in the rest of the hearing process. Dissatisfaction with a department action may be expressed, orally or in writing, without specifically requesting a hearing. Determine whether there is actually a desire to request a hearing. If so, ensure that the request is put in writing. The DHS-18, Request for Hearing, available from MDHHS, may be used. Note the date of receipt of the original written request on the form/notice. All hearing requests must be recorded in Bridges, on the Hearing Restore Benefits screen; see Timely Hearing Requests in this item.
BAM 600 3 of 50 HEARINGS BPB 2026-014 5-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Requests Signed by an AHR All Programs The appointment of an AHR must be made in writing. An AHR must be authorized or have made application through probate court before signing a hearing request for the client. Verify the AHR's prior authorization unless the AHR is the client’s attorney at law, parent or, for MA only, spouse. Relationship of the parent or spouse must be verified only when it is questionable. MOAHR will deny a hearing request when the required verification is not submitted; see Local Office and MOAHR Time Limits in this item. The following documents are acceptable verification sources: • Probate court order or court-issued letters of authority naming the person as guardian or conservator. • Probate court documentation verifying the person has applied for guardian or conservatorship. • Authorization signed by the client authorizing this person to represent the client in the hearing process. • Birth or marriage certificate naming the person as parent or spouse or adult child. Note any known information about the identity of the person who signed the request (for example, a spouse) on the DHS-3050, Hearing Summary. Attach a copy of any required verification document to the DHS-3050 and forward to MOAHR. Process requests signed by someone whose AHR status is questionable or unverified according to standard hearings procedures, including restoration of benefits, if appropriate. If MOAHR denies the request, reimplement the disputed case action and recoup the restored benefits; see Recouping Program Benefits in this item. When the AHR is an Attorney All Programs
BAM 600 4 of 50 HEARINGS BPB 2026-014 5-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
A DHS-1216-AP, Request for Attorney General Representation, must be completed if a client will be represented by an attorney at the hearing. Submit the DHS-1216-AP form to the Bureau of Legal Affairs (BLA) at MDHHS-AGrepresentation-AP@michigan.gov at the earliest of: • The date that the DHS-3050, Hearing Summary, is sent to MOAHR, or • Within 24-hours of learning an attorney will be representing the client, where the DHS-3050 has already been sent to MOAHR. The Bureau of Legal Affairs (BLA) will review the request for appropriateness and completeness, and if approved, BLA will forward the DHS-1216-AP to the Office of the Attorney General for assignment. The Attorney General’s Office requires a two-week notice prior to the date of the hearing. If there is less than two weeks’ notice, make a request for adjournment to M0AHR for the purpose of arranging legal representation; see Request for Adjournment in this item. Make a request for representation even if a hearing date is not received. Adjournment is putting off a scheduled administrative hearing until a later date. Note: Request attorney general representation using the process in this item if it is beneficial to the department to have attorney general representation for example, a complex issue in dispute; client representation by a third-party organization, etc. Communication with Assigned Assistant Attorney General Direct all routine communications to the assigned assistant attorney general (AAG), not to MOAHR. This directive does not pertain to communications that only MOAHR can address. (For example, dismissal of a case when a client requests to withdraw a request subsequent to the meaningful prehearing conference.) Under no circumstances should any local office or policy unit send an email to the AG-HEFS mailbox. That email address is only for the BLA requests for representation and the email notice from the attorney general of the assignment of an AAG. Any other communication to that mailbox will cause confusion and delay in obtaining the representation of the MDHHS by the attorney general’s office. Any communication about a case prior to the
BAM 600 5 of 50 HEARINGS BPB 2026-014 5-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
assignment of an AAG can be directed to the MDHHS- AGrepresentation-AP@michigan.gov mailbox. Prehearing Conferences AAGs do not generally participate at meaningful prehearing conferences held by the department. Do not delay the scheduling of a prehearing conference for the assignment of an AAG. Be certain however, to share any documents and/or communication received at the prehearing conference with an AAG, once one is assigned. Department Requests All Programs The department may request a hearing to establish an intentional program violation, a disqualification, or a debt; see BAM 720, IPV Hearing. Usually Office of Inspector General (OIG), the OIG Overpayment Establishment Analysts (OEA) make these requests. Referral suspected IPV to OIG. Granting a Hearing All Programs MOAHR may grant a hearing about any of the following: • Denial of an application and/or supplemental payments. • Reduction in the amount of program benefits or service. • Suspension or termination of program benefits or service. • Restrictions under which benefits or services are provided. • Delay of any action beyond standards of promptness. • For FAP and CDC, the current level of benefits or denial of expedited service. MA Only MOAHR may grant a hearing about any of the following: • Community spouse income allowance. • Community spouse's income considered in determining the income allowance.
BAM 600 6 of 50 HEARINGS BPB 2026-014 5-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Initial asset assessment (but only if an application for MA has actually been filed for the client). • Determination of the couple's countable assets or protected spousal amount. • Community spouse resource allowance. Where to File a Hearing Request All Programs Instruct clients or AHR's to deliver, mail, or fax the hearing request to their local MDHHS office labeled, Attention Hearings Coordinator. The hearings coordinator receives the request on behalf of the department. Route all hearings-related material through the coordinator without regard to whom it is addressed. All hearings requests received must be date-stamped and for- warded immediately to the hearings coordinator. If the hearing request is received by a local office that is not responsible for the disputed action, date-stamp the request and forward it immediately to the correct local office labeled, Attention Hearings Coordinator. Exception: For hearing requests about Medical Services Administration (MSA) determinations, follow procedures in MSA HEARINGS in this item. The administrative tribunal ensures that the request is properly processed. Deadlines for Requesting a Hearing All Programs The client or AHR has 90 calendar days from the date of the written notice of case action to request a hearing. The request must be received in the local office within the 90 days; see Where to File a Hearing Request, found in this item. Exception: SEBT groups have 90 days from the date of the written notice of case action to request a hearing. The request must be received in writing by MDHHS within the 90 days, see BEM 619, Summer EBT Program.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Note: Unless otherwise stated elsewhere, computation of time for the purposes of administrative hearings is determined as follows: • Time is measured in calendar days. • The computation of time begins on the day after the act, event, or action occurs. (The day on which the act, event, or action occurred is not included.) • The last day of the time period is included, unless it is a Saturday, Sunday, State of Michigan holiday, or day on which the State of Michigan offices are closed. (In such instances, the last day of the time period is the next business day.) • The last day of the time period runs through the normal close of business. Example: A notice of case action is issued on August 1st. Under BAM 600, the client has 90 days to request an administrative hearing. In computing this time period, August 1st, the date on which the action was taken, is not counted. The client must file a request for hearing by the close of business on October 30th (unless that day is a weekend, holiday, or non-working day, in which case the request must be filed by the close of the next business day.) Exception: For FAP only, the client or AHR may request a hearing disputing the current level of benefits at any time within the benefit period. See Timely Hearing Request in this item if a request is received: • Within the pended negative action period. • Within 11 days of the effective date of an immediate negative action (such as with adequate notice). For requests that do not meet the definition of a timely hearing request; see Untimely Hearing Request in this item. Denial of a Hearing Request All Programs For hearing requests about MSA determinations; see MSA Hearings in this item.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
For all inappropriate requests and/or requests filed more than 90 days from the date of the notice of case action, do the following: • Complete a DHS-3050, Hearing Summary, stating either of the following: State with some specificity why the request should not be heard. The request was received after 90 days from the date of the notice of case action (attach a copy of the notice). • If there is no resolution at the meaningful prehearing conference, send by US postal mail or ID mail the hearing request and summary to MOAHR. MOAHR will inform the client (referred to by administrative hearings as the claimant), the AHR and the hearings coordinator if the request is denied. MOAHR will not grant a hearing regarding the issue of a mass update required by state or federal law unless the reason for the request is an issue of incorrect computation of program benefits or patient-pay amount. Central office may issue separate instructions regarding deletion of pending negative actions and forwarding of hearing requests to MOAHR for disposition. Supplemental Security Income (SSI)-Related MA Only MDHHS cannot conduct hearings regarding the issue of disability/blindness when the Social Security Administration (SSA) made the determination, and that determination is the only issue. These appeals must be filed at SSA. If the request includes other issues that MDHHS must hear, do the following: • Refer the client to SSA to appeal the SSA disability/blindness determination. • For all remaining issues, follow standard procedures outlined in this item. Document the referral to SSA on the hearing summary.
BAM 600 9 of 50 HEARINGS BPB 2026-014 5-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
STANDARDS OF PROMPTNESS All Programs Final action on hearing requests, including implementation of the decision and order (D&O), must be completed within 90 days. The standard of promptness begins on the date the hearing request was first received by any local MDHHS office or MDHHS central office. For FAP only, final action on hearing requests involving only FAP or FAP and any other program (for example, State Disability Assis- tance (SDA), MA, Child Development and Care (CDC) must be completed within 60 calendar days of receipt of the written or oral request. Exception: When a hearing request is for Family Independence Program (FIP) and FAP ONLY, the FIP timeliness standard of 90 days may be applied. Local Office Time Limits All Programs Local offices have 21 days from receipt of a hearing request to do all of the following: • Log the request. • Obtain and submit to MOAHR verification of the AHR's prior authorization, if needed. • Contact partners 24 hours within receiving DHS-18. • Schedule a meaningful in-person prehearing conference with a first-line supervisor no later than the 11th calendar day from the receipt of the request for hearing. Include all appropriate staff and partners. (for example, first-line supervisor, Office of Child Support (OCS) or prosecuting attorney's office (PA), Office of Quality Assurance (OQA) auditors, Partnership. Accountability. Training. Hope. (PATH) representative, Family Independence Specialist/Eligibility Specialist (FIS/ES) or OIG). Exception: A prehearing conference is not completed for SEBT.
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Note: When the 11th day falls on a non-workday, the prehearing conference must be scheduled by the next workday. Do not schedule a meaningful prehearing conference for Disability Determination Service (DDS) disputes. • Determine the nature of the complaint. • If the issue(s) raised in the request for hearing is not resolved at the meaningful prehearing conference, ID mail or send by US postal mail all the following to MOAHR: • DHS-18, Request for Hearing. • Any required verification of authority to represent. • DHS-3050, Hearing Summary, to include, but not limited to the following: Clear, concise statement of the case action(s) taken, including all programs involved in the case. Chronological summary of events, containing facts that led to the action(s) taken. Identification of any verifications supporting the action(s) taken. Citation of policy that supports the action(s) taken. Correct address of the client and the AHR. • Complete hearing packet to include, but not limited to, the following: DHS-1605, Notice of Case Action. DHS-1606, Health Care Coverage Determination Notice. A narrative of the meaningful prehearing conference offer and outcome and the DHS-1560, Notice of Prehearing Conference. A copy of all documents the Department intends to offer as exhibits at the hearing.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Numbering of the hearing packet in the lower right corner of each page. Note: MOAHR must receive the hearing summary and hearing packet by the 21st day. For hearing requests disputing: • Determinations made by the DDS. • Determinations made by MSA; see MSA Hearings in this item. • Determinations made by the OCS or a (PA) office, a copy of the request for hearing must be faxed to the office that initiated the adverse action within 24 hours of receipt. The fax cover sheet must include: • Title “Administrative Hearing-Time Sensitive.” • Contact information for the hearing coordinator, MDHHS specialist and the Family Independence Manager (FIM)/Assistance Payments (AP) Supervisor. • Date and time of the prehearing conference. The local office has 10 days from the date the decision was mailed from MOAHR to complete the DHS-1843, Administrative Hearing Order Certification, which certifies compliance. MOAHR Time Limits MOAHR has 59 days to schedule and conduct a hearing, render a decision and mail it to the local office, the client and the AHR. Exception #1: For MA community spouse resource allowance requests only, MOAHR has 15 days to schedule and conduct a hearing and 50 days to render and mail a decision. Exception #2: For FAP only, MOAHR has 29 days to schedule and conduct a hearing, render a decision and mail it. Local Controls All Programs A DHS-1940, Hearing Request Record, or its equivalent must be maintained by the hearings coordinator. The coordinator is
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responsible for tracking the progress of the hearing request from receipt through disposition. Note: A copy of the Hearing Request Record must be made available to the Business Service Centers or central office upon request. Expedited Hearings All Programs Request an expedited hearing when unusual circumstances exist. A local office supervisor or hearings coordinator may request an expedited hearing by calling the MOAHR director or designee. Do all of the following within two workdays of receiving the hearing request: • Complete the DHS-3050. Include an explanation about why an expedited hearing is needed; see Hearing Summary in this item. • Write “Expedited Hearing” at the top of the hearing request. • Forward the hearing request and the summary to MOAHR. Note: The hearing itself is conducted in the same manner as any other hearing. FAP Only Request an expedited hearing if a migrant group plans to leave the state within 60 days. Requests for Adjournment All Programs The client, AHR, or local office may request an adjournment of a scheduled hearing. Instruct the client or AHR to call MOAHR to request an adjournment. All requests for adjournment should be in writing to MOAHR and must include a specific reason for the request unless exception #1 or #2 below applies. Only MOAHR can grant or deny an adjournment. MOAHR will notify the hearings coordinator if the adjournment is granted. When the hearing is
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rescheduled, a new notice of hearing is mailed to everyone who received the original notice. If the adjournment is granted at the request of the client or AHR, the standard of promptness is extended for as many days as the hearing is adjourned. However, adjournment of a telephone hearing to schedule an in-person hearing does not extend the standard of promptness. Adjournments requested by the local office and MOAHR initiated adjournments do not extend the standard of promptness. Exception #1: For FAP only, MOAHR must grant one adjournment of a scheduled hearing requested by the client or AHR. It cannot exceed 30 days unless good cause is shown. Exception #2: For FAP-intentional program violation only, MOAHR must grant an adjournment of a scheduled hearing if the client or AHR makes the request at least 10 days in advance of the hearing. It cannot exceed 30 days and MOAHR may limit the number of adjournments to one. COMMUNITY ACTION AGENCY (CAA) AND LIMITED PURPOSE AGENCY (LPA) HEARINGS CAAs LPAs Only Community Action Agency (CAA) and Limited Purpose Agency (LPA) administer several programs that are funded through MDHHS. These programs vary depending on locality and funding availability, but generally include weatherization assistance, emergency assistance and programs that promote self-sufficiency. All CAAs and LPAs have internal appeals processes for clients who receive their services. If the CAA/LPA internal appeals process has been exhausted and fails to resolve the issue, and the program is a MDHHS-funded pro- gram, either the client or the CAA/LPA will forward a hearing request to the MDHHS Bureau of Community Action and Economic Opportunity.
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The bureau will review the hearing request, complete a DHS-3050, Hearing Summary, and forward the request to administrative hear- ings. Administrative hearings will handle the hearing request according to current procedures. Role of MDHHS Local Office Staff- CAA and LPA Hearings Only When the local MDHHS office receives a hearing request disputing services received by a CAA or LPA, the local hearings coordinator does the following: • Faxes a copy of the hearing request to MDHHS Bureau of Community Action and Economic Opportunity:
Fax: 517-335-5042
Phone: 517-373-3550 Be sure that the fax clearly identifies that it is a CAA or LPA hearing request. • Sends the original hearing request and any supporting materials within three workdays to: MDHHS Bureau of Community Action and Economic Opportunity 235 S. Grand Ave. Ste. 204 PO Box 30037 Lansing, MI 48909 The MDHHS Bureau of Community Action and Economic Opportunity will communicate the hearing decisions to the CAA/LPA. MSA HEARINGS MA Only Michigan Office of Administrative Hearings and Rules (MOAHR) for the Michigan Department of Health and Human Services conducts administrative hearings regarding MSA determinations; see MSA Determinations in this item. The tribunal also conducts hearings regarding the following MSA determinations:
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Medical transportation. • Level of payment for home help services. • Denial or reduction of specific home help services related to activities of daily living. The administrative tribunal has the same authorities and responsibilities MOAHR has for MDHHS hearings. These include: • Granting/denying a hearing request. • Scheduling/rescheduling the hearing. • Notifying all parties of the time/place of the hearing. • Processing requests for in-person hearings. • Granting/denying requests for adjournments. • Issuing administrative subpoenas. • Reimbursing clients for hearings-related expenses. • Holding the hearing. • Issuing a decision and order. • Granting/denying a rehearing/reconsideration request. Note: Medicaid Recipients enrolled in a managed care health plan, Community Mental Health Services Program- Pre-Paid Inpatient Health Plan (CMHSP-PIHP), or MI Choice Waiver Agency who disagree with an adverse benefit determination made by the health plan/ CMHSP-PIHP/MI Choice Waiver Agency must first exhaust the internal appeal process with that organization prior to being eligible to request a state fair hearing from MOAHR. An adverse benefit determination includes, but is not limited to, the denial or limitation of a requested service or the denial, reduction, suspension of termination of a previously authorized service. Beneficiaries who have questions about the internal appeals process should be directed to call the organization who took the action (health plan/CMHSP-PIHP/MI Choice Waiver Agency) first. They can also be directed to the Beneficiary Help Line at 1-800- 642-3195, TTY users call 1-866-501-5656. MSA Determinations MA Only MSA determinations include all the following: • Denial of prior authorization.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Denial of payment for a service, appliance or prosthesis. • Restricted utilization of the client’s mihealth card. • Determination of program enrollment type (PET) code (long- term care or MIChoice waiver). • Enrollment in managed care, including requests for exemption. • Denial of CHILD’s waiver services. • Reduction of services. • Authorization of MA for a newborn under; see BEM 145, Newborns. Role of MDHHS Staff Role of MDHHS Local Office Staff, Appeals Review Office Staff and MSA Policy Staff or MOAHR Staff MA Only When the local MDHHS office receives a hearing request disputing a MSA determination, the local office hearings coordinator does all the following: • Logs the hearing request. • Faxes a copy of the hearing request to MOAHR at 517-763- 0146. • Sends the original hearing request within three workdays to: Michigan Office of Administrative Hearings and Rules PO Box 30763 Lansing, MI 48909 MDHHS local office staff will provide a room for the hearing. Exception: See BAM 825, Medical Transportation, for MDHHS and Medical Services Administration (MSA) responsibilities when MDHHS receives a hearing request on medical transportation.
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Role of MSA Staff or MDHHS Appeals Review Office Staff MA Only MSA staff or MDHHS appeals review office staff have responsibility to do all the following: • Arrange an internal review of the appeal to identify appropriate staff involved and whether issue can be resolved. • Complete the hearing summary and send it to the client/representative and to MOAHR in advance of the hearing • Notify the client/representative, MOAHR, other MSA staff and local MDHHS if all issues raised in a hearing request are resolved prior to the hearing. • MSA staff or Appeals staff will represent MDHHS during the hearing by explaining the action taken by MDHHS as well as provide the policy that supports the action. • Department representatives such as ARO or MSA staff, will assist in distributing the decision and order to the appropriate department participants to facilitate compliance to the order in a timely manner. MSA staff will complete and send to MOAHR within 10 days, an order of certification of ALJ Order, if any. Michigan Office of Administrative Hearings and Rules (MOAHR) for the Department of Health and Human Services (MDHHS) staff have responsibility to do all the following: • MOAHR will send a notice of hearing to the client/representative, the appeals review office and local MDHHS hearings coordinator email box when a hearing is scheduled. • MOAHR will send the decision and order to the client/representative, other MSA staff, the appeals review office and local MDHHS hearings coordinator email box.
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LOCAL OFFICE REVIEW All Programs Resolve disagreements and misunderstandings quickly at the low- est possible level to avoid unnecessary hearings. On receipt of a hearing request, the hearings coordinator must schedule a meaningful in-person prehearing conference with the client and AHR and a first-line supervisor no later than the 11th calendar day from the receipt of the request for hearing. When the 11th day falls on a non-workday, the prehearing conference must be scheduled by the next workday. The client or AHR is not required to phone or meet with any department staff in order to have a hearing. Exception: For DDS disputes, do not schedule a prehearing conference unless the client or AHR requests one. Supervisory Review All Programs Upon receipt of the hearing request from the hearings coordinator, the first-line supervisor: • Reviews the disputed case action for accuracy according to policy and fact; see Corrected Case Action in this item. • Determines if the request is timely; see Interim Program Benefits Pending The Hearing in this item. Meaningful Prehearing Conference All Programs The department must assure that clients receive the services and assistance for which they are eligible. Concerns expressed in the hearing request should be resolved whenever possible through a conference with the client or AHR rather than through a hearing. The spokesperson for the local office at the prehearing conference may be anyone from the county director to a first-line supervisor.
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Whoever is assigned this function, however, acts on behalf of the county director or district manager. A DHS-1560, Prehearing Conference Notice, must be generated and mailed to the client and AHR upon receipt of a hearing request, unless the issue in dispute pertains solely to a DDS decision. A meaningful prehearing conference must be scheduled no later than the 11th day from the date MDHHS receives the request for hearing, unless the client and AHR chooses not to attend the prehearing conference. Note: When the 11th day falls on a non-workday, the prehearing conference must be scheduled by the next workday. All appropriate staff and partners (for example, first-line supervisor, support specialist (SS) or PA, PATH representative, FIS/ES or OIG) must participate in the prehearing conference. Exception #1: When the disputed case action involves a MSA determination, MSA staff must participate in the prehearing conference. Exception #2: When a meaningful prehearing conference is requested on a DDS dispute, the medical consultant does not participate in the conference. Exception #3: When the disputed case action involves a fleeing felon decision, OIG does not participate in the conference. A meaningful prehearing conference includes at a minimum, performing all of the following: • Determine why the client or AHR is disputing the MDHHS action. • Review any documentation the client or AHR has to support his/her allegation. • Explain the department's position and identify and discuss the differences. If the dispute cannot be resolved, do all the following: • Provide the client and AHR a copy of the DHS-3050, Hearing Summary, and all evidence the department used in making the
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determination that is in dispute. Complete the DHS-1520, Proof of Service. • Mention to clients the availability of reimbursement for child care or transportation costs incurred in order to attend the hearing; see Reimbursement for Transportation and Child Care in this item. State-funded Family Independence Program (FIP) and SDA Only Contact the local office Interim Assistance Reimbursement (IAR) liaison when the disputed action involves computation by central office payment reconciliation staff of the amount of retroactive SSI benefits recovered from a state-funded FIP or an SDA recipient who signed a repay agreement (Interim Assistance Recovery). The liaison must: • Obtain documentation supporting the calculations from payment reconciliation staff. • Arrange for payment reconciliation staff to participate in the prehearing conference. FAP and CDC For a denial of expedited service only, inform clients or authorized representatives that they may request a prehearing conference if they do not agree with the MDHHS decision. The conference must be held within two workdays of the expedited request, unless the client requests that it be scheduled later. The following persons must attend the conference: • Specialist’s supervisor and/or the local office director or designee. • Client, authorized representative or AHR. The specialist is not required to attend but may attend at local office option.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Corrected Case Action All Programs If the local office determines that the case action needs correction, do the following: • Update Bridges with the corrected information, including corrected Circumstance Start Change Date (CSCD) dates. Any benefits owed will be issued when Eligibility Determination and Benefit Calculation (EDBC) and certification is completed. This will result in a new Notice of Case Action being generated to the client. Ensure notices are provided to the AHR. • For Interim Assistance Recovery disputes, central office payment reconciliation staff will process corrective payments. • For state SSI payments, central office SSI Payments Unit staff will process corrective payments. • If the action taken does not resolve the issue include a short summary of the actions the local office took to correct all the client's concerns on the DHS-3050, Hearing Summary. Include a copy of the Notice of the Meaningful Prehearing Conference. • At the meaningful prehearing conference, explain the action taken and provide the AHR and the client a copy of the new notice of case action. Be sure to obtain a signature on the DHS-18M. Note: Once MOAHR receives a request for hearing, a hearing will be scheduled unless the client or AHR signs a DHS-18A, Written Withdrawal; see Withdrawals Not In-Person in this item. MA Only If a MDHHS denial is overturned on appeal by MDHHS, an Administrative Law Judge (ALJ) or a court, send or give the client a DHS-334, Reimbursement Notice.
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Hearing Summary All Programs Complete a DHS-3050, Hearing Summary, prior to the meaningful prehearing conference. In the event additional space is required to complete the DHS-3050, Hearing Summary, attach a word document to the DHS-3050 and number the word document accordingly. All case identifiers and notations on case status must be complete. The hearing summary must include all the following: • A clear statement of the case action, in chronological order, including all programs involved in the case action. • Facts which led to the action. • Policy which supported the action. • Correct address of the client and the AHR. • Description of the documents the local office intends to offer as exhibits at the hearing. Number the document copies consecutively in the lower right corner; begin numbering with the hearing summary. Exception #1: For hearing requests disputing state SSI payments, see State SSI Payment in this item. Exception #2: For hearing requests disputing MSA determinations, see MSA Hearings in this item. Exception #3: For DDS disputes do all the following: • Complete all identifying information at the top of the DHS- 3050. • Write a brief description of the case action, including all programs involved in the case action. • Explain the status of any SSI application. • Conclude with the statement “See attached medical packet.”
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Number the document copies in the medical packet consecutively in the lower right corner, attach them to the hearing summary and forward to the hearings coordinator. Exception #4: For hearing requests disputing OCS/PA actions: Attach a supplemental hearing summary completed by OCS/PA detailing actions taken and all evidence provided by the OCS/PA. State-funded FIP and SDA Only For Interim Assistance Recovery (IAR) disputes, prepare the hearing summary using documents obtained by the local IAR liaison from central office payment reconciliation staff. Attach copies of those and any other supporting documents to the hearing summary and forward to the hearings coordinator. MA Only When a hearing request based on a Medicaid denial is received, send or give the client a DHS-333, Retroactive Period/Corrective Action Eligibility Notice. This notice explains the potential for reim- bursement of paid medical expenses after a MDHHS denial that is overturned on appeal by MDHHS, an ALJ or a court. To be eligible for reimbursement, the payment must be for a Medicaid-covered care or service that is provided on or after February 2, 2004. If the client is to be notified of an overturned Medicaid eligibility decision, send or give the client a DHS-334, Reimbursement Notice. A client may be eligible for reimbursement of medical expenses paid to providers for a retroactive eligibility period Medicaid-covered care or service. A medical payment for care or services received in a client’s retroactive period may be reimbursable if it is made between a MDHHS denial and 10 days after the date an eligibility determination is issued as a result of the hearing request. A client may also be eligible for corrective action reimbursement of medical expenses paid to providers for care or services received after the MDHHS application. The corrective action period covers medical expenses paid to providers between the date a MDHHS administrative hearing request is filed and 10 days after the date an eligibility determination is issued as a result of the hearing request. The client must show that the original denial was incorrect for corrective action reimbursements. Example: A client submits his income and expense information but forgets to include proof of health insurance premiums or child
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support payments and is denied due to excess income. If the client appeals the MDHHS denial and provides the missing information, this could allow the initial denial, correct when issued, to be overturned. If the care or service for which the client made the medical payment was received after the client’s application that resulted in the MDHHS denial, the payment would not be eligible for reimbursement. Example: • 2/20/06 application for Medicaid and retroactive Medicaid is received by MDHHS. • 4/5/06 the application is denied. • 5/3/06 a hearing request is received in the local MDHHS office. • 6/7/06 the ALJ overturns the denial and determines the client is eligible for Medicaid. • 6/14/06 the specialist processes the Medicaid opening. If the medical payment was for care or services received in the retroactive period, the client is eligible for reimbursement for payments between 4/5/06 (the original denial date) and 6/24/06 (10 days after the second eligibility notice is mailed). If the medical payment was for care or services after the retroactive period, the corrective action period covers payments made between 5/3/06, (the date the hearing request was received by MDHHS) and 6/24/06, (10 days after the second eligibility notice was mailed). Hearing Packet All Programs A copy of the hearings packet must be ID mailed or sent by US postal mail to: 1. The client, if not presented at the prehearing conference. 2. AHR, if not presented at the prehearing conference. 3. MOAHR. Administrative Review All Programs
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The second-line manager or designee must review all hearing requests which are not resolved by the first-line supervisor. The purpose of the review is to assure that local office staff has done the following: • Applied MDHHS policies and procedures correctly. • Explained MDHHS policies and procedures to the client and AHR. • Explored alternatives. • Offered appropriate referrals to the client. • Considered requesting a central office policy clarification or policy exception, if appropriate. By signing box 4 on the DHS-3050, Hearing Summary, the second- line manager must certify: • The date the DHS-1560, Notice of Prehearing Conference, was sent to the client and AHR, if any. • The reason the hearing request could not be resolved. • That eligibility was properly determined for this case. • That the hearing request cannot be resolved, except through a formal hearing and the reason(s) why. The managerial certification does not replace the hearing process. The hearing must be held as scheduled unless the hearing request is withdrawn using a DHS-18A, Hearing Request Withdrawal. The second line manager or designee must evaluate the advisability of a hearing in relation to such factors as intent of policy, type of issue(s) raised, strength of the department's case, and administrative alternative. MA Only If, before a pending hearing, the local office overturns a Medicaid denial, see Implementing the Decision and Order in this item.
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CONTINUATION OF PROGRAM BENEFITS PENDING ADMINISTRATIVE HEARING
Denial at Application All Programs The client is not entitled to benefits pending the hearing when the reason for the hearing request is a denial at application or, for FAP only, a denial at redetermination. For FAP and CDC, when the hearing request disputes a denial of expedited service, continue to process the application according to normal processing standards. Timely Hearing Request All Programs A timely hearing request is a request received by the department within 10 days of the date the notice of case action was issued. When the 10th calendar day is a Saturday, Sunday, holiday, or other non-workday, the request is timely if received by the following workday. While waiting for the hearing decision, recipients must continue to receive the assistance authorized prior to the notice of negative action when the request was filed timely. Upon receipt of a timely hearing request, reinstate program benefits to the former level for a hearing request filed because of a negative action. For MA ONLY the department must maintain benefits if a beneficiary requests a hearing before the effective date of the action. For example, if a beneficiary is provided notice their Medicaid eligibility will be terminated effective 01/01/19, the beneficiary has until 12/31/18 to file a request and maintain their benefit. For FAP only, these actions apply only if the benefit period has not expired. Exception #1: For all programs, do not restore benefits reduced or terminated due to a mass update required by state or federal law
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unless the issue contested is that the benefits were improperly computed. Exception #2: For all programs, do not restore program benefits when the client or AHR specifically states in writing that continued assistance pending the hearing decision is not requested. Exception #3: For FAP only, if a client or AHR disputes the computation of supplemental benefits, issue the supplement as originally computed. Untimely Hearing Request All Programs If a client or AHR files an untimely hearing request, program benefits continue at the current level. Exception: For FAP only, benefits must be restored to the former level if either: • The delay in filing the request was for good cause (for example, client hospitalized). • The change was the result of a mass update and the issue being contested is that FAP eligibility or benefits were improperly computed or that federal law/regulation is being misapplied/misinterpreted. SSI Disability/ Blindness Denials SSI-Related MA Only MA negative actions based on SSI disability/blindness denials can- not be deleted if MOAHR schedules a hearing regarding other issues raised in the hearing request. However, if a hearing request is filed at SSA regarding the disability/blindness issue within the pended negative action period, follow the instructions in this item under Timely Hearing Request. MDHHS can never delete the negative action if the SSI disability/blindness denial is final as defined in BEM 260, MA Disability/Blindness.
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When Changes Occur Pending the Hearing All Programs Pending the hearing decision, restored benefits must not be reduced or terminated unless: • A change not related to the hearing issue occurs that affects the recipient's eligibility or benefits; and • The recipient or AHR fails to request a hearing about the change after the subsequent notice of negative action. Note: For FIP only, the client must continue participation with the Partnership. Accountability. Training. Hope. (PATH) program unless the hearing request was the result of non-cooperation. FAP Only Pending the hearing decision, restored benefits must not be reduced or terminated unless: • The benefit period expires. Note: The client may reapply and be determined eligible for a new benefit period and amount based on a new application. Recouping Program Benefits All Programs If a hearing request is filed timely and program benefits are restored, recoup overissuances if: • The request is later withdrawn. • MOAHR denies the request. • The client or AHR fails to appear for the hearing and MOAHR issues an order of dismissal. • The hearing decision upholds the department's action.
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Calculate the overissuance from the date the negative action would have taken effect until the date the negative action is subsequently implemented. If an administrative recoupment is processed to recover an overis- suance due to a hearing, send a timely notice of case action. In this situation, the client is entitled to a hearing solely on the issue of the recoupment amount. If a cash repayment is sought to recover an overissuance, requests for a hearing will not be granted except in FAP cases. Complete a DHS-3050 describing the current facts. Forward the hearing request and the summary to MOAHR. MOAHR will inform the client and AHR that a hearing will not be granted. WITHDRAWALS All Programs When any issue is still in dispute, do not: • Suggest that the client or AHR withdraw the request; or • Mail a withdrawal form to the client or AHR unless it is requested. When correcting a case action, follow procedures in the Corrected Case Action section of this item. Do not ask for a withdrawal based on an action that will be taken in the future; MOAHR cannot grant a withdrawal based on an action that has not been completed. If the client has an AHR, the AHR must sign the withdrawal request. The client may not withdraw the hearing request without first provid- ing the department with a written, signed notice stating they wish to revoke the AHR’s authorization to represent the client. The authori- zation to represent must be revoked by the client before the client signs the hearing request withdrawal.
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Withdrawals Requested In- Person at the Meaningful Prehearing Conference All Programs At any time during a meaningful prehearing conference the client or AHR may choose to withdraw his/her request for hearing. If the client has an AHR, the AHR must sign the withdrawal request. The client may not withdraw the hearing request without first providing the department with a written, signed and dated notice stating they wish to revoke the AHR’s authorization to represent the client. The authorization to represent must be revoked by the client before the client signs the hearing request withdrawal. When such a request is made, complete a DHS-18M, Hearing Request Withdrawal In- Person, form. The DHS-18M, Hearing Request Withdrawal In-Person, form is only used when the client or AHR attends the meaningful prehearing conference in-person and chooses to withdraw his/her request for hearing while at the local MDDHS office. This form should never be mailed or given to a client to mail back to MDHHS. Do not send the signed DHS-18M form to MOAHR. Once the form has been completed: • Provide a copy to the client and AHR. • Keep the original in the case record in the hearings packet. • Dispose of the request in Bridges. • Notify the hearings coordinator to dispose of the request on the hearings log. • Notify any MDHHS partners of the withdrawal and disposition. • Close out the request for hearing in this matter and take no further action.
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Withdrawals Not In-Person All Programs When the client or AHR requests a hearing request withdrawal form outside of the Meaningful Prehearing Conference setting, the DHS- 18A, Hearing Request Withdrawal, must be used. If the client has an AHR, the AHR must sign the withdrawal request. The client may not withdraw the hearing request without first providing the department with a written, signed and dated notice stating they wish to revoke the AHR’s authorization to represent the client. The authorization to represent must be revoked by the client before the client signs the hearing request withdrawal. DHS-18A, Hearing Request Withdrawal, forms received by MDHHS must be faxed to the Michigan Administrative Hearing System (MOAHR) for disposition at 517-763-0155. 1. Withdrawal requests received prior to submitting the DHS- 3050, Hearing Summary, and hearing packet to MOAHR, ID mail or send by US postal mail all the following to MOAHR: • DHS-1605, Notice of Case Action. • DHS-18, Request for Hearing (or equivalent). • Signed DHS-18A, Hearing Request Withdrawal. 2. Withdrawal requests received after submitting the DHS-3050, Hearing Summary, and hearing packet to MOAHR, ID mail send by US postal mail all of the following to MOAHR: • Signed DHS-18A, Hearing Request Withdrawal. • Copy of the DHS-3050, Hearing Summary, previously submitted. (A copy of the DHS-3050 will allow MOAHR to match the withdrawal with the correct request for hearing.) 3. Withdrawal requests received from client by telephone. Ask the caller to promptly mail or drop off a signed written request for withdrawal to the local office. The client may obtain and complete a DHS-18A at the local office or online at: www.michigan.gov/dhs-forms in the other category. When the request for withdrawal is received, mail a copy to MOAHR. File the original in the case record. If the withdrawal is received within seven business days of the scheduled hearing, fax the withdrawal to MOAHR.
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MOAHR will review the hearing request withdrawal and: • If approved, send an Order Dismissing Request for Hearing Pursuant to Withdrawal to all parties. • If denied, an administrative hearing will be scheduled. 4. Withdrawal requests received at the time of hearing. When a client comes to the local office for a hearing, and while at the local office, decides to withdraw the request, contact MOAHR to advise of the withdrawal request. The assigned ALJ must have an opportunity to discuss the withdrawal request with the client and AHR or review the signed withdrawal request that may be faxed. Do not send the client away until MOAHR has reviewed the withdrawal request and made a determination whether to grant or deny the request. If the withdrawal request is denied, the hearing will take place as scheduled while the client is present in the local office. 5. If a withdrawal fails to dispose of all issues (partial withdrawal), MOAHR may accept the DHS-18A on the identified program and a hearing will be conducted on unresolved issues. STATE SSI PAYMENT (SSP) SSPs are made for only those months the recipient received a regular monthly federal benefit. This is shown on State On-Line Query (SOLQ) as a recurring payment dated the first of the month. SSPs are not issued for retroactive or supplemental federal benefits. The client or AHR may request a hearing when the client receives a DHS-430, Benefit Reduction Notice, stating that the SSP is being reduced or terminated; see BEM 660, State SSI Payment. Handle these hearing requests in the same manner as all other benefit hearing requests. When a hearing request (usually a DHS-430) is received, do all the following: • Log the receipt of the hearing request on Bridges. A timely hearing request will delete the negative action and issue a warrant equal to the previous quarterly payment.
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Note: The cutoff date for entering the receipt of a timely hearing request for the State SSI payment program is the payroll run date for case digit ending in 9; see Reference Schedules Manual (RFS) 106. If a hearing request was received timely but was not entered on Bridges by this date, send a copy of the hearing request to the State SSI Payment Unit at SSI-Bridges-Coord@michigan.gov. The State SSI Payment Unit will issue a supplemental payment. • Prepare a DHS-3050, Hearing Summary. The hearing summary must include the information that the specialist views on materials obtained from SSA. Example SDX or SOLQ. • Do not include a SOLQ within the hearing packet. Contact the State SSI Payment Unit at SSI-Bridges-Coord@michigan.gov for assistance if the SOLQ fails to explain the action taken. • Represent the department at the hearing. • If the hearing decision reverses the action taken by the department, issue a supplemental payment. Prepare for the hearing under the guidance of the SSI Payments Unit staff, as needed. SSI Payments Unit staff will not participate in the hearing but are available for consultation regarding: • Preparation of the hearing summary, and • Presentation of the case at hearing. If the SSI Payments Unit determines the disputed case action should be reversed, it will take all actions required. Inform MOAHR of the reversal in writing. MOAHR will then dismiss the hearing request. EVIDENCE
Client Access to the Case Record All Programs Clients and AHRs have the right to review the case record and obtain copies of needed documents and materials relevant to the hearing. Send a copy of the DHS-3050 and all documents and records to be used by the department at the hearing to the client and AHR. DHS-4772, Hearing Summary Letter, may be used for this purpose.
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Exception #1: Do not disclose the identity of any person who has reported information relating to an alleged program violation. Exception #2: MDHHS cannot provide access to case records restricted by law or specific orders of a court; see BAM 310, Confidentiality and Public Access to Case Records. Exception #3: Access to certain mental health records is restricted; see BAM 310. Subpoenas All Programs Request a subpoena if the specialist, the client or AHR requires either of the following: • A person outside MDHHS to come to a hearing to testify. • A document from outside MDHHS to be offered as evidence at a hearing. Send a memo requesting the subpoena to MOAHR. Attach a copy of the notice of hearing, (or other indication of date, time and place of hearing) if available. Allow adequate time to mail or hand-deliver the subpoena. The memo must include all the following: • Name and address of the person whose testimony is required. • What document is to be subpoenaed. • Why the person's presence and/or the document is needed at the hearing. • How the person's testimony or the document relates to the hearing issue. The requester is responsible for serving the subpoena and must pay the attending witness $12 per day or $6 per half-day plus the state travel rate per mile from and to the person's residence in Michigan. MDHHS employees are expected to participate in hearings without a subpoena when their testimony is required; Employee Handbook, SUBPOENAS ISSUED IN ADMINISTRATIVE MATTERS. If the specialist, the client or AHR requests that a MDHHS employee (for example, from another county or central office)
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participate in the hearing and that participation cannot be arranged, send a memo to MOAHR giving all the following: • The name and location of the employee. • Why the employee's participation is needed. • How the employee's testimony relates to the hearing issue. MOAHR will decide whether to require the employee's participation. NOTICE OF HEARING If the case action involved actions taken by MDHHS partners fax or email a copy of the Notice of Hearing to the partner within 24 hours of receipt. THE HEARING All Programs A hearing will take place if the local office and the client or AHR have been unable to resolve the issue(s) which prompted the hearing request. MOAHR must give advance written notice of the time, date and place of the hearing. For FAP only, advance notice is specifically defined as the 10-day period preceding the date of the hearing. However, less advance notice may be requested to expedite the hearing. Clients have the right to all the following: • Representation by legal counsel or other person of choice at the client’s expense. • Barrier-free access to the hearing site. • Interpreters: see BAM 105, Rights and Responsibilities. • Child care and transportation costs as necessary to ensure that full participation in the hearing process is possible.
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Reimbursement for Transportation and Child Care All Programs Clients may request reimbursement of transportation and child care costs at the hearing. Clients must make the request on the hearing record and provide the ALJ the following information: • Their name and address. • For transportation expense reimbursement, the number of miles traveled round-trip for the hearing. • For child care expense reimbursement, the provider type (for example, child care center) and a signed and dated receipt from the provider showing the full names and ages of all children for whom care was provided. MOAHR will issue the reimbursements when the total combined cost exceeds $3. Note: Reimbursements are computed using the least costly travel rate. Telephone Hearings All Programs MOAHR schedules a telephone hearing for most cases. However, at the request of the client or AHR, MOAHR must schedule an in- person hearing. In exceptional circumstances the local office may request an in-person hearing by calling MOAHR and explaining the reason for the request. Telephone hearings are conducted from the assigned ALJ's office. Speaker phones are used to communicate with participants at the local office.
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Requests for In- Person Hearings All Programs The client or AHR may indicate in the hearing request the desire for an in-person hearing. The notice of hearing also instructs the client and AHR to call MOAHR to request an in-person hearing. In-person hearings are conducted in the local office that serves the client. Late Arrival for the Hearing All Programs Hearings will be held on the scheduled date if the client or AHR arrives within 15 minutes of the scheduled time. If the client or AHR arrives more than 15 minutes late, do not send the person away. Immediately call MOAHR for direction on how to proceed. Whenever possible, the hearing will be held on the scheduled date if MOAHR determines good cause exists for the late arrival. Failure to Appear for the Hearing All Programs Contact MOAHR if the client or AHR does not appear for the hearing within 15 minutes of the scheduled time. Do not take negative action until written authorization from MOAHR has been received. If the client or AHR later contacts MDHHS to have the hearing rescheduled, tell the person to do one of the following: • Write MOAHR at P.O. Box 30639, Lansing, MI, 48909-8139. • Call MOAHR at the toll-free number included on the notice of hearing. Persons at the Hearing All Programs An AHR may appear at the hearing with or without the client. Attendance of support person(s) is allowed, unless the ALJ
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determines that space limitations prohibit multiple persons in attendance. The local office that initiated the case action that leads to the hearing request must present the case. If the client moved to another county, the county where the client resides must host the client, however, the office that took the action must present the case. Interim Assistance Recovery State-funded FIP and SDA Only For Interim Assistance Recovery disputes, the local office IAR liaison must arrange for central office payment reconciliation staff to participate in the hearing by telephone. Presentation of the Case All Programs The local office and client or AHR will each present their position to the ALJ, who will determine whether the actions taken by the local office are correct according to fact, law, policy and procedure. In most cases, the client or AHR and local office staff will be together in the hearing room and will speak into a speaker telephone. The ALJ will be on the other end of the phone line. Following the opening statement(s), if any, the ALJ directs the MDHHS case presenter to explain the position of the local office. The hearing summary, or highlights of it, may be read into the record at this time. The hearing summary may be used as a guide in presenting the evidence, witnesses and exhibits that support the department's position. Always include the following in planning the case presentation: • An explanation of the action(s) taken. • A summary of the policy or laws used to determine that the action taken was correct. • Any clarifications by central office staff of the policy or laws used.
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• The facts which led to the conclusion that the policy is relevant to the disputed case action. • The MDHHS procedures ensuring that the client received adequate or timely notice of the proposed action and affording all other rights. Both the local office and the client or AHR must have adequate opportunity to present the case, bring witnesses, establish all pertinent facts, argue the case, refute any evidence, cross-examine adverse witnesses, and cross-examine the author of a document offered in evidence. Hearings Facilitator
All Programs The MDHHS case must be presented by a hearings facilitator or backup facilitator. A hearings facilitator and backup facilitator must be a person familiar with MDHHS programs, policies and systems and is designated to present all cases to the ALJ. The facilitator or backup facilitator must review the case prior to the administrative hearing for correct case action and reasonable fairness. Individuals in this position will present the department’s case and be able to knowledgeably and completely answer the ALJ’s program, policy and case-specific questions during the administrative hearing. Admission of Evidence All Programs The ALJ will follow the same evidentiary rules used in circuit court to the extent these rules are practical in the case being heard. The ALJ may admit and give probative effect to evidence of a type commonly relied on by reasonably prudent persons in the conduct of their affairs. The ALJ must ensure that the record is complete, and may do the following: • Attempt to ensure all necessary information is presented on the record.
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• Be more lenient than a circuit court judge in deciding what evidence may be presented. • Refuse to accept evidence that the ALJ believes is: Unduly repetitious. Immaterial. Irrelevant. Incompetent. Note: The ALJ may not act as an advocate for either party. Either party may: • State on the record its disagreement with the ALJ's decision to exclude evidence and the reason for the disagreement. • Object to evidence the party believes should not be part of the hearing record. When refusing to admit evidence, the ALJ must state on the record the nature of the evidence and why it was not admitted. The ALJ may allow written documents to be admitted in place of oral testi- mony if the ALJ decides this is fair to both sides in the case being heard. SDA and Medicaid Only When requested evidence is received, the ALJ will review the evidence for completeness and responsiveness and determine whether the evidence is material and relevant. The client is responsible for providing evidence to support his or her claim. If the client does not provide medical or other evidence the ALJ needs and requests, the ALJ will generally make a decision based on the evidence in record, including evidence the ALJ has obtained directly. To document that the ALJ has made an attempt to fully and fairly develop the record, the ALJ will document all attempts to obtain the evidence as an exhibit(s) in the record. HEARING DECISIONS All Programs The ALJ determines the facts based only on evidence introduced at the hearing, draws a conclusion of law, and determines whether
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MDHHS policy was appropriately applied. The ALJ issues a final decision unless: • The ALJ believes that the applicable law does not support MDHHS policy. • MDHHS policy is silent on the issue being considered. In that case, the ALJ recommends a decision, and the policy hearing authority makes the final decision. Exception: For MA client eligibility only, if a presiding ALJ believes an MA policy at issue in a given case does not conform with federal or state law, all of the following occur: • The ALJ issues a recommended decision within 20 days of the hearing date. • Copies of the decision are sent to the client, AHR, MDHHS policy hearing authority, MDHHS local office and chief executive officer (CEO) of MDHHS-MSA, all of whom may file exceptions with the ALJ. • The recommendation and exceptions are forwarded by the MDHHS Legal Affairs Administration to the MDHHS CEO through the Michigan Administrative Hearings System for the Department of Community Health. • The MDHHS CEO makes the final decision regarding all recommended decisions. • For Medicaid disability determinations, the ALJ will review the evidence for completeness and responsiveness and generally make a decision based on the evidence admitted into the record as to disability, including evidence the ALJ has obtained directly. MOAHR mails the final hearing decision to the client, the AHR and the local office. In most cases, the client has the right to appeal a final decision to circuit court within 30 days after that decision is received.
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Community Spouse Income Allowance MA Only The ALJ may raise the total allowance used to calculate the community spouse income allowance to an amount greater than provided for in BEM 546 to provide such additional income as is necessary due to exceptional circumstances resulting in significant financial duress. The fact that a community spouse's expenses for goods and ser- vices purchased for day-to-day living exceed the total allowance provided by policy does not constitute exceptional circumstance. Goods and services purchased for day-to-day living include: • Clothing. • Drugs. • Food. • Shelter (for example, mortgage, taxes, insurance, rent, mainte- nance). • Telephone. • Trash pickup. • Doctor's services. • Entertainment. • Heat. • Utilities. • Taxes. • Transportation (for example, car payments, insurance, mainte- nance, fuel, bus fare). Employment expenses do not constitute exceptional circumstances.
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An example of exceptional circumstances is the need for the com- munity spouse to pay for supportive and medical services at home to avoid being institutionalized. Significant financial duress does not exist if the community spouse could meet expenses using their assets. This includes assets pro- tected for the community spouse's needs as the protected spousal amount. The ALJ may also grant a greater protected spousal amount (BEM 402, Special MA Asset Rules) when necessary to raise the commu- nity spouse's income to the total allowance for the community spouse. The community spouse's income for this purpose includes the maximum amount the long-term care facility and/or hospital (L/H) client could make available to their community spouse per BEM 546. When the ALJ grants a greater amount in the above circumstances, the final decision specifies: • The amount of the protected spousal amount; see BEM 402, Special MA Asset Rules. • The total allowance in BEM 546, Post-Eligibility Patient-Pay Amounts, used for the community spouse when determining the community spouse income allowance. • The assets to be transferred for use by the community spouse. • When another hearing will be held to review the exceptional circumstances. If exceptional circumstances no longer exist before the case is due for the follow-up hearing, send the information to MOAHR. Be sure to include the register number of the last D&O. MOAHR will then decide whether to reschedule that hearing. Additional Low- Income Medicare Beneficiaries (ALMB) MA Only The ALJ cannot order prior months of ALMB eligibility when the prior month(s) is before January of the current calendar year.
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Example: A client applies in December 2004 and the specialist determines eligibility in January 2005. The MA begin date is January 2005. There is no eligibility for December 2004 because it is before January of the current year. Notifying Partners If a MDHHS partner was involved in the hearing, a copy of the hearing decision must be faxed, mailed, or emailed (use their preferred mode of communication) to the partner within 24 hours of receipt. Implementing the Hearing Decision All Programs All hearing decisions must be recorded in Bridges, on the Hearing Restore Benefits screen. Some hearing decisions require implementation by the local office. Implement a decision and order within 10 calendar days of the mail- ing date on the hearing decision. Do not provide a notice of case action. The hearing decision serves as notice of the action. If implementation requires a redetermination, send a notice of case action on the redetermination action. Implement the hearing decision pending a court appeal unless a circuit court or other court with jurisdiction issues an order requiring a stay. Note: Specialists will be notified by the Legal Affairs Administration if MDHHS is not to implement a hearing decision because of a court stay. If such an order is received from the client, AHR or a court, or if there are any questions, contact Legal Affairs Administration; see Administrative Policy, APL 410, Freedom of Information Act (FOIA). If unable to determine what action is required, contact the policy clarification mailbox. Policy staff will clarify the situation with the appropriate supervisory ALJ. If a hearing decision or a local office review results in Medicaid eligibility, send or give the client a DHS-334, Reimbursement Notice. This notice explains the procedure for a client to follow to request reimbursement of paid medical bills from the Michigan Department of Health and Human Services (MDHHS).
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Send a copy of the DHS-334, Reimbursement Notice, that was sent to the client to:
Michigan Department of Health and Human Services
Medical Services Administration
Eligibility Quality Assurance Section/Reimbursement
400 S. Pine St., 5th floor
Lansing, MI 48913 The following hearing decisions are not implemented by the local office: • Decisions about MSA determinations are implemented by MSA. • Decisions about Interim Assistance Recovery disputes are implemented by central office payments reconciliation staff. Note: See BEM 660 for instructions on implementing decisions about state SSI payments. Certifying Implementation of the Hearing Decision All Programs When a decision requires a case action different from the one origi- nally proposed, a DHS-1843, Administrative Hearing Order Certifi- cation, is sent with the hearing decision. Complete the necessary case actions within 10 calendar days of the mailing date noted on the hearing decision. Complete and mail the DHS-1843 to MOAHR to certify implementation and place a copy of the form in the case file. If it is impossible to implement the hearing decision as written within 10 calendar days, a local office manager or hearings coordinator should call MOAHR at 517-335-7519 and speak with the supervisor of the ALJ who issued the hearing decision. The supervisor will offer advice on how to proceed. A local office manager or hearings coordinator is responsible to follow-up to ensure implementation of the hearing decision is completed.
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REHEARING/ RECONSIDERATION All Programs A rehearing is a full hearing which is granted when either of the fol- lowing occur: • The original hearing record is inadequate for purposes of judicial review. • There is newly discovered evidence that existed at the time of the original hearing that could affect the outcome of the original hearing decision. A reconsideration is a paper review of the facts, law and any new evidence or legal arguments. It is granted when the original hearing record is adequate for purposes of judicial review and a rehearing is not necessary, but one of the parties believes the ALJ failed to accurately address all the relevant issues raised in the hearing request. Rehearing/ Reconsideration Requests All Programs The department, Office of the Attorney General, MDE, client or AHR may file a written request for rehearing/reconsideration. Request a rehearing/reconsideration when one of the following exists: • Newly discovered evidence that existed at the time of the original hearing that could affect the outcome of the original hearing decision. • Misapplication of manual policy or law in the hearing decision, which led to a wrong conclusion. • Typographical, mathematical or other obvious error in the hearing decision that affects the rights of the client. • Failure of the ALJ to address in the hearing decision relevant issues raised in the hearing request.
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The department, the Office of the Attorney General, the client or AHR must specify all reasons for the request. Local Office Requests A written request from the local office for a rehearing/reconsidera- tion must be sent to Economic Stability Administration (ESA) program policy in central office or to the Michigan Department of Lifelong Education, Advancement, and Potential/CDC Policy for a recommendation. The written request must include all the following: • A copy of the decision and order. • A copy of the hearing summary and all evidence presented at the hearing. • Explanation of why a rehearing/reconsideration is appropriate. Email to the appropriate policy email box, per BEM 100, Introduction. CDC Send requests to: Michigan Department of Lifelong Education, Advancement, and Potential Child Development and Care PO Box 30008 Lansing, MI 48909 Email Policy-CDC@michigan.gov. If the field program policy or CDC policy supports the local office request, the request shall be made a part of the record. The request will be sent to all parties including: MOAHR, the client, AHR, and the requesting local office. Office of the Attorney General Requests A written request made by the Office of the Attorney General must be mailed to MOAHR as follows: The written request must be addressed as follows: Michigan Administrative Hearings Reconsideration/Rehearing Request P.O. Box 30639
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Lansing, MI 48909-07322 The Office of the Attorney General will notify MDHHS field operations and the Legal Affairs Administration and provide a copy of the request to the client and AHR. Client or AHR Requests A written request for rehearing or reconsideration must be either faxed or mailed to MOAHR as follows: The written request must be faxed to 517-763-0155 and labeled as follows: Attention: MOAHR Rehearing/Reconsideration Request. If submitted by mail, the written request must be addressed as follows: Michigan Office of Administrative Hearings and Rules Reconsideration/Rehearing Request P.O. Box 30639 Lansing, MI 48909-07322 All Requests MOAHR will not review any response filed to any rehearing/reconsideration requests. A request must be received by MOAHR within 30 days of the date the hearing decision is mailed. Granting a Rehearing/ Reconsideration All Programs MOAHR will either grant or deny a rehearing/reconsideration request and will send written notice of the decision to all parties to the original hearing. Exception: MOAHR will not grant a rehearing involving FAP-IPV. If MOAHR grants a reconsideration, a reconsideration decision will be issued.
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If a rehearing is granted, MOAHR will schedule and conduct the hearing in the same manner as the original. Implementation Pending a Rehearing All Programs Pending a rehearing or reconsideration request, implement the original decision and order unless a circuit court or other court with jurisdiction issues an order which requires a delay or stay. Note: If such an order is received by the client, MOAHR, the court or the Legal Affairs Administration and Policy, or if there are questions about implementing the order, see Administrative Policy Manual Legal (APL) 403, How to Obtain Legal Services Lawsuits, Litigation, Legal Documents and Forms. LEGAL BASE All Programs MCL 400.9 MCL 400.37 MCL 24.271- 24.287 Mich Admin Code, R 400.901 et seq. 42 CFR 438.400-438.424. FIP 45 CFR 205.10
RCA 45 CFR 400.54 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
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SDA Current Annual Appropriations Act Mich Admin Code, R 400.3151 - 400.3180 MA 42 CFR 431.200-.250 42 USC 1396r-5 FAP 7 CFR 273.15
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SPOLICY All Programs When an individual/client, household, or provider receives benefits exceeding what they were eligible to receive, the Michigan Department of Health and Human Services (MDHHS) must attempt to recover the overpayment (OP). This item explains overpayment types, responsibilities, and timeframes. DEFINITIONS Benefit Recovery System (BRS) The system within the Bridges application that contains all established Family Independence Program (FIP), State Disability Assistance (SDA), Refugee Cash Assistance (RCA), Child Development and Care (CDC) and Food Assistance Program (FAP) overpayment claims. Benefit Withholding (BW) A process where some or all the benefits a recipient is otherwise eligible to receive are withheld and applied as a payment to an overpayment claim owed to the State of Michigan. Also known as Administrative Recoupment (AR). Discovery Date The date when an overpayment claim is known to exist, and the amount of the overpayment claim can be reasonably determined. For IPV overpayment claims the discovery date is determined by the individual's signed and dated disqualification agreement, an IPV hearing request, or prosecutorial referral. Establishment Date The date an overpayment claim is created in Bridges and cannot be prior to the discovery date. Overpayment The amount of benefits issued to the individual/client, household, or provider exceeding what the recipient(s) was/were eligible to
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receive. An overpayment is also the amount of benefits misused, trafficked, or attempted to be trafficked. Recoupment The identification, establishment, and recovery of benefit overpayments. OVERPAYMENT TYPES All Programs Types of overpayments include Agency Error (AE), Client Error (CE), Intentional Program Violation (IPV), and Provider Error. Agency Error A type of overpayment or underissuance resulting from an incorrect action or failure to take action by the state agency; see Bridges Administrative Manual (BAM) 705. Client Error A type of overpayment or underissuance resulting from inaccurate reporting on the part of the household; see BAM 715. Client Suspected IPV A type of overpayment resulting from suspected intentional inaccurate reporting on the part of the household. FIS/ES will refer client errors suspected of IPV to the Office of Inspector General (OIG). Intentional Program Violation IPV (BAM 720) consists of having intentionally: • Made a false or misleading statement, or misrepresented, concealed, or withheld facts; or • Committed any act that constitutes a violation of FAP, Supplemental Nutrition Assistance Program (SNAP) regulations, or any federal or state law, involving the use, presentation, transfer, acquisition, receipt, possession, theft, trafficking or sale of items purchased with FAP benefits or Electronic Benefits Transfer (EBT) cards.
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Provider Error A type of overpayment claim resulting from a client receiving more benefits than they were eligible to receive because the client/CDC provider gave incorrect or incomplete information or failed to notify the department of required information, believed to be unintentional; see BAM 715. CDC Provider Suspected IPV Suspected provider IPV is an overpayment caused by a provider's intentional act to receive higher reimbursements than they were entitled to. See Bridges Eligibility Manual (BEM) 707 for information on provider IPVs. If care was authorized, provided, and paid for but the client was ineligible, this would be considered a CDC client error or agency error. Multiple Overpayment Types An overpayment may involve more than one overpayment type. If an agency error and client error occur in the same OP period, process as an agency error. If an overpayment involves suspected IPV along with another overpayment type, an overpayment referral should be routed to OIG by completing an Overpayment Referral in Bridges and ensuring Yes is checked for Suspected IPV. Prudent judgement should be used in evaluating an overpayment for suspected IPV; see BAM 720 for IPV referral criterial. CDC Only If agency error and another error occurred, calculate which error resulted in the largest overpayment and establish the overpayment claim using that error type. If provider error and CDC individual/client error or CDC individual/client IPV occurred and care was authorized by MDHHS and paid by the Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP) to the provider, but care was not provided, recover from the provider.
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MINIMIZATION OF OVERPAYMENTS All Programs MDHHS must minimize potential overpayments by following BAM 105 requirements and by informing the individual/client or authorized representative (AR) of the following: • Applicants and recipients are required by law to give complete and accurate information about their circumstances. Incorrect, late reported, or omitted information can result in benefit repayment or reduction. • Applicants and recipients are required by law to promptly notify MDHHS of all changes in circumstances within 10 days (or other timeframe specified in policy) that potentially affects eligibility or benefit amount. • Applicants can file a timely hearing request, because of a negative action, to suspend a proposed benefit reduction and have their former level benefits reinstated. Reinstated benefits may be recovered in certain instances; see BAM 600. MDHHS will minimize potential overpayments by referring questionable information to the OIG Front End Eligibility (FEE) agent for investigation via link: FEE Referral Form. DISCOVERY OF POTENTIAL OVERPAYMENTS All Programs A potential overpayment might be discovered through normal casework or by one of the following but not limited to: • Case readings. • Computer cross matches. • FAP Quality Control (QC) audit findings. • Federal CDC audit findings. • Welfare Fraud referrals. • Non-honored repay agreements. • Michigan Office of Administrative Hearings and Rules (MOAHR).
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FAP Only If discovered that a FAP household is receiving FAP and Indian Tribal Food Distribution benefits in the same month, a FAP OP exists only if the household received Indian Tribal Food Distribution benefits prior to its FAP application; see BEM 222. CDC Only An individual/client or CDC provider may voluntarily repay any program benefits even when there is no overpayment. Refer these situations to the CDC office within MiLEAP: 1-866-990-3227. OVERPAYMENT THRESHOLD FIP, SDA, RCA, CDC and FAP Agency and client errors are not pursued if the OP amount is equal to or less than $250 per program. Threshold limits: • Above $250 effective December 1, 2012 - current. • Above $125 effective August 1, 2008 - November 30, 2012. • Above $500 effective September 1, 2003 - July 31, 2008. • Above $1000 effective August 31, 2003, and prior. Exception: There is no threshold limit on FAP QC or IPV benefit overpayments. Exception: There is no threshold limit on CDC provider system errors. MiLEAP will recover these types of overpayments. Example: If payroll checks or electronic funds transfer (EFT) for the CDC provider was issued twice, the full amount would be recovered. OVERPAYMENT PROCESSING All Programs ES/FIS Actions When a potential overpayment is suspected, the following actions must be taken:
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• Immediately correct the current benefits if necessary following the change processing requirements in BAM 220. • Do not enter historical information relating to the potential overpayment within the Bridges case. • Complete an Overpayment Referral in Bridges within 60 days. Ensure the following: Select the appropriate overpayment type; agency error (AE) or client error (CE). For all CE overpayments, evaluate the potential overpayment for a suspected IPV; see BAM 720 for IPV criteria. If IPV is suspected, ensure Yes is checked for Suspected IPV. Ensure all relevant evidence is attached to the overpayment referral. Exception: FAP QC and federal CDC potentially discovered overpayments must be referred within seven days of receipt of the FAP QC and CDC audit findings. FIP, RCA and FAP Do not refer a potential overpayment if at the time it occurred the group did not include an eligible or disqualified adult. Medicaid (MA) Only Do not pursue overpayment of agency errors. Refer suspected IPV errors to OIG; see BAM 710. CDC Only For individuals/clients processed under CDC Expedited Service, BAM 118, benefits issued for child care services provided during the presumptive eligibility period will not be considered an overpayment, regardless of whether the ongoing eligibility determination is approved or denied.
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Direct Support Services (DSS), Employment Support Services (ESS) and Family Support Services (FSS) Initiate a referral to OIG when a suspected IPV results in an overpayment of MDHHS-authorized DSS, including FSS and ESS of $500 or more; see BEM 232. State Emergency Relief (SER) Refer SER overpayments to OIG when IPV overpayment exists and the total overpayment amount exceeds $500 across all programs. See Emergency Relief Manual (ERM) 306 and ERM 404 for SER. OEA Actions An OEA will establish an overpayment before the last day of the quarter following the quarter in which the overpayment was discovered. The discovery date may be prior or equal to the establishment date. Example: If an OEA discovers an overpayment on February 6th (1st quarter), the overpayment claim must be established by June 30th (2nd quarter). Example: If an OEA discovers an overpayment on June 28th (2nd quarter), the overpayment claim must be established by September 30th (3rd quarter). Note: An OEA must establish overpayment claims even if they cannot be established within the timeframe outlined above per 7 CFR 273.18(d)(3). For discovering an overpayment, an OEA will: • Determine if an overpayment actually occurred. • Determine the overpayment type. • Determine the overpayment period. • Obtain all additional evidence needed. • Calculate the amount. • Establish overpayment(s) for program(s) on BRS. • Send a DHS-4358-A, -B, -C & -D, Notice of Overissuance, to the client. FAP QC potentially discovered overpayments must be processed as a priority (within 90 days of receipt) because the existence of a potential overpayment has already been verified.
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Disaster Relief Program (DRP) and Disaster Food Assistance Program (DFAP) DHS-4701, Overpayment Referrals, must be processed as a priority (within 30 days of receipt); see BEM 800. OEAs use policy in effect at the time the overpayment occurred. If after reviewing a client error, it is determined that an IPV is suspected, do not establish a client error in Bridges. Instead, send an overpayment referral to OIG by emailing MDHHS-OIG-IPV- Referral@michigan.gov. OIG Referral Prudent judgment should be used in evaluating an overpayment for suspected IPV; see BAM 720 for referral criteria. IPV is suspected when an overpayment exists for which all three of the following conditions exist: • The individual/client failed to report information or gave incomplete or inaccurate information needed to make a correct benefit determination, and • The individual/client was clearly and correctly instructed regarding their reporting responsibilities, and • The individual/client has no apparent physical or mental impairment that limits their understanding or ability to fulfill their reporting responsibilities. Refer all individual/client and CDC provider errors that meet the referral criteria for suspected IPV to OIG. Refer to OIG via an Overpayment Referral in Bridges, ensure Yes is checked for Suspected IPV to route the referral to OIG. FIP, RCA, and FAP Do not refer a potential overpayment if at the time it occurred the group did not include an eligible or disqualified adult. MA, SER and DSS ES/FIS refer these programs directly to OIG when IPV is suspected. Suspected IPV overpayments are referred to OIG via an Overpayment Referral in Bridges, ensure Yes is checked for Suspected IPV to route the referral to OIG. • Evidence for the suspected IPV must be attached.
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• Provide calculation of the amount and OP period. These overpayments are not tracked on BRS. OIG will inform the Collections Unit when an accounts receivable needs to be established. WELFARE FRAUD REFERRAL The public can contact their local MDHHS office to report suspected welfare fraud or submit a Welfare Fraud Complaint form online. Responsibility Local Office Actions • Receive a call. • Enter into online fraud database. • Complete file clearance. • Forward to fraud coordinator. Central Office Actions • Access and review fraud referrals submitted online by the public via the database. • Complete file clearance to determine affected county. • Forward referral electronically to the designated fraud coordinator in local office. RESOURCES FIP Personal Responsibility and Work Opportunity Reconciliation Act of 1996., P. L. 104-193 of 1996, as amended 1939 PA 280 as amended (Social Welfare Act) MCL 400.1 et seq MCL 400.60 Mich Admin Code, R 400.3129 - 400.3131 MA 42 CFR 431.230(b) MCL 400.60
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FAP 7 CFR 271.2 7 CFR 272.8 7 CFR 273.18 7 USC 2022 Mich Admin Code, R 400.3011 SDA Annual Appropriations Act Mich Admin Code, R 400.3011 RCA 42 CFR 400.49 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
CONTACT Policy-Recoupment@michigan.gov - Overpayment Policy MDHHS-OIG-OEA-Policy@michigan.gov - OIG OEA Policy.
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POLICY All Programs If a household receives benefits, and the department makes an error, the adult(s) in the household must repay the extra benefits they are not eligible for. The benefits must be repaid even if there was no fraud. This item explains agency error (AE) processing and establishment. DEFINITION Agency Error A type of overpayment (OP) or underissuance resulting from an incorrect action or failure to take action by the state agency. Examples include, but not limited to: • Available information was not used or used incorrectly. • Policy was misapplied. • Action by local office or central office staff was delayed. • Computer/system error occurred. • Information was not shared between department divisions, for example, services staff. • Data match reports were not timely acted on (Wage Match, New Hire, BENDEX, etc.). Note: If unable to identify the type of overpayment, process as an agency error. Child Development and Care (CDC) Only There could be agency errors for providers and/or clients/individuals. The following are some typical agency errors. Use this non-all-encompassing list to help determine who is held responsible for the repayment of the overpayment. Agency Errors Related to the Provider • Provider not eligible. • Payments authorized under wrong provider eligibility type.
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Agency Errors Related to the Client/Individual • Family Contribution is wrong. • Child not eligible. • Child birthdate is incorrect, causing a higher agency maximum rate. AGENCY ERROR PROGRAM EXCEPTIONS Family Independence Program (FIP), State Disability Assistance (SDA), Refugee Cash Assistance (RCA), and Food Assistance Program (FAP) Recover a system generated supplement when incorrectly issued by Bridges and the supplement amount is above the overpayment threshold. Example: Client/individual was issued FAP benefits in the amount of $930 on 05-03-2023. The case was updated, eligibility ran and certified on 03-12-2024. Bridges incorrectly recertified the 05-2023 FAP EDG issuing the client/individual a supplement in the amount of $930. Establish an overpayment claim for the system generated supplement of $930. FIP, SDA, and RCA Only Treat an overpayment due to excess assets as an agency error unless caused by intentional program violation (IPV). Prudent judgement should be used in evaluating an overpayment for suspected IPV; see Bridges Administrative Manual (BAM) 700 and BAM 720 for referral criteria. FIP Only Do not recover children's clothing allowance funds that were issued due to an incorrect FIP eligibility determination; see BAM 405. FAP Only Do not recover overpayments caused by the following agency errors: • The group was certified in the wrong county. • The local office failed to have the FAP group sign the application form.
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Simplified Reporting (SR) does not affect the determination of agency error overpayments; see BAM 200. The overpayment claims calculation cannot include the 15 percent benefit increase issued during the months of January 2021 through June 2021 per the Consolidated Appropriations Act of 2021. The overpayment claims calculation cannot include the 15 percent benefit increase issued during the months of July 2021 through September 2021 per the American Rescue Plan Act of 2021. Do not recover replacement benefits; see BAM 502. Medicaid (MA) and Employment Support Services (ESS) Overpayment of agency errors is not pursued. State Emergency Relief (SER) For SER follow Emergency Relief Manual (ERM) 306 and ERM 404 for benefit recovery. CDC Only For clients/individuals processed under CDC Expedited Service, BAM 118, benefits issued for childcare services provided during the presumptive eligibility period will not be considered an overpayment, regardless of whether the ongoing eligibility determination is approved or denied. OVERPAYMENT PERIOD FIP, SDA, RCA, CDC and FAP The overpayment (OP) period for agency errors can be for no more than the latest 12 months. Example: A potential agency error was assigned to an Overpayment Establishment Analyst (OEA) for the period of March 2019 through December 2020. The latest 12 months an OEA can look at to discover an overpayment is January 2020 through December 2020. This 12 month or less period cannot include any months that occurred more than six years before the overpayment discovery date per 7 CFR 273.18(c)(1)(i).
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Example: A potential agency error was assigned to an OEA for the period of January 2015 through July 2016. The OEA discovers an overpayment in February 2022 for the months of March 2016 through July 2016. The OEA only pursued the latest five months because the months of January 2015 through February 2016 occurred more than six years before the discovered overpayment. To determine the first month (or first pay period for CDC) of the overpayment period, allow time for: • The client/individual reporting period per BAM 105 and • The full standard of promptness (SOP) for change processing per BAM 220 and • The full negative action suspense period per BAM 220. Exception: When an agency error occurs at application, redetermination, semi-annual, or mid-certification, allow the SOP for change processing per BAM 220 and the full negative action suspense period per BAM 220 when determining the first month (or first pay period for CDC) of the overpayment. The client/individual already reported their information on these forms per BAM 105. Example: Client/individual applies for FAP and FIP on 08-29-2023 for a group size of three. Head of household (HOH) reports Supplemental Security Income (SSI) income of $800, $400 rent, and heat and utility expenses. Department failed to budget the SSI income. First month of the overpayment period for FAP is determined as follows: • HOH reporting period is date of application - 08-29-2023. • Ten days for change processing - 09-08-2023. • Twelve-day negative action suspense period - 09-20-2023. • First month of OP is 10-2023. Using the example above, the first month of the overpayment period for FIP is determined as follows: • HOH reporting period is date of application - 08-29-2023. • Fifteen workdays for change processing - 09-20-2023 (09-04- 2023 was the state observed holiday of Labor Day). • Twelve-day negative action suspense period - 10-02-2023. • First month of OP is 11-2023.
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The overpayment period ends the month (or pay period for CDC) before the benefit is corrected or month of program closure. OVERPAYMENT AMOUNT FIP, SDA, RCA, CDC and FAP The amount of benefits issued to the client/individual, household, or provider in excess of what the recipient(s) was/were eligible to receive. FAP Only If the agency error involves two or more FAP groups which should have received benefits as one group, determine the error amount by the following: • Add together all the benefits received by each group, and • Subtract the correct benefits for the one combined group. OVERPAYMENT CALCULATION
Benefits Received FIP, SDA, RCA, and CDC The amount of benefits received in an overpayment calculation include: • Regular warrants. • Supplemental warrants (use for the month for which it was intended). • Duplicate warrants. • Vendor payments. • Benefit Withholding (BW) deductions. • Electronic Benefit Transfer (EBT) cash issuances. • Electronic Funds Transfer (EFT) payments.
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• Replacement warrants (use for the month of the original warrant). Do not include: • Warrants that have not been cashed. • Escheated EBT cash benefits. Warrant history is obtained from Bridges under Benefit Issuance. FAP Only The amount of FAP benefits received in the calculation is the gross (before benefit withholding deductions) amount issued for the benefit month. FAP issuance history is obtained from Bridges under Benefit Issuance. If the FAP budgetable income included FIP/SDA/RCA benefits, use the grant amount actually received in the overpayment month, even when the FIP/SDA/RCA benefit is being recovered. A supplement is counted in the month for which it was intended. Determining Budgetable Income FIP, SDA, RCA, CDC and FAP If improper budgeting of income caused the overpayment, use actual income for that income source and convert to a standard monthly amount; see Bridges Eligibility Manual (BEM) 505. Any income properly budgeted remains the same in the corrected budget month(s). This income was already converted within Bridges to a standard monthly amount. Example: Mandatory program group members Joseph and Michelle both started working. Only Joseph's income was budgeted. For the corrected calculation, use actual income for Michelle and the projected income already budgeted correctly for Joseph. Note: When verifying actual income, if an employer does not respond to or cannot provide the information or incompletely fills out the verification form, use the IG-011, Employee Wage History by Recipient ID, report as the best available information of income; see BAM 130 and BEM 505. Income is not converted from a wage
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match or IG-011, Employee Wage History by Recipient ID, report. This is quarterly income and can be divided by three (or less based on available information) to a standard monthly amount.
OVERPAYMENT ADJUSTMENTS
Assigned Support FIP Only Subtract from the overpayment all or part of any net assigned current support collections (not arrears) retained by the state as follows: • If the group was ineligible for FIP during the overpayment period, subtract the net current support collections retained. • If the group was eligible for part of the FIP benefits issued, subtract the portion of the net current support collections retained in excess of what the group was eligible for. Overpayment Adjustment Examples
Overpayment exists: $400 Monthly FIP benefit received by the group. - $300 Monthly FIP benefit group should have received. $100 One month OP. Reducing the overpayment when paid support exceeds the FIP benefit: $375 Child support paid per Consolidated Inquiry (CI). - $50 Child support rebate sent to group. $325 Difference in child support. - $300 Actual monthly FIP benefit group was eligible for. $25 This amount is subtracted to reduce the OP amount from $100 to $75.
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Do not reduce the overpayment when paid support does not exceed the FIP benefit: $300 Child support paid per CI. - $50 Child support rebate sent to group. $250 Difference in child support. - $300 Actual monthly FIP benefit group was eligible for. 0 Do not subtract anything from the overpayment amount; FIP benefit exceeds the difference in child support. Exception: For overpayment months prior to October 2011, subtract $50 from the reported amount before performing the calculations above. CLIENT/INDIVIDUAL NOTIFICATION FIP, SDA, RCA, CDC and FAP Unless recovering from the CDC provider, Bridges will notify the household of an agency error by sending the following: • DHS-4358-A, Notice of Overissuance. • DHS-4358-B, Overissuance Summary. • DHS-4358-C, Department and Client Error Information and Repayment Agreement. • DHS-4358-D, Hearing Request for Overissuance or Recoupment Action. An explanation of the reason for overpayment, along with the man- ual items, must be filled in on the DHS-4358-A, Notice of Overissuance. This is done under Correspondence, View Pending in Bridges. CDC Provider Only The provider is not notified of an overpayment by an OEA. The CDC office in the Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP) will notify the provider and
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initiate repayment. Send a copy of the issuance summary by ID- mail to:
MiLEAP
Child Development and Care
105 W. Allegan St. - 2nd Floor
PO Box 30267
Lansing, MI 48909
Attention: CDC Overpayment INITIATE REPAYMENT FIP, SDA, RCA, CDC and FAP Bridges automatically starts the repayment process once an overpayment claim has been established. The client/individual is instructed to return the DHS-4358-C, Department and Client Error Information and Repayment Agreement, to the Collections Unit. If the signed repay is returned to an OEA, they must enter it in Bridges under Benefit Recovery, Record Repayment Agreement. The OEA must place the signed repayment agreement in the OI (Overissuance) tab of the Electronic Case File (ECF). HEARING REQUESTED FIP, SDA, RCA, CDC and FAP A DHS-4358-D, Hearing Request for Overissuance or Recoupment Action, must be forwarded to the Michigan Office of Administrative Hearings and Rules (MOAHR) along with a completed DHS-3050, Hearing Summary, and exhibits in accordance with BAM 600. Update the overpayment claim status field under Benefit Recovery, Claim Adjustment to Pending Administrative Hearing from the drop- down. Note: If a client/individual withdraws the hearing request or fails to show and the hearing is not rescheduled, update the overpayment claim status field under Benefit Recovery, Claim Adjustment to Standard Recoupment from the drop-down. If Michigan Department of Health and Human Services (MDHHS) is upheld: • Update the overpayment claim status field back to Standard Recoupment from the drop-down.
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• Enter the date of the hearing decision under Benefit Recovery, Claim Adjustment, Agreement Sign Date. • Send a Collection Notice to the client/individual as renotification of the overpayment claim. • If warranted, update the Delinquency Date under Benefit Recovery, Claim Adjustment 31 days after the Collection Notice is sent. This is currently a manual process. If MDHHS is not upheld: • Act in accordance with the decision and order. • Decrease the balance under Benefit Recovery, Claim Adjustment with Hearing Decision as the reason from the drop- down. RESOURCES FIP Personal Responsibility and Work Opportunity Reconciliation Act of 1996, P.L. 104-193 of 1996, as amended 1939 PA 280, as amended (Social Welfare Act) MCL 400.1 et seq. MCL 400.60 Mich Admin Code, R 400.3129 - 400.3131 FAP 7 CFR 273.18 7 USC 2022 Mich Admin Code, R 400.3011 Consolidated Appropriations Act, 2021, P.L. 116-260 American Rescue Plan Act of 2021, P.L. 117-2 SDA Annual Appropriations Act Mich Admin Code, R 400.3151 - 400.3180 RCA 42 CFR 400.49
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CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186) 45 CFR Parts 98 and 99 Social Security Act, as amended 2016
CONTACT Policy-Recoupment@michigan.gov - Overpayment Policy. MDHHS-OIG-OEA-Policy@michigan.gov - OIG OEA Policy.
BAM 710 1 of 2 MA OVERPAYMENTS BPB 2026-009 4-1-2026
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DEPARTMENTAL POLICY MA Only Local office staff initiate a referral to the Office of Inspector General (OIG) when an overpayment (OP) appears to result from a suspected intentional program violation (IPV) by an individual eligible soley for Medicaid; see Bridges Administrative Manual (BAM) 700. Proceed as follows: • Determine the overpayment period and amount. • Evaluate the potential overpayment for suspected IPV; see BAM 720 for IPV criteria. If the potential overpayment meets IPV criteria an Overpayment Referral must be completed in Bridges, ensure Yes is checked for Suspected IPV to route the referral to OIG. Exception: Do not recoup OPs resulting from hearing decisions upholding MDHHS regarding the level of long-term care. PROCEDURES Document decisions and actions in case comments. A manager must review the case record. MA Payment Information Requests for MA payment information must be done by OIG. If an IPV is suspected contact OIG to request MA payment information. Overpayment Determination When the amount of MA payments is received, determine the OP amount. For an OP due to unreported income or a change affecting need allowances: • If there would have been a deductible or larger deductible, the OP amount is the correct deductible (minus any amount already met) or the amount of MA payments, whichever is less.
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• If there would have been a larger LTC, hospital or post- eligibility patient-pay amount, the OP amount is the difference between the correct and incorrect patient-pay amounts or the amount of MA payments, whichever is less. For an OP due to any other reason, the OP amount is the amount of MA payments. OIG Referral The minimum OP amount for OIG referral is $500 unless the local prosecutor sets a lower amount. OIG through regular channels informs affected local offices of lower amounts. Refer an IPV that falls below the established minimum if the group's actions are repetitious, flagrant, or if there is a previous IPV. The referral must be approved by the local office director or designee. Recoupment Before recoupment is initiated, a manager or a designee must review the MA case. After review, notify the client (or legal guardian) in writing that: • MDHHS must seek recoupment, but • Refusal to repay will not cause denial of current or future MA if the client is otherwise eligible. If recoupment is agreed to, complete a DHS-4358B, Recoupment Agreement, have the client/guardian sign it, then forward the original to the local office for collection. If he/she refuses to sign it, inform the local office in writing. A delinquent OP balance can be referred to Treasury for collection if: • The client signed a DHS-4358B, or • Recoupment is court ordered. LEGAL BASE MA 42 CFR 431.230(b) MCL 400.60
BAM 715 1 of 11 CLIENT/CDC PROVIDER ERROR OVERPAYMENTS BPB 2026-009 4-1-2026
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POLICY All Programs If a household receives benefits they are not eligible for, the adult(s) in the household must repay the extra benefits. The benefits must be repaid even if there was no fraud. This item explains client error (CE) processing and establishment. DEFINITIONS Client Error A type of overpayment (OP) or underissuance resulting from inaccurate reporting on the part of the household. Provider Error A type of overpayment claim resulting from an individual/client receiving more benefits than they were eligible to receive because the individual/client/Child Development & Care (CDC) provider gave incorrect or incomplete information or failed to notify the department of required information, believed to be unintentional. CLIENT ERROR PROGRAM EXCEPTIONS State Disability Assistance (SDA) Only A client error exists when the individual/client fails to honor an SDA repayment agreement after receiving a potential resource. Do not pursue an intentional program violation (IPV); see Bridges Eligibility Manual (BEM) 272. Note: Supplemental Security Income (SSI) benefit recovery is initiated by the Government Benefits and Chargeback unit in central office. If the individual/client contacts the local office to arrange repayment, issue individual/client the DHS-4358-A, -B, -C and -D, Notice of Overissuance. Have the individual/client sign form DHS- 4358-C, Department and Client Error Information and Repayment Agreement. Do not enter these debts on Bridges unless the individual/client signs the DHS-4358-C. Notify the local Interim Assistance Reimbursement (IAR) liaison in the local office if the individual/client signs a DHS-4358-C. The IAR liaison will contact the Government Benefits and Chargeback unit; see BEM 272.
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Family Independence Program (FIP) Only Do not recover children's clothing allowance funds that were issued due to an incorrect FIP eligibility determination; see Bridges Administrative Manual (BAM) 405. Food Assistance Program (FAP) Only The overpayment claims calculation cannot include the 15 percent benefit increase issued during the months of January 2021 through June 2021 per the Consolidated Appropriations Act of 2021. The overpayment claims calculation cannot include the 15 percent benefit increase issued during the months of July 2021 through September 2021 per the American Rescue Plan Act of 2021. Do not recover replacement benefits; see BAM 502. State Emergency Relief (SER) and Direct Support Services (DSS) For SER follow Emergency Relief Manual (ERM) 306 and ERM 404 for benefit recovery. For DSS follow BEM 232. CDC Only For individuals/clients processed under CDC Expedited Service, BAM 118, benefits issued for child care services provided during the presumptive eligibility period will not be considered an overpayment, regardless of whether the ongoing eligibility determination is approved or denied. CDC Providers Only All overpayments established in the local office for CDC providers are sent by ID mail to: Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP) Child Development and Care 105 W. Allegan St. - 2nd Floor PO Box 30267 Lansing, MI 48909 Attention: CDC Overpayment
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OVERPAYMENT PERIOD FIP, SDA, Refugee Cash Assistance (RCA), CDC, and FAP The overpayment period for client errors can be for no more than 72 months prior to the date of discovery. This 72 month or less period cannot include months that occurred more than six years before the overpayment discovery date per 7 CFR 273.18(c)(1)(i). Example: A potential client error was assigned to an Overpayment Establishment Analyst (OEA) for the period of January 2015 through December 2018. The OEA discovers an overpayment in February 2022 for the months of March 2016 through May 2018. The OEA started the overpayment period for March 2016 because the months of January 2015 through February 2016 occurred more than six years before the discovered overpayment. To determine the first month (or first pay period for CDC) of the overpayment period, allow time for: • The individual/client reporting period per BAM 105 and • The full standard of promptness (SOP) for change processing per BAM 220 and • The full negative action suspense period per BAM 220. Exception: When a client error occurs at application, the first month (or first pay period for CDC) is the application month. When a client error occurs at redetermination, semi-annual, or mid- certification, the first month (or first pay period for CDC) is the month affected by the processed redetermination, semi-annual, or mid-certification. The overpayment period ends the month (or pay period for CDC) before the benefit is corrected or month of program closure.
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Simplified Reporting FAP Only The first month of overpayment is two months after the actual monthly household income exceeded the simplified reporting (SR) limit; see BAM 200. Example: The group’s gross income for April exceeded the SR limit. The group should have reported this by May 10th but did not. June is the first month of the overpayment. However, using the example above, if the group's gross income falls below the SR limit any time after April and May and does not exceed the SR limit again during the certification period, overpayment establishment is not necessary. If it does exceed the SR limit again during the certification period and the individual/client does not report, all months that exceeded the SR limit after April and May would be processed as a potential overpayment. Example: Within the certification period of July through June, Bert started a job and called his specialist to report the hours and wages. Bert is put in SR in February and was sent a letter stating his SR income limit. After a week he gets an increase in hours which puts him over the limit for February. He does not report by March 10th. In April the hours were reduced putting him under the SR income limit. In May Bert is promoted and goes over the SR income limit and again does not report by June 10th. The last week of June he is demoted but still over the SR income limit. Bert’s overpayment period would be May and June. OVERPAYMENT AMOUNT FIP, SDA, RCA, CDC and FAP The amount of benefits issued to the individual/client, household, or provider in excess of what the recipient(s) was/were eligible to receive. FAP Only If the client error involves two or more FAP groups which should have received benefits as one group, determine the error amount by the following:
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• Add together all the benefits received by each group, and • Subtract the correct benefits for the one combined group. OVERPAYMENT CALCULATION
Benefits Received FIP, SDA, RCA, and CDC The amount of benefits received in an overpayment calculation includes: • Regular warrants. • Supplemental warrants (use for the month for which it was intended). • Duplicate warrants. • Vendor payments. • Benefit Withholding (BW) deductions. • Electronic Benefit Transfer (EBT) cash issuances. • Electronic Funds Transfer (EFT) payments. • Replacement warrants (use for the month of the original warrant). Do not include: • Warrants that have not been cashed. • Escheated EBT cash benefits. Warrant history is obtained from Bridges under Benefit Issuance. FAP Only The amount of FAP benefits received in the calculation is the gross (before benefit withholding deductions) amount issued for the benefit month. FAP issuance history is obtained from Bridges under Benefit Issuance.
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If the FAP budgetable income included FIP/SDA/RCA benefits, use the grant amount actually received in the overpayment month, even when the FIP/SDA/RCA benefit is being recovered. A supplement is counted in the month for which it was intended. Determining Budgetable Income FIP, SDA, RCA, CDC and FAP If improper reporting of income caused the overpayment, use actual income for that income source and convert to a standard monthly amount; see BEM 505. Any income properly budgeted remains the same in the corrected budget month(s). This income was already converted within Bridges to a standard monthly amount. Example: Mandatory program group members Joseph and Michelle both started working. Only Joseph's income was reported. For the corrected calculation, use actual income for Michelle and the projected income already budgeted correctly for Joseph. Note: When verifying actual income, if an employer does not respond to or cannot provide the information or incompletely fills out the verification form, use the IG-011, Employee Wage History by Recipient ID, report as the best available information of income; see BAM 130 and BEM 505. Income is not converted from a wage match or IG-011, Employee Wage History by Recipient ID, report. This is quarterly income and can be divided by three (or less based on available information) to a standard monthly amount. FAP Only For client error overpayments, do not allow the 20 percent earned income deduction on unreported earnings. Example: If a household reports monthly earned income of $500 when it actually received $800, do not apply the earned income deduction to the difference of $300 in unreported earnings. OVERPAYMENT ADJUSTMENTS
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Assigned Support FIP Only Subtract from the overpayment all or part of any net assigned current support collections (not arrears) retained by the state as follows: • If the group was ineligible for FIP during the overpayment period, subtract the net current support collections retained. • If the group was eligible for part of the FIP benefits issued, subtract the portion of the net current support collections retained in excess of what the group was eligible for. Overpayment Adjustment Examples Overpayment exists: $400 Monthly FIP benefit received by the group. - $300 Monthly FIP benefit group should have received. $100 One month OP. Reducing the overpayment when paid support exceeds the FIP benefit: $375 Child support paid per Consolidated Inquiry (CI). - $50 Child support rebate sent to group. $325 Difference in child support. - $300 Actual monthly FIP benefit group was eligible for. $25 This amount is subtracted to reduce the OP amount from $100 to $75. Do not reduce the overpayment when paid support does not exceed the FIP benefit: $300 Child support paid per CI. - $50 Child support rebate sent to group.
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Exception: For overpayment months prior to October 2011, subtract $50 from the reported amount before performing the calculations above. INDIVIDUAL/CLIENT NOTIFICATION FIP, SDA, RCA, CDC and FAP Unless recovering from the CDC provider, Bridges will notify the group of a client error by sending the following: • DHS-4358-A, Notice of Overissuance. • DHS-4358-B, Overissuance Summary. • DHS-4358-C, Department and Client Error Information and Repayment Agreement. • DHS-4358-D, Hearing Request for Overissuance or Recoupment Action. An explanation of the reason for overpayment, along with the manual items, must be filled in on the DHS-4358-A, Notice of Overissuance. This is done under Correspondence, View Pending in Bridges. CDC Provider Only The provider is not notified of an overpayment by an OEA. The CDC office in MiLEAP will notify the provider and initiate repayment. Send a copy of the issuance summary by ID-mail to: MiLEAP Child Development and Care 105 W. Allegan St. - 2nd Floor PO Box 30267 Lansing, MI 48909 Attention: CDC Overpayment $250 Difference in child support. - $300 Actual monthly FIP benefit group was eligible for. 0 Do not subtract anything from the OP amount, FIP benefit exceeds the difference in child support.
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INITIATE REPAYMENT FIP, SDA, RCA, CDC and FAP Bridges automatically starts the repayment process once an overpayment claim has been established. The individual/client is instructed to return the DHS-4358-C, Department and Client Error Information and Repayment Agreement, to the Collections Unit. If the signed repayment agreement is returned to an OEA, they must enter it in Bridges under Benefit Recovery, Record Repayment Agreement. The OEA must place the signed repayment agreement in the OI (Overissuance) tab of the Electronic Case File (ECF). SUSPECTED IPV When an IPV is suspected an Overpayment Referral must be completed in Bridges, ensure Yes is checked for Suspected IPV to route the referral to the Office of Inspector General (OIG). For CE overpayment claims suspected of IPV, see BAM 720 for referral criteria. If after reviewing a client error, it is determined that an IPV is suspected, do not establish a client error in Bridges. Instead, send an overpayment referral to OIG by emailing MDHHS-OIG-IPV- Referral@michigan.gov.
HEARING REQUESTED FIP, SDA, RCA, CDC and FAP A DHS-4358-D, Hearing Request for Overissuance or Recoupment Action, must be forwarded to Michigan Office of Administrative Hearings and Rules (MOAHR) along with a completed DHS-3050, Hearing Summary, and exhibits in accordance with BAM 600. Update the overpayment claim status field under Benefit Recovery, Claim Adjustment to Pending Administrative Hearing from the drop- down. Note: If an individual/client withdraws the hearing request or fails to show and the hearing is not rescheduled, update the overpayment claim status field under Benefit Recovery, Claim Adjustment to Standard Recoupment from the drop-down.
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If Michigan Department of Health and Human Services (MDHHS) is upheld: • Update the overpayment claim status field back to Standard Recoupment from the drop-down. • Enter the date of the hearing decision under Benefit Recovery, Claim Adjustment, Agreement Sign Date. • Send a Collection Notice to the individual/client as renotification of the overpayment claim. • If warranted, update the Delinquency Date under Benefit Recovery, Claim Adjustment 31 days after the Collection Notice is sent. This is currently a manual process. If MDHHS is not upheld: • Act in accordance with the decision and order. • Decrease the balance under Benefit Recovery, Claim Adjustment with Hearing Decision as the reason from the drop- down. RESOURCES FIP Personal Responsibility and Work Opportunity Reconciliation Act of 1996, P.L. 104-193 of 1996, as amended 1939 PA 280, as amended (Social Welfare Act) MCL 400.1 et seq. MCL 400.60 Mich Admin Code, R 400.3129 - 400.3131 FAP 7 CFR 273.18 7 USC 2022 Mich Admin Code, R 400.3011 Consolidated Appropriations Act, 2021, P.L. 116-260 American Rescue Plan Act of 2021, P.L. 117-2 SDA Annual appropriations Act Mich Admin Code, R 400.3151 - 400.3180
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RCA 42 CFR 400.49 Medicaid (MA) 42 CFR 431.230(b) MCL 400.60 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186) 45 CFR Parts 98 and 99 Social Security Act, as amended 2016
CONTACT Policy-Recoupment@michigan.gov - Overpayment Policy. MDHHS-OIG-OEA-Policy@michigan.gov - OIG OEA Policy.
BAM 720 1 of 19 INTENTIONAL PROGRAM VIOLATION BPB 2026-009 4-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
POLICY All Programs Intentional Program Violation (IPV) is when you intentionally make a false or misleading statement, hide, misrepresent or withhold facts on purpose to receive or continue to receive extra benefits. If we think you committed fraud/IPV, we may hold an administrative hearing, bring criminal charges, or ask you to voluntarily sign a disqualification agreement. This item explains Intentional Program Violation processing and establishment. DEFINITIONS Intentional Program Violation (IPV) IPV consists of having intentionally: • Made a false or misleading statement, or misrepresented, concealed or withheld facts; or • Committed any act that constitutes a violation of the Food Assistance Program (FAP), Supplemental Nutrition Assistance Program (SNAP) regulations, or any state statute for the purpose of using, presenting, transferring, acquiring, receiving, possessing, or trafficking of FAP benefits or Electronic Benefit Transfer (EBT) cards. FAP Only Misuse Misuse is the use, presenting, transferring, acquiring, receiving or possessing, theft, or sale of items purchased with FAP benefits or EBT cards that constitutes a violation of any federal or state statute of FAP regulations or program rules for the purpose of administering this program. Trafficking • The buying, selling, stealing, or otherwise effecting an exchange of FAP benefits issued and accessed via EBT cards, card numbers and personal identification numbers (PINs), or by manual voucher and signature, for cash or consideration
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other than eligible food, either directly, indirectly, in complicity or collusion with others, or acting alone; or • The exchange of firearms, ammunition, explosives, or controlled substances, as defined in section 802 of title 21, United States Code, for SNAP (FAP) benefits; or • Purchasing a product with FAP benefits that has a container requiring a return deposit with the intent of obtaining cash by discarding the product and returning the container for the deposit amount, intentionally discarding the product, and intentionally returning the container for the deposit amount; or • Purchasing a product with FAP benefits with the intent of obtaining cash or consideration other than eligible food by reselling the product, and subsequently intentionally reselling the product purchased with FAP benefits in exchange for cash or consideration other than eligible food; or • Intentionally purchasing products originally purchased with FAP benefits in exchange for cash or consideration other than eligible food; or • Attempting to buy, sell, steal, or otherwise affect an exchange of FAP benefits issued and accessed via Electronic Benefit Transfer (EBT) cards, card numbers and personal identification numbers (PINs), or by manual voucher and signatures for cash or consideration other than eligible food, either directly, indirectly, in complicity or collusion with others, or acting alone. SUSPECTED IPV IPV is suspected when an overpayment (OP) exists for which all three of the following conditions exist: • The client failed to report information or gave incomplete or inaccurate information needed to make a correct benefit determination, and • The client was clearly and correctly instructed regarding their reporting responsibilities, and • The client has no apparent physical or mental impairment that limits their understanding or ability to fulfill their reporting responsibilities.
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IPV is suspected when there is evidence that the client or Child Development and Care (CDC) provider has apparently withheld or misrepresented information for the purpose of establishing, maintaining, increasing or preventing reduction of program benefits or eligibility. FAP Only IPV is suspected for a client who is alleged to have misused or trafficked FAP benefits. Reminder: For OPs originally calculated as suspected IPV that are found to be client error (CE) only, the OP period may change and affect the OP amount. OVERPAYMENT AMOUNT FIP, SDA, RCA, CDC and FAP The amount of benefits issued to the client, household, or provider in excess of what the recipient(s) was/were eligible to receive. FAP Only If the client error involves two or more FAP groups which should have received benefits as one group, determine the error amount by doing the following: • Add together all the benefits received by each group, and • Subtract the correct benefits for the one combined group. Trafficking amount for trafficking related IPVs is the value of the attempted or actually trafficked benefits as determined by: • The court decision. • The individual's admission. • Documentation used to establish the trafficking determination, such as an affidavit from a store owner or sworn testimony from a federal or state investigator of how much a client could have reasonably trafficked in that store. This can be established through circumstantial evidence.
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IPV DETERMINATION Family Independence Program (FIP), State Disability Assistance (SDA), Refugee Cash Assistance (RCA), CDC and FAP The client/authorized representative (AR) is determined to have committed an IPV by: • A court decision. • An administrative hearing decision. • The client/AR signing and dating a MDHHS-826, Request for Waiver of Disqualification Hearing, or MDHHS-830, Disqualification Consent Agreement, or other overpayment and disqualification agreement form. Note: A signed and dated MDHHS-4350, IPV Repayment Agreement, alone does not determine IPV. FIP Only IPV disqualifications for the program formerly known as Aid to Families with Dependent Children (ADC) are to be taken into consideration when imposing subsequent disqualifications for the program now known as the Family Independence Program (FIP) FAP Only IPV exists when an administrative hearing decision, signed and dated disqualification agreement or court decision determines FAP benefits were misused or trafficked. Medicaid (MA) Only IPV exists when the beneficiary or AR: • Is found guilty by a court, or • Signs a MDHHS-4350, Intentional Program Violation Repayment Agreement, and the prosecutor or the Office of Inspector General (OIG), authorizes repayment in lieu of prosecution, or • Is found responsible for the IPV by an administrative law judge (ALJ) conducting an IPV or debt establishment hearing.
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OIG REFERRAL CRITERIA All Programs Prudent judgment should be used in evaluating an overpayment for suspected IPV. Consider the following questions when reviewing the case: • Does the record show that department staff advised the client of their rights and responsibilities? • Does the record show the client’s acknowledgment of these rights and responsibilities? • Did the client neglect to report timely when required to do so? • Did the client appear to make false or misleading statements? • Does the client error meet suspected IPV criteria? • Does the amount meet the OIG dollar threshold found below?
Suspected IPVs are referred to OIG when: • From preliminary review, it appears that the overpayment falls within the definition of suspected IPV, and • The total overpayment amount for all programs combined is $500 or more, or • The total overpayment amount for all programs combined is less than $500, and The group has a previous IPV, or Misuse or trafficking are suspected, or It involves concurrent receipt of assistance; see Bridges Eligibility Manual (BEM) 222, or The client has had at least two client errors previously, or The alleged fraud is committed by a state government employee.
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CDC Provider Error Only Refer overpayments of $500 or more caused by a provider’s intentional false billings or intentional inaccurate statements. Some examples are: • Failing to bill correctly. • Receiving CDC payment for care paid by a third party. • Receiving CDC payment for hours when the child was not in care and the absence was not allowable; see BEM 706. State Emergency Relief (SER) Only Suspected IPVs can be combined with FIP, SDA, RCA, FAP and CDC programs to meet the OIG referral threshold of $500. FIS/ES must calculate the overpayment amount and period before sending a referral to OIG FAP MISUSE Overpayment claims arising from misuse or trafficking of benefits will be the value of the benefits as determined by: • The individual's admission, or • Adjudication, or • The documentation that forms the basis for the determination. Such as: Sworn testimony from a federal or state investigator, or An affidavit from a store owner of how much an individual could have reasonably misused or trafficked. This can be established through circumstantial evidence.
OIG RESPONSIBILITIES All Programs Suspected IPV cases are investigated by OIG. OIG will: • Refer suspected IPV cases that meet criteria for prosecution to the Prosecuting Attorney.
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• Refer suspected IPV cases that meet criteria for IPV administrative hearings to the Michigan Office of Administrative Hearings and Rules (MOAHR). • Refer/return non-IPV cases to the Overpayment Establishment Section (OES). IPV Hearings FIP, SDA, RCA, CDC, MA and FAP OIG represents MDHHS and Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP) during the hearing process for IPV hearings. OIG requests IPV hearings when no signed MDHHS-826 or MDHHS-830 is obtained, and correspondence to the client is not returned as undeliverable, or a new address is located. Exception: For FAP only, OIG will pursue an IPV hearing when correspondence was sent using first class mail and is returned as undeliverable. OIG requests IPV hearing for cases involving: 1. FAP overpayments, misuse, and trafficking related referrals that are not forwarded to the prosecutor. 2. Prosecution of welfare fraud FAP overpayments, misuse, and trafficking related referrals declined by the prosecutor for a reason other than lack of evidence, and • The total amount for the FIP, SDA, RCA, CDC, MA and FAP programs combined is $500 or more, or • The total amount is less than $500, and The group has a previous IPV, or The alleged IPV involves FAP trafficking, or The alleged fraud involves concurrent receipt of assistance (see BEM 222), or The alleged fraud is committed by a state/government employee.
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Excluding FAP, OIG will send the overpayment to the OES to process as a client error when the MDHHS-826 or MDHHS-830 is returned as undeliverable and no new address is obtained. OIG DISPOSITIONS All Programs Referral Rejected OIG may refer/return an Overpayment Referral to the Overpayment Establishment Section (OES) when the referral does not meet IPV criteria. OIG may return a MDHHS-834 MIGS, Fraud Investigation Request, as inappropriate or with insufficient information to pursue overpayment as a result of their initial review and screening of the referral. FIP, SDA, RCA, CDC and FAP Process the overpayment as client or provider error if: • Not previously established as a client or provider error, and • There is enough information to determine the OP period and amount, and • It is not due to agency error. Note: For potential agency errors see Bridges Administrative Manual (BAM) 705. OIG Closure OIG may return an investigation disposition indicating investigation closure if it determines IPV evidence does not exist. FIP, SDA, RCA, CDC and FAP Process the overpayment as client or provider error if: • Not previously established as a client or provider error, and • There is enough information to determine the OP period and amount, and • It is not due to agency error. Note: For potential agency errors see BAM 705.
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Prosecutor Actions The investigation disposition is completed specifying the prosecut- ing attorney’s office action. If the client signed a MDHHS-830, Disqualification Consent Agreement and MDHHS-4350, Intentional Program Violation Repayment Agreement, in lieu of prosecution, see the IPV ESTABLISHED section in this item. There is no further administrative appeal after a MDHHS-830 and MDHHS-4350 are signed. The client may appeal to circuit court. FIP, SDA, RCA, CDC and FAP Establish the overpayment as client or provider error if: • Not previously established as a client or provider error, and • Prosecution is declined for lack of IPV evidence, and • OIG did not pursue an IPV hearing, and • There is enough information to determine the OP period and amount, and • It is not due to agency error. Note: For potential agency errors see BAM 705.
Court Actions The investigation disposition is completed specifying the action of the court. If it is determined the client or provider committed an IPV, complete the following steps: • Initiate restitution as ordered by the court. • Process the full amount as IPV if the court does not address restitution. • If the court ordered IPV restitution is less than the overpayment amount, process the remainder as client or provider error. • For FIP, SDA, RCA and FAP apply the court-ordered disqualification period or the standard disqualification period specified in this item if the court does not address disqualification.
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FIP, SDA RCA, CDC and FAP Process the overpayment as client or provider error if: • Not previously established as a client or provider error, and • The charges were dismissed for lack of evidence, and • There is enough information to determine the OP period and amount, and • It is not due to agency error. Note: For potential agency errors see BAM 705. OIG Administrative Action FIP, SDA, RCA, CDC and FAP The investigation disposition is completed when: • A MDHHS-826 and MDHHS-4350 is obtained from the client. • An IPV hearing decision is issued. Exception: If only an MDHHS-826 or MDHHS-830 is obtained from the client and a client error overpayment claim was previously established in Bridges an OIG OEA will convert the CE overpayment claim to an IPV overpayment claim. IPV ESTABLISHED All Programs OIG will send all dispositions to the OIG OEA disposition mailbox at MDHHS-OIG-OEA-Disposition@michigan.gov within 14 days of their final disposition. For program overpayments not established in Bridges such as SER and MA, account receivable set up is required. The assigned OIG OEA will forward a copy of one of the following to the Collections Unit mailbox at MDHHS-Collections- Unit@michigan.gov: • Signed MDHHS-4350, Intentional Program Violation Repayment Agreement. • MOAHR Administrative Hearing Decision and Order. • Court Order signed by a judge. Note: If only page two of the MDHHS-4350 is provided, include a copy of only page one of the MDHHS-1835 MIGS, OIG
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Investigation Disposition Report to verify the actual amount of program overpayments. FIP, SDA, RCA and FAP IPV findings result in a higher administrative repayment amount of the overpayment and member disqualification for the program in which it occurred. OIG OEA must complete repayment and disqualification actions within 10 days of receipt of the OIG final disposition or signed MDHHS-4350 and MDHHS-830. DISQUALIFICATION FIP, SDA, RCA and FAP Disqualify an active or inactive recipient who: • Is found by a court or hearing decision to have committed IPV. • Has signed a MDHHS-826 or MDHHS-830. • If found responsible through an administrative hearing or convicted in court of duplicate receipt of assistance. • For FAP, is found by MOAHR or a court to have misused or trafficked FAP benefits. A disqualified recipient remains a member of an active group as long as he lives with them. Other eligible group members may con- tinue to receive benefits. See BEM 400, BEM 518, and BEM 554 for treatment of the assets and income of disqualified group members. CDC Providers Only See BEM 707 for provider disqualifications. Standard Disqualification Periods FIP, SDA, RCA and FAP The standard disqualification period is used in all instances except when a court orders a different period; see Non-Standard Disqualification Periods in this item.
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Apply the following disqualification periods to recipients determined to have committed an IPV: • One year for the first IPV. • Two years for the second IPV. • Lifetime for the third IPV. FIP and FAP Ten-year disqualification for concurrent receipt of benefits if fraudulent statements were made regarding identity or residency; see BEM 203. CDC Providers Only See BEM 707 for disqualification periods. Nonstandard Disqualification Periods FIP, SDA, RCA and FAP Courts may order nonstandard disqualification periods. Apply the court ordered period. If the court does not address disqualification in its order, the stan- dard period applies. Periods Shorter Than Standard Periods of at least one month, but shorter than the standard period specified are entered on Bridges like the standard period. When zero disqualification is ordered for a recipient do not enter on Bridges. Disqualified Grantee FAP Only A disqualified member may continue as the grantee only if there is no other eligible adult in the group.
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When the grantee in a joint FIP/SDA/RCA and FAP case is disqualified for FAP, open the group’s FAP under a separate case number if: • There is another adult in the FAP case, and • The disqualified member remains the FIP/SDA/RCA grantee. • Continue a joint FIP/SDA/RCA and FAP case under a single case number after the grantee's FAP disqualification if the other adult FAP member becomes the grantee for both groups. FAP Program Violations FAP Only Courts order FAP program disqualifications for misuse or trafficking of program benefits; see BEM 203 for more information. Apply disqualification periods when a recipient is convicted by a state or federal court, as follows: • Two years when the recipient has been convicted of trading FAP to acquire illegal drugs. • Lifetime period when the recipient has been convicted of: Trading FAP to acquire illegal drugs for a second time. Trading FAP to acquire firearms, ammunition or explosives. Trafficking FAP with a value of $500 or more. • The standard IPV disqualification periods apply to FAP misuse or trafficking convictions less than $500. The standard IPV disqualification periods apply to FAP misuse or trafficking determinations made by MOAHR or by the client signing an IPV Repayment Agreement. CLIENT NOTIFICATION All Programs Notify the client of IPV repayment and disqualification actions via the DHS-4357, IPV Client Notice. OIG OEAs have 10 days after receiving disposition to initiate repayment and disqualification actions.
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Give adequate notice when initiating repayment and disqualifica- tion as a result of an IPV hearing or when a MDHHS-826, Request for Waiver of Disqualification Hearing, is signed. This applies to active and inactive cases. Give the individual timely notice before initiating recoupment as a result of a court action unless the individual also signed a MDHHS- 826. This applies to active and inactive cases. Reminder: All programs in which IPV has been determined such as MA, SER, Services etc., are to be included on the DHS-4357, IPV Client Notice. CDC Provider Only See BEM 707 for provider notification. Hearing Request on DHS-4357 FIP, SDA, CDC and FAP If the DHS-4357 is returned with a hearing requested, send a copy to MOAHR (see BAM 600). Attach a copy of the signed MDHHS- 826 or MDHHS-830 and the MDHHS-4350, court order or hearing decision establishing the IPV. Only hearing requests challenging the overpayment benefit reduction or repayment amount (not the overpayment amount) are granted by MOAHR. Update the overpayment claim status field under Benefit Recovery, Claim Adjustment to Pending Administrative Hearing form the drop- down. Note: If an individual withdraws the hearing request or fails to show and the hearing is not rescheduled, update the overpayment claim status field under Benefit Recovery, Claim Adjustment to Standard Recoupment from the drop-down. If Michigan Department of Health and Human Services (MDHHS) is upheld: • Update the overpayment claim status field back to Standard Recoupment from the drop-down. • Enter the date of the hearing decision under Benefit Recovery, Claim Adjustment, Agreement Sign Date.
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• Send a Collection Notice to the individual as renotification of the overpayment claim. • If warranted, update the Delinquency Date under Benefit Recover, Claim Adjustment 31 days after the Collection Notice is sent. This is currently a manual process. If MDHHS is not upheld: • Immediately request a reconsideration/rehearing. • Act in accordance with the decision and order. • Decrease the balance under Benefit Recovery, Claim Adjustment with Hearing Decision as the reason from the drop- down. Note: CDC providers do not have hearing rights. INITIATING OVERPAYMENT FIP, SDA, RCA, CDC and FAP Initiate the overpayment on the effective date of the DHS-4357 by entering or changing the overpayment claim on Benefit Recovery System (BRS). Note: If a court or OIG specifies an IPV overpayment amount less than the total amount, and the difference is not due to a calculation error, process: • The court ordered amount as IPV. • The remaining balance as a client error. Active programs are subject to benefit withholding (BW) also known as administrative recoupment (AR) to repay the overpayment. Inactive programs are subject to cash repayment. BRS will automatically send collection notices to inactive cases; see BAM 725. BRS Entry FIP, SDA, RCA and FAP To start benefit withholding/administrative recoupment and other collections on active and inactive FIP, SDA, RCA and FAP programs, take the following actions in Bridges:
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• Authorize an IPV overpayment claim for the amount on the MDHHS-1835 MIGS. • The discovery date for misuse or trafficking-related overpayment claims and any other IPV overpayment claim is determined by the individual's signed and dated disqualification agreement, an IPV hearing request, or prosecutorial referral. • Enter the current date as the IPV repay notice sent date. Note: If a client error overpayment claim already exists in Bridges for the same overpayment period: • Complete an overpayment claim adjustment to reduce the outstanding balance of the client error overpayment claim to zero. • Authorize an IPV overpayment claim for the outstanding balance of the client error overpayment claim (balance before overpayment claim adjustment). • The IPV discovery date is the same discovery date as the previously established client error overpayment claim and does not change upon conversion to an IPV. • If the client error overpayment claim outstanding balance is already zero, an overpayment claim adjustment is not required. Authorize an IPV overpayment claim for the program and amount on the MDHHS-1835 MIGS and immediately reduce the IPV overpayment claim balance to zero since the debt has already been paid in full as a client error.
INITIATING IPV DISQUALIFICATION FIP, SDA, RCA and FAP All IPV disqualifications must be served immediately. Begin the dis- qualification the first month after the notice is sent unless the action is untimely; see Untimely Disqualification in this item. If multiple IPV disqualifications occur in the same program, they are served concurrently or with overlapping periods. If other program disqualifications occur during an IPV period, they are served concurrently with the IPV disqualification.
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IPV disqualification periods cannot be interrupted, even if the per- son becomes otherwise ineligible. IPV disqualification from a program, for example FIP, is not counted when later determining the IPV disqualification period for a different program, for example FAP. Disqualifications take precedence over penalties; therefore, disqualification resulting in penalties (benefit reductions) must be ended in order to impose IPV disqualifications. Update IPV Sanctions to remove the disqualified member. CDC Providers Only MiLEAP CDC Policy Unit will initiate disqualifications. Local offices should continue to complete and submit the MDHHS-834 MIGS, Fraud Investigation Request, to OIG when it is discovered a provider may be non-compliant with program requirements; see BEM 707. Standard of Promptness FIP, SDA and FAP Send the individual a DHS-4357 within 10 days after the receipt of: • The investigation disposition indicating IPV was determined. • The hearing decision that IPV occurred. • The signed MDHHS-826 or MDHHS-830. Begin the disqualification the first month after the notice is sent. Untimely Disqualification FIP, SDA, RCA and FAP When a disqualification was not imposed according to the standard of promptness (above): • Impose the disqualification for any remaining months. • Process an agency error overpayment for the benefits issued during the months the person should have been disqualified.
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• If the agency error amount is above $250, establish the overpayment claim and notify the individual of this overpayment via the DHS-4358A, B, C and D; see BAM 705. RESOURCES FIP Personal Responsibility and Work Opportunity Reconciliation Act of 1996, P.L. 104-193 of 1996, as amended 1939 PA 280, as amended (Social Welfare Act) MCL 400.1 et seq. MCL 400.60 Mich Admin Code, R 400.3129 - 400.3131 FAP 7 CFR 271.5 7 CFR 273.16 7 CFR 273.18 7 USC 2022 Mich Admin Code, R 400.3011 MCL 400.60 MCL 750.300a Consolidate Appropriations Act, 2021, P.L. 116-260 American Rescue Plan Act of 2021, P.L. 117-2 SDA Annual Appropriations Act Mich Admin Code, R 400.3151 - 400.3180
RCA 42 CFR 400.49
MA 42 CFR 431.230(b) MCL 400.60
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CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
CONTACT MDHHS-OIG-OEA-Policy@michigan.gov - OIG OEA Policy. Policy-Recoupment@michigan.gov - Overpayment Policy.
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POLICY Family Independence Program (FIP), State Disability Assistance (SDA), Child Development and Care (CDC), and Food Assistance Program (FAP) When the client group or Child Development and Care (CDC) provider receives more benefits than entitled to receive, Michigan Department of Health and Human Services (MDHHS) or Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP) must attempt to recoup the overissuance. This item explains repayment responsibility, Benefit Recovery System data management, and the various collection processes used by MDHHS or MiLEAP. Definitions Benefit Recovery System (BRS) The part of Bridges that tracks all FIP, SDA, CDC and FAP overissuances and repayments, issues automated collection notices and triggers automated benefit reductions for active FIP, SDA, CDC and FAP programs. Administrative Recoupment (AR) An automated Bridges process that reduces current MDHHS and/or MiLEAP benefits in order to obtain repayment on overissuances for a program. Claim Number A unique number assigned to each overissuance when entered on the Benefit Recovery System. PAYMENT RESPONSIBILITY All Programs Repayment of an overissuance is the responsibility of: • Anyone who was an eligible, disqualified, or other adult in the program group at the time the overissuance occurred. • A FAP-authorized representative if they had any part in creating the FAP overissuance.
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Bridges will collect from all adults who were a member of the case. Administrative recoupment may be deducted on more than one case for a single overissuance. FIP and FAP If the overpaid group did not contain an eligible or disqualified adult during the overissuance period, do not initiate recoupment, unless recoupment is established by court order or a repayment agreement is obtained in lieu of prosecution. An adult for recoupment purposes is an individual 18 years old or older. Note: The Aid to Families with Dependent Children (ADC) program was succeeded by the Family Independence Program (FIP). Treat these programs as interchangeable when applying recoupment/dis- qualification policy. Example: Clients who committed an Intentional Program Violation (IPV) while receiving ADC are to be disqualified under the FIP program. CDC Provider Error CDC Only The reconciliation and recoupment section (RRS) is responsible for collecting and recording provider errors. Reconciliation and recoup- ment section staff enters the overissuance into the automated pro- vider recoupment system. The system produces a notice and overpayment detail and acceptance report, which is mailed to the child care provider. The provider is instructed to review and complete the report and mail it back to the reconciliation and recoupment section. Note: There is no threshold limit on CDC system errors. MiLEAP will recoup these types of overissuances. BENEFIT RECOVERY SYSTEM FIP, SDA, CDC and FAP Benefit Recovery System (BRS) data is based on recipient identification numbers. Each program overissuance is entered separately. Do not combine program overissuances with different overissuance periods or different overissuance types.
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Each overissuance is assigned an overissuance claim number when initially entered on BRS. Review Office of Inspector General dispositions for multiple events that may have been combined or may be deleted. Case Number Usage Bridges reviews all persons responsible for the overissuance for current program activity and/or different case numbers. Active Programs All cases that contain an adult member from the original overissu- ance group and are active for the program in which the overissu- ance occurred are liable for the overissuance and subject to administrative recoupment. Inactive Programs Overissuances on inactive programs are recouped through cash repayment processes. Collection notices are sent to the household on the inactive case. To determine the best case number to use for an inactive case, use this priority: 1. Use the original overissuance case number, when the following apply: • The case number has not been purged. • The case number is not active for another program. • The group includes an eligible or disqualified adult member who was in the program group when the overissuance occurred. Note: Change the grantee, if necessary, to the person who is responsible for repayment of the overissuance. 2. Use any existing case number for inactive person(s) responsible for overissuance repayment when the original case number is not available.
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OVERISSUANCE CHANGES Always do an inquiry before entering, changing or closing an overissuance. Always document in Bridges case comments the reason for changing or closing an overissuance event in the incorrect issuance packet. Some reasons an overissuance might be changed include: • An Office of Inspector General or Michigan Administrative Hearings System (MAHS) disposition is received. • A repayment agreement is received. • The responsible person has filed for bankruptcy. • The responsible person has died. • Duplicate overissuance events are on Benefit Recovery System. • The overissuance is transferred to another case number. • A debt collection action has taken place. Reconciliation and Recoupment Section Changes Contact the reconciliation and recoupment section (RRS), Welfare Debt Unit, to get changes made to overissuances whenever: • The overissuance has been suspended by the Welfare Debt Unit. • The overissuance has a debt referral status type. Bridges will generate an edit when changes are made to overissu- ances in any of the above circumstances. Overissuance Balance Changes The overissuance balance is calculated by Benefit Recovery Sys- tem. Changing the original overissuance amount will change the balance for that overissuance and program on Benefit Recovery
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System records. Do not reduce an overissuance balance for any of the following reasons: • A court released the person from probation and waived restitution. • A court (probation officer) indicated an amount was worked off (for example, in community service). Exception: For FAP only, reduce an overissuance by the amount the person worked off after a court has ordered and verified the activity. Issue supplemental FAP benefits if the total repaid and worked off exceeds the overissuance. Do not enter an overissuance payment for the amount worked off. Payment Consolidation Changing an overissuance amount or closing an overissuance event will cause Benefit Recovery System to redistribute any pay- ments that were made to the overissuance event. Overissuance Transfer Bridges automatically transfers an overissuance to another case number when a liable individual is currently active for the same pro- gram in which the overissuance occurred. COLLECTIONS ON ACTIVE PROGRAMS Overissuances on active programs are repaid by: • Lump-sum cash payments. • Monthly cash payments such as when court-ordered or processed by AG. • Administrative recoupment (benefit reduction). Note: For FIP, SDA and FAP the client may repay any part of the overissuance with electronic benefit transfer (EBT) benefits. The electronic benefit transfer benefits cannot cross programs. The client may pay on a FIP overissuance with FIP benefits and/or FAP overissuance with FAP benefits. The local office will accept and provide receipt for payment.
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Lump-Sum Cash Payments Lump-sum cash payments are acceptable on active programs. Pay- ments can be made at the local office or to Cashier’s Unit, P.O. Box 30259, Lansing, MI 48909. Note: When the full overissuance amount is paid in a lump sum prior to the administrative recoupment effective date, the payment must be entered on Benefit Recovery System immediately after the overissuance is entered in order to prevent administrative recoupment from occurring. Cash Payments Monthly cash payments (instead of administrative recoupment) are acceptable on active programs only if ordered by a court or processed by the Attorney General office; see Administrative Recoupment or Delinquent Cash Payments, in this item. Note: Clients repaying all or part of an overissuance with a MDHHS issued warrant must be referred to local office to sign the warrant over to the local office. Do not have the warrant voided and returned to Treasury. Administrative Recoupment FIP, SDA, CDC and FAP Active programs are subject to Administrative Recoupment (AR) for repayment of overissuances. Active program recipients are allowed to make monthly cash payments (instead of administrative recoup- ment) only when ordered by a court or processed by the AG office; see Cash Payments in this item. Administrative recoupment cannot cross programs. For example; a FIP overissuance cannot be recouped from FAP benefits. An ADC overissuance can be recouped from FIP. A General Assistance (GA) overissuance can be recouped from SDA. Administrative recoupment continues until program closure or all collectible overissuances are repaid. Administrative recoupment automatically resumes when a program with an overissuance bal- ance reopens.
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Administrative recoupment can be deducted from more than one active case for a single overissuance. See BAM 400, CASH BENEFITS, Openings, for FIP and SDA early payment procedures. AR Amount FIP, SDA and CDC FIP and SDA benefits are reduced for recoupment by a percentage of the payment standard. The administrative recoupment amount automatically changes when the payment standard changes. The standard administrative recoupment percentage is always used unless a court has ordered a different percentage or a specific dollar amount. The standard administrative recoupment percentage for FIP, SDA and CDC is: • 5 percent for agency error. • 5 percent for client error. • 10 percent for intentional program violation. • 20 percent for CDC provider intentional program violation. Note: When necessary, the administrative recoupment amount is automatically reduced in order to leave a $2 grant payment to the client. FAP Only FAP benefits are reduced for recoupment by a percentage of the monthly FAP entitlement. (The entitlement amount is the amount of FAP a group would receive if any intentional program violation- disqualified members were included in the eligible group.) Administrative recoupment occurs only on current month issuances and automatically changes when the monthly issuance amount changes. Use the standard administrative recoupment percentage unless a court has ordered a different administrative recoupment percentage or a specific dollar amount. The minimum administrative recoup- ment amount is $10, unless the final overissuance payment is less than $10.
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The standard administrative recoupment percentage for FAP is: • 10 percent (or $10, whichever is greater) for agency error. • 10 percent (or $10, whichever is greater) for client error. • 20 percent (or $20, whichever is greater) for intentional program violation. Note: In addition to administrative recoupment, FAP supplements to restore lost benefits are automatically offset when entered on Bridges to repay FAP overissuances. The restoration supplement is used in part or in whole to repay overissuances. Delinquent Cash Payments on Active Cases FIP, SDA and FAP Active cases failing to make required court-ordered cash payments for 60 days are sent a DHS-1440E, Notice of Payment Due. All cases sent the DHS-1440E notice informs the client of changing the recoupment method to benefit reduction via Administrative Recoupment (AR). Thirty days after the DHS-1440E is sent, Bridges changes the recoupment type from cash collection to administrative recoupment, unless the client: • Makes a full payment, or • Seeks to renegotiate the monthly cash payment amount, and • Their financial circumstances warrant a lower monthly payment by the court order. COLLECTIONS ON INACTIVE PROGRAMS FIP, SDA, CDC and FAP Overissuance balances on inactive cases must be repaid by lump- sum or monthly cash payments unless collection is suspended; see SUSPENDED COLLECTION ACTIONS in this item. Benefit Recovery System sends a collection notice when programs or cases close and an outstanding overissuance exists; see AUTOMATED DELINQUENCY NOTICES in this item.
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Cash Payments All Programs Lump sum or monthly cash payments are accepted at any local office and in some cases will be routed through the AG office. FIP, CDC, SDA and FAP Payments can also be mailed to; State of Michigan Cashier’s Unit P.O. Box 30259 Lansing, MI 48909 CDC Providers State of Michigan Cashier Unit-Child Development and Care P.O. Box 30382 Lansing, MI 48909 MA Fraud State of Michigan MDHHS P.O. Box 30437 Lansing, MI 48909 SER and DSS Fraud State of Michigan MDHHS-Reconciliation and Recoupment P.O. Box 30802 Lansing, MI 48909 Such payments should include the payer’s SSN or case number to ensure proper posting of the payment. Expunged EBT Benefits FAP Only Expunged electronic benefit transfer benefits are applied to existing overissuances for the program at the time the expungement occurs.
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Probate Claims All Programs If a local office becomes aware of an estate of a deceased person with a remaining overissuance balance, it may refer the claim to the Welfare Debt Unit (WDU). WDU and the AG will determine if pursuit of the estate through probate court claim action is in the best interest of MDHHS or MiLEAP. DELINQUENCY FIP, SDA and FAP Bridges automatically sets delinquency at the claim level and affects all liable individuals attached to the claim. Delinquency is triggered when: • The client fails to sign and return the DHS-4358C, Department and Client Error Information and Repayment Agreement, within 30 days of the claim establishment date. • The client fails to make a $50 monthly cash payment within those same 30 days if the case is closed. • The client on the closed case fails to make full payments each month until the claim is paid off. • Previously active clients who were being administratively recouped and now have closed did not make the $50 monthly payment within 30 days after the DHS-1440A, Notice of Balance Due, was sent and each month thereafter. When a claim becomes delinquent, Bridges refers qualifying cash programs to Michigan Treasury and FAP claims referred to the Treasury Offset Program (TOP). MICHIGAN TREASURY COLLECTIONS FIP, SDA and CDC The welfare debt collection process refers cash overissuances to the State Treasury Accounts Receivable System (STARS) at the Michigan Department of Treasury and collects debts through any of the following:
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• Garnishment of wages. • Liens on bank accounts. • Regular cash payments. • State income tax offsets. • Lottery winnings. • Gaming winnings. A cash overissuance may be referred to treasury when a full payment has not been received within 30 days after the DHS- 1440A was sent. Once an overissuance is selected for this process, the case will be identified on BRS. Refer clients to the reconciliation and recoupment section staff (RRS) in central office at 1-800-419-3328, when requesting a review of the collection action. RSs must assist when contacted by RRS staff in resolving issues such as evidence search, grantee changes, overissuance transfers, etc. A person’s income tax refund might be offset in error when: • The grantee on a case is not the person responsible for repayment. • Monthly overissuance payments are made to another department as part of court order and not entered on Benefit Recovery System in a timely manner. For cases offset in error, recoupment specialists must send a memo explaining the reasons for requesting a refund to: Overpayment Recovery and State Psychiatric Hospital Reimbursement Division Overpayment Dispute Resolution Unit Suite 808, Grand Tower Building Do not delete or modify the overissuance amount to remedy the error.
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FEDERAL TREASURY OFFSET PROGRAM FAP Only Federal salaries, benefits and tax refunds may be offset to repay any collectible FAP overissuance when the claim is delinquent. Federal payments eligible for offset include: • Federal income tax returns. • Federal salary pay, including military pay. • Federal retirement benefits, including military retirement pay. • Federal contractor or vendor payments. • RSDI benefits. • Railroad Retirement benefits. • Black Lung (part B) benefits. • Other federal payments, including certain loans. Once an overissuance is selected for this process, the case will be identified on Benefit Recovery System. Refer clients to the Reconciliation and Recoupment Section (RRS) in central office to request a review of the collection action. The reconciliation and recoupment section’s phone number is 1-800-419-3328. ATTORNEY GENERAL INITIATIVE FIP, SDA and FAP Delinquent claims for inactive programs are eligible for referral to the Department of Attorney General (AG), Revenue and Collections Division. Referrals are issued through WDU. The AG will pursue collections on such claims through voluntary repayments, civil lawsuits, probation violations and seizure/garnishment on civil and criminal restitution orders.
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Automated Delinquency Notices FIP, SDA, CDC and FAP Benefit Recovery System sends a collection notice when programs close with an outstanding overissuance if the claim is not already set as delinquent. DHS-1440A The DHS-1440A, Notice of Balance Due, is sent in the month after: • A program with an outstanding overissuance balance closes. • The last active program closes and there is an outstanding overissuance balance in any program. DHS-1440E The DHS-1440E, Notice of Payment Due, is sent to active cases when: • The overissuance type is due to court-ordered intentional program violation. • The recoup type is non-standard cash recoupment. • Required monthly payments not received. See Delinquent Cash Payments on Active Programs in this item. DHS-1440-1 The DHS-1440-1, Notice of Default, is sent to inactive cases when the claim is delinquent. All delinquent claims are sent to Michigan Treasury for collection action. SUSPENDED COLLECTION ACTIONS FIP, SDA, CDC and FAP Every overissuance is entered on Benefit Recovery System even when collection action is pending or suspended. Certain status types suspend all or some collection actions:
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Used For Collection Action • OIs pending with OIG • Suspends all collections actions. • OIs pending with AH • Suspends all collection actions. • Bankruptcy
• Death
• Suspends all collection actions. • Suspends all collection actions. • Suspended • Suspends all collection actions. Bankruptcy When a bankruptcy notice for a person with an outstanding overissuance balance is received it must be forwarded to the local office's designated fraud coordinator, who will process and track all bankruptcy notices. The coordinator scans the notice to the RSSECT mailbox or sends the document to WDU, WDU will notify MDHHS Legal Affairs and the RS so proper actions will be taken. MDHHS Legal Affairs reviews and makes recommendations to the Attorney General’s office regarding whether to take legal action to block discharge of the debt. The reconciliation unit suspends debts and retrieves debt if they are in debt collection status. The RS verifies that debts are suspended. CDC Only MiLEAP reviews and makes recommendations to the Attorney General's office regarding whether to take legal action to block discharge of the debt. MiLEAP directs the reconciliation unit to suspend debts and retrieves debt if they are in debt collection status. The RS verifies that debts are suspended. If the client’s bankruptcy petition is granted, the court issues a dis- charge of debt. If MDHHS or MiLEAP is listed as a discharged debt on the court document, determine which overissuances were discharged. Update Benefit Recovery System by: 1. The central office document control unit manually writes off overissuances that were discharged by the court: 2. Reinstating recoupment for any intentional program violation overissuances that were not discharged by the court.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• A notification from MDHHS Legal Affairs will be sent if any intentional program violation overissuances were successfully blocked from discharge. • Change the status type to standard recoupment. If MDHHS or MiLEAP obtains an order of non-dischargeability from the U.S. Bankruptcy Court, change the status type back to standard recoupment on each of the affected overissuances to enable collection activities to resume. Keep all bankruptcy documents in the case record’s legal packet. The reconciliation and recoupment section coordinates bankruptcy actions between Treasury and MDHHS. If any claim shows referred to collections contact Reconciliation and Recoupment section at 1- 800-419-3328. Death Enter the status type of deceased so Bridges will suspend all collection actions on Benefit Recovery System. The overissuance will be written off at the next quarterly Benefit Recovery System write-off. TERMINATED COLLECTIONS FIP and SDA BRS Write-Off Every quarter, Benefit Recovery System writes off overissuances that are not collectible. Overissuances are not collectible when: • The program has been closed six years from the most recent of the following dates: Overissuance end date, or Establishment date, or Last payment date on any overissuances. RECONCILING GH REPORTS Bridges generates reports that must be acted on by staff.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Accounting Service Center Each Accounting Service Center is responsible for reconciling the monthly: • GH-370, Monthly Cash Reconciliation Report, which lists all cash or FAP benefits made directly to the local office by clients owing MDHHS for overissuances of benefits. • GH-380, Monthly Write Off Report, contains an audit trail by listing all programs for a client where a write-off occurred. The Accounting (ACM) Manual 481-5 has detailed instructions on completing these reports. DRS-100 Report Recoupment specialists are expected to take action to correct each disqualification record on the report. Depending on the error listed, the RS will correct the decision date, Social Security number, sanc- tion begin date and/or decision date. COMPROMISED CLAIMS FAP Only MDHHS can compromise (reduce or eliminate) an overissuance if it is determined that a household’s economic circumstances are such that the overissuance cannot be paid within three years. A request for a policy exception must be made from the RS to the Overpayment, Research and Verification Section office outlining the facts of the situation and the client’s financial hardship. The manager of the MDHHS Overpayment, Research and Verification Section has final authorization on the determination for all compromised claims. Send to:
Overpayment Recovery and State Psychiatric Hospital Reimbursement Division Overpayment Research and Verification Section Suite 1011 235 S. Grand Ave P.O. Box 30037
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Lansing, MI 48909 INTERSTATE CLAIMS FIP, SDA and FAP Michigan continues to initiate and collect on claims whether the household remains in the state or not. All requests from other states to transfer a claim to or from Michigan are reviewed by the recoupment section; see address above. FAP Only When MDHHS learns that a client is serving a current intentional program violation disqualification in another state, the specialist must review the information. Disqualify the client if it is determined the disqualification should continue being served in Michigan. Hearing requested FIP, SDA, CDC, MA and FAP A hearing request on a DHS-4358D, Hearing Request for Overissuance or Recoupment Action, must be forwarded to MAHS along with a completed DHS-3050, Hearing Summary, and exhibits according to normal hearing procedures; see BAM 600. LEGAL BASE FIP Personal Responsibility and Work Opportunity Reconciliation Act of 1996, PL 104-193 of 1996 1939 PA 280, as amended Mich Admin Code, R 400.3129 - R 400.3131 FAP 7 CFR 272.8 7 USC 2022 Mich Admin Code, R 400.3011 SDA Annual appropriations Act
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CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY All Programs The Michigan Department of Health and Human Services (MDHHS) routinely matches recipient and applicant data with other public and private agencies through computer data exchanges. Information provided with MDHHSMiLEAP applications (MDHHS-1010, -1171, - 4574, -4574B, and DCH-1426) informs clients of the data exchange process. Data exchanges assist in the verification of income, assets and other eligibility factors for MDHHS recipients and applicants. Data exchange information must be reconciled with information contained in MDHHS case records. DEFINITIONS BENDEX The Beneficiary Data Exchange system which is used to exchange information with SSA on recipients of RSDI and Medicare benefits. eDRS The Federal Electronic Disqualified Recipient System. IRS The Internal Revenue Service. MDE The Michigan Department of Education. MDOC The Michigan Department of Corrections. MiLEAP The Michigan Department of Lifelong Education, Advancement, and Potential.
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NDNH The National Directory of New Hires which is used to receive out of state new hire information. RSDI Retirement, Survivors, Disability Insurance, commonly referred to as Social Security benefits. SDX The State Data Exchange system which is used to receive information from SSA on applicants and recipients of Supplemental Security Income (SSI). Social Security Account Number (SSN) The number shown on a person's social security card. Social Security Claim Number The account number under which a person can receive RSDI and/or Medicare benefits. The claim number might be the person's own account number or that of someone else (such as, spouse, parent). SSA The Social Security Administration. SSI Supplemental Security Income. UCB Unemployment compensation benefits. UIA The Michigan Unemployment Insurance Agency. DATA EXCHANGES Family Independence Program (FIP), State Disability Assistance (SDA), Refugee Cash Assistance (RCA), Child
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Development and Care (CDC), Medicaid (MA) and Food Assistance Program (FAP) Data is currently exchanged with: • Social Security Administration (SSA). • Michigan Unemployment Insurance Agency (UIA). • Michigan New Hire Operations Center. • Internal Revenue Services (IRS). • Michigan Department of Corrections (MDOC). • Michigan Department of Education (MDE). • Michigan Department of Lifelong Education, Advancement, and Potential. • Michigan Lottery. • National Directory of New Hires (NDNH). • Public Assistance Reporting Information System (PARIS) SSA Data Exchanges All Programs Data exchanges from SSA include: • BENDEX (Beneficiary Data Exchange System).
This process reports information on recipients of RSDI and Medicare benefits. • SDX (State Data Exchange).
This system reports information on applicants and recipients of SSI. • Enumeration Verification System.
This process matches SSNs entered on Bridges with SSNs on SSA records.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
• Deceased Recipient Match.
This match compares active recipient SSNs to SSA’s death records. • Prisoner Match
This match identifies pending and active clients in prison or jail. UIA Data Exchanges FIP, SDA, RCA, CDC, MA and FAP Data exchanges from UIA include: • Wage Match.
This process cross-matches MDHHS recipient data with work history records submitted by Michigan employers. • Unemployment Compensation.
This process cross matches MDHHS recipient data with unem- ployment insurance compensation recipient data. State New Hire Exchange FIP, SDA, RCA, CDC, MA and FAP The only data exchange with the Michigan New Hire Operations Center is New Hires. This process cross matches active MDHHS recipients with the New Hire database which is from W-4 tax records or other new hire reporting formats submitted by employers for new employees. IRS Data Exchange FIP, RCA, MA, and FAP Data exchanges from IRS include: • IRS Unearned Income Match.
This process cross matches unearned income data from MDHHS applicants and recipients with unearned income reported to IRS.
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• IRS Wage and Pension Match.
This process cross matches income data from MDHHS applicants and recipients with certain income reported to IRS. Department of Corrections Data Exchange All Programs The only data exchange with the Department of Corrections is the automated monthly Incarceration Match. This match identifies all individuals who are active for any program whose current living arrangement is not prison. Department of Education Data Exchange FAP Only The only data exchange with the Michigan Department of Education (MDE) is the School Lunch Program. This process provides MDE with a list of school-age children receiving FAP. This allows students to be certified for free lunches without requiring the student or parent to complete an application. Students may complete an application form at the local school if they believe they meet the low income requirements and either do not receive FAP or, if they receive FAP, did not appear on the MDHHS match that was distributed to that school district. Local school districts are required to verify eligibility for a certain percentage of applications for the school lunch program. The verification sampling is for paper applications only, as no further verification is needed from the names provided by the MDHHS. If a FAP recipient’s name is on a segment of the MDHHS information that was sent by the MDE to a different school district, the local school district may contact the local office for verification of a school lunch applicant’s receipt of FAP. Local offices must cooperate in providing this verification to the local school districts.
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eDRS Exchange FAP Only The eDRS is an exchange with the Federal Electronic Disqualified Recipient Service for all clients who are applying for FAP or are being added to a FAP case as a new member. This match assists in the identification of potential recipients who may have an intentional program violation in another state. Lottery Match Data Exchange FIP, SDA, RCA, MA and FAP The only data exchange with Michigan Lottery is the Lottery Match. This match identifies clients who won $1,000 or more in the previous week. National Directory of New Hires Exchange FAP Only The NDNH is an exchange with the National Directory of New Hires and is required for all FAP recipients and applicants at application and recertification. This match is used to determine current income sources reported from another state. PARIS Interstate Match FIP, SDA, RCA, CDC, MA and FAP The PARIS Interstate Match is a quarterly data matching service used to help determine if a client has received duplicate benefits in two or more states. Data Exchange Reconciliation FIP, SDA, RCA, CDC, MA and FAP Information received from any computer data exchange must be reviewed and compared with the recipient’s MDHHS record. Any discrepancies must be clarified.
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The standard of promptness for resolving information received from most computer matches is 45 calendar days. Exception: • It is a best practice to resolve information received from new hires within 21 calendar days. • The standard of promptness for resolving information received from the SSA Prisoner match is 12 calendar days. • It is a best practice to send an email to the recoupment specialist as soon as possible to allow the other state to verify the IPV before the standard of promptness to open the case. Procedures for processing each data exchange vary depending on the information received and the particular data exchange process involved. Refer to the appropriate item: • BAM 801, SSA Data Exchanges: BENDEX. SDX. Enumeration. • BAM 802, Wage Match and UCB: Wage Match. Unemployment Compensation Match. • BAM 803, IRS Data Exchanges: IRS Unearned Income. IRS Wage and Pension. • BAM 804, Incarceration Match. • BAM 807, State New Hires. • BAM 808, Deceased Recipient Match. • BAM 809, Lottery Matches. • BAM 812, Electronic Disqualification Recipient System. • BAM 813, National Directory New Hires Match.
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• BAM 814, PARIS Interstate Match. LEGAL BASE All Programs MCL 400.10c FIP 45 CFR 205.56 -.58 MCL 400.57a(3) MCL 400.83 RCA45 CFR 400.45 MA MCL 400.10, .83 SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 FAP 7 CFR 272 7 CFR 273.2 7 CFR 273.8 7 CFR 273.12 7 CFR 273.16(i)(1),(2),(4) CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY All Programs The Michigan Department of Heath & Human Services (MDHHS) regularly matches recipient data with the Social Security Administration (SSA) through computer data exchange processes. Information provided with MDHHS applications (MDHHS-1010, - 4574, -4574-B, MDHHS-1171 and DCH-1426) inform clients of the data exchange process. SSA data exchanges assist in the verification of Social Security numbers (SSNs), Retirement, Survivors and Disability Insurance (RSDI), Supplemental Security Income (SSI) and Medicare benefits. OVERVIEW All Programs Data exchanges from SSA and the resulting reports include: • BENDEX (Beneficiary Data Exchange System) updates Bridges information on recipients of RSDI and Medicare benefits. • SDX (State Data Exchange) updates Bridges information on SSI recipients. • Enumeration Verification System matches SSNs entered on Bridges with SSNs on SSA records. • SOLQ (State Online Query) reports point in time information on RSDI, Medicare, and SSI. SDA and FAP 40 Qualifying Quarters displays Social Security credits.
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BENEFICIARY DATA EXCHANGE (BENDEX) All Programs BENDEX is the primary source for RSDI and Medicare benefit infor- mation. Each month, a BENDEX inquiry is sent to SSA on all new recipients. The Social Security Administration response includes any new or changed RSDI and Medicare benefits for that person. After the initial MDHHS inquiry, a BENDEX report is generated whenever RSDI or Medicare begins, changes or stops for active MDHHS recipients. Note: Black Lung Program data through 1973 is also shown. Later claims were processed by the Department of Labor & Economic Growth and do not appear on BENDEX. How BENDEX Works For every MDHHS recipient with a Social Security account number or claim number on Bridges, BENDEX cross-matches the name, Social Security number and date of birth against Social Security Administration's master beneficiary file. A discrepancy between Bridges and BENDEX information will result in no match. A match by claim number, if available, is attempted first because it is the most reliable. Therefore, when a MDHHS client is an RSDI recipient, enter the correct claim number in Bridges. SPECIALIST INQUIRIES TO SSA
State On-Line Query (SOLQ)
All Programs Specialist inquiries to SSA are requested through Bridges.
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Public Assistance Department Information Request When unable to reconcile discrepant information, send the DHS- 3471, DHS/SSA Referral, to the SSA district office serving your area. Limit its use to situations in which written and/or automated information sources differ on client benefits. For example: • To resolve a conflict between BENDEX and SDX or data and other evidence. • To obtain retroactive and/or historical data unavailable via BENDEX or SDX. • To refer a person potentially eligible for an SSA program. • To determine the status of a claim pending with SSA. STATE DATA EXCHANGE (SDX) All Programs The Social Security Administration provides daily SDX data on Michigan's SSI applications, denials, openings, reopenings, clo- sures, addresses and other changes. Central office uses this infor- mation to open and update MA program code A, B and E cases on Bridges. The Social Security Administration provides monthly SDX payroll data on SSI recipients living in Michigan. Central office uses this data to update the state SSI payment file which is used to issue state SSI payment warrants. ENUMERATION MATCH All Programs The ongoing effort to assign Social Security numbers is monitored by the Enumeration Verification System which validates Social Security account numbers entered on Bridges against SSA data.
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When an SSN is verified there will be a check mark in the Validated by SSA box on the Individual Information screen of Bridges. LEGAL BASE FIP 45 CFR 205.56-.58 MCL 400.83 MA MCL 400.10.,.83 SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 RCA 45 CFR 400.66 FAP 7 CFR 273.2 (f)(1)(r)(a) CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY FIP, SDA, CDC, MA, and FAP The Michigan Department of Health and Human Services (MDHHS) routinely matches recipient employment data with the Michigan Department of Labor and Economic Opportunity (LEO) and the Unemployment Insurance Agency (UIA) through computer data exchange processes. Information provided with MDHHS/MiLEAP applications (MDHHS-1010, -1171, -4574, -4574-B, and DCH- 1426) inform clients of the data exchange process. These data exchanges assist in the identification of potential current and past employment income. Unemployment Compensation Benefits (UCB) are automatically populated in Bridges. WAGE MATCH FIP, SDA, CDC, MA, and FAP MDHHS submits client Social Security Numbers to LEO quarterly to be cross matched with the work history records submitted by Michigan employers. This information is compared to the client’s gross earnings record in Bridges. Specialists receive one task and reminder listing all the matches for the quarter when there is a significant discrepancy between LEO and MDHHS records. The task and reminder is removed when all matches have been disposed of for the quarter. Bridges also compiles the wage match report, identifying overdue and disposed wage matches by county, unit, or other. This report is available under the left navigation inquiry/wage match reports. SPECIALIST ACTIONS
When to process FIP, SDA, CDC, and MA Wage match information must be resolved within 45 calendar days of receiving the wage match task and reminder. When a match is
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not disposed of within 45 days, the task and reminder is escalated to the specialist’s supervisor. FAP The wage match information is held and addressed at the next semi-annual, mid-certification or redetermination (whichever comes first).
Reconciling Discrepancies FIP, SDA, CDC, MA, and FAP Reconcile each match on the alert by verifying the client’s work his- tory stated on the application or other information in the client’s case record. Compare that with the wage match information to resolve the following: • Is the person reported by LEO the MDHHS client? • Was the client required to report earnings? • Were the earnings already reported to MDHHS? • Is a referral to the overpayment establishment analyst needed to pursue an overpayment ? If there is a discrepancy, request verification from the client. FAP Only If FAP is active with another program and the wage match information is returned, it can be acted on. However, FAP cannot be closed for failure to provide the wage match information if the match is held. Verifying Earned Income Request verification of the wage match earnings by generating a DHS-4638, Wage Match Client Notice, from Bridges. The DHS- 4638 automatically gives the client 30 days to provide verification. UCB Match Alert Dispose of each recipient identified on the wage match alert.
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Case Actions When income from the wage match is verified and is continuing, make the appropriate changes in Bridges, then run Eligibility Deter- mination Benefit Calculation (EDBC) to reduce or close the benefits. Exception: For CDC only, do not reduce benefits or close the Eligibility Determination Group (EDG) unless the gross income exceeds the income eligibility scale in RFT 270, CDC Income Eligibility Scale And Provider Rates, and is expected to last more than six months; see temporary excess income in BEM 505, Prospective Budgeting/Income Change Processing. Failure to Provide If verifications are not returned by the 30th day, case action will need to be initiated to close the case in Bridges. If the client reapplies, the date the client reapplies determines if the wage match notification must be returned before processing the new application. See the following examples. Example: Ms. Madison applies for assistance 30 days after case closure was initiated in Bridges. The wage match verification must be returned before processing the application. The case can be opened after verifications are provided. See BAM 117, FAP Expedited Service, for cases meeting expedited criteria. Example: Ms. Madison applies for assistance 31 days after the case closure was initiated in Bridges. Her case may be opened without wage match verification from the date of the new application, if eligible. Exception: For CDC Only, do not close the CDC EDG or reduce benefits if a CDC recipient fails to return Wage Match information. OVERPAYMENT ESTABLISHMENT ANALYST ACTION FIP, SDA, MA, and FAP If the household and employer fail to provide verification of actual earnings, the overpayment establishment analyst is to use the income shown on the wage match report to calculate the overpayment.
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Average the income over the time period reported on the wage match report to determine a monthly income amount. Follow the guidelines below: • Use the first day of the first month covered by the wage match report as the date the client knew of the change. If there is more than one wage match report for the overpayment, use the first day of the first report period. • Use the IG-011 Employee Wage History by Recipient ID, report when the wage match does not cover all time periods. • Follow policy for either change reporting or simplified reporting depending on the reporting status of the household. • Notify the household of its right to request an administrative hearing or provide actual income verification by checking the box provided on the DHS-4358B, Overissuance Summary. • If actual income verification is provided, recalculate the overpayment. Wage match reports that identify the Michigan Department of Health and Human Services (MDHHS) as the employer are adult home help provider earnings. Payment information can be found on Bridges by accessing consolidated inquiry for the recipient. UNEMPLOYMENT COMPENSATION BENEFITS FIP, SDA, MA, and FAP MDHHS receives a weekly file from Michigan UIA containing UCB payments distributed to MDHHS clients. Bridges populates Michigan UCB income automatically. If a file is received for an individual who does not have an existing unearned income record for Michigan UCB in Bridges, one will be created. The circumstance start/change date (CSCD) will be equal to the payment date. The period start date will equal the payment date minus three calendar days, and the pay detail will be entered and marked as yes to include in projections when the payment is for only a two-week period. Mass update will be triggered so the eligibility determination benefit calculation (EDBC) results will then be certified. Out-of-state UCB income is not automated and must be entered as other unearned income.
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A specialist must enter UCB income at application. If the automatic update determines a different UCB amount, Bridges will calculate a new CSCD period start date and enter the new pay detail. The population of Michigan UCB income in Bridges will automati- cally stop when all extensions are exhausted. Clients must report if UCB ends before all extensions are exhausted within 10 days. If the client fails to report UCB ending in a timely manner, a supplement cannot be issued. LEGAL BASE FIP 45 CFR 205.56-.58 MCL 400.83 MA MCL 400.10, .83 SDA Annual Appropriations Act Mich Admin Code, R 400.3151-400.3180 MCL 400.10, .83
FAP 7 CFR 273.2(f)(9) 7 CFR 272.8 Michigan Claims Plan MCL 400.10, .83
CDC
The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99 Social Security Act, as amended 2016
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BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
DEPARTMENT POLICY FIP, SDA, MA and FAP The Michigan Department of Health and Human Services (MDHHS) is required to match income information reported by third parties to IRS for all FIP, SDA, MA and FAP recipients. The data is compared to earned and unearned income for the recipient. This occurs at application and prior to each redetermination. Information provided with MDHHS applications (MDHHS-1010, - DHS-4574, DHS- 4574B, DCH-1426 and MDHHS-1171 inform clients of the data exchange process. OVERVIEW FIP, SDA, MA and FAP MDHHS conducts two data exchange processes with IRS. When a data match occurs, applicants or recipients are sent a notice informing them of the data obtained, the source and further instruction that MDHHS will be contacting them. IRS PENALTIES FIP, SDA, MA and FAP The Internal Revenue Code contains criminal and civil penalties for unauthorized disclosure of tax return information: • Per Section 7213(a), unauthorized disclosure of a federal tax return or return information is punishable by a $5,000 fine and/or 5 years imprisonment; see EXHIBIT I in this item. • Per Section 7431, such disclosure is also subject to a lawsuit, including punitive damages if the disclosure is willful or caused by gross neglect; see EXHIBIT II in this item. These criminal and civil penalties apply even after leaving MDHHS employment. IRS tape match information is always confidential whether or not the client has signed the release of information and should never be distributed by any means including email or fax for any reason.
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UNEARNED INCOME MATCH FIP, SDA, MA and FAP The IRS Unearned Income Match compares MDHHS recipient data with unearned income reported to IRS from sources such as bank account interest, lottery winnings and government subsidies. When the data exchange results in a recipient match, the client is sent a DHS-4487A, Unearned Income Notice, for applicants and DHS- 4487 for active recipients. Applicants FIP, SDA, MA and FAP The DHS-4487A is mailed to applicants upon receipt of IRS data. A task/reminder is sent which identifies the applicant who received the notice. Active Recipients FIP, SDA, MA and FAP The DHS-4487 is mailed during the month prior to the redetermina- tion month for active recipients when a match is found with IRS. A task/reminder is sent which identifies the client who received the notice. WAGE AND PENSION MATCH FIP, SDA, MA, (except for Healthy Kids) and FAP The IRS Wage and Pension Match compares MDHHS recipient data with unearned income reported to IRS from sources such as agricultural and military pensions, unemployment compensation, self-employment and annualized out-of-state wages. When a match is found on the Wage and Pension Match, the client is sent a DHS-4033, Tape Match Income Notice, in the month of August. A task/reminder is sent which identifies the client who received the notice.
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CLIENT NOTICE FIP, SDA, MA and FAP One notice is sent which includes each source of income that is reported for the recipient. The number of pages mailed to the group is shown at the top of each notice (such as page 1 of 3). Each notice contains the following information: • Recipient-identifying information. • Name and address of third-party source reporting the income. • Type and amount of income reported. • Tax year for which the income was reported. • Instructions to submit verification to his/her specialist. The notice also informs the client that failure to provide the required information may result in benefit denial, reduction or closure. SPECIALIST PROCESSING OF IRS MATCHES FIP, SDA, MA and FAP Upon receipt of a task/reminder indicating a match notice was sent, take the following actions: 1. Request the client return all supporting verification. 2. When the client returns the notice, determine if additional verifications are needed. If so, have client sign the DHS-20, Verification of Assets, to allow for release of information from the institution on the notice. 3. If a notice is returned to the local office: • Send the form to the designated staff person (DSP) for logging and destruction. • Document in the case record any actions taken regarding the notice. Note: If the specialist, rather than the client, completes the name and/or address of the institution on any document pertaining to the IRS match, it must be sent to the DSP to be logged and destroyed.
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4. If the client claims a notice was lost or never received, or if you need a copy, the DSP can reproduce a copy for the client or you; see Obtaining IRS Notice Copies in this item. 5. The client must verify the information on the notice. • If the client cannot verify the notice information, have the client enter the name and address of the third-party source and sign a DHS-20, Verification of Assets, to allow for release of information from the institution listed on the notice. • If the client refuses to verify the information, use appropriate Bridges Eligibility Manuals and Bridges Administrative Manuals procedures to deny or close the case or reduce benefits. Note: FAP only cases can only be addressed at the next redetermination/semi-annual contact or mid-certification. If FAP is active with another program and the match information is returned, it can be acted on. However, FAP cannot be closed for failure to provide the match information if the match is held.
VERIFICATIONS FIP, SDA, MA and FAP Information on IRS match notices is unverified. Do not take a neg- ative action based solely on that information. Seek verifications from the client or third party which establish fac- tors such as the following: • Time period involved. • The asset that generated the income. • Whether the asset and/or income was available to the client. When verification is unavailable to both you and the client, use the best available information to determine current eligibility and docu- ment in the case record. Once verification is received, use appropriate BEM and BAM pro- cessing procedures to determine past and current eligibility, benefit denial/closure/reduction.
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FILING THE CLIENT NOTICE AND THIRD- PARTY VERIFICATIONS FIP, SDA, MA and FAP Do not file the match notice in the case record. It must be treated as confidential and returned to the designated staff person; see Safeguarding IRS Information. The verification received from the third party is not considered IRS confidential information if the client filled out the name and address of the institution and should be filed in the case record. If the spe- cialist fills out the name and/or address of the institution on any document pertaining to the IRS match, then it must be sent to the DSP to be logged and destroyed. SAFEGUARDING IRS INFORMATION FIP, SDA, MA and FAP The local office or any other office holding these notices must do all the following: • Appoint a DSP to be responsible for the security of notices (safeguarding, release, destruction and log maintenance). • Keep each notice to be retained in a locked place (for example, in a drawer or cabinet). When it is destroyed, destruction must be done by MDHHS staff and only by shredding. • Keep visitor log to authenticate visitors before authorizing access to the area where the notices are kept. Visitor log shall contain the following information: Name and organization of visitor. Signature of visitor. Form of identification. Date of access. Time of entry and departure. Purpose of visit. • Develop and follow procedures to ensure notices are not released.
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DSP Duties FIP, SDA, MA and FAP Only the DSP may retain a key to the place housing the notices. The key must be kept in a locked place. Any duplicate key(s) must be kept in the office safe. The DSP must: • Print notices for specialist or clients as described in Obtaining IRS Notice Copies in this item. • Maintain a DHS-4488, Internal Revenue Service Data Control Sheet, to track notice copies released directly to specialists, clients, or mailed to the client. • Log all notices sent to the DSP (undeliverable, forwarded or returned from specialists) on the DHS-4488 and treat them as confidential. Shred all notices returned and log the method and date of destruction. The DHS-4488 must be retained for five years after the last notice is logged on it. It may then be destroyed by MDHHS staff and only by shredding. OBTAINING IRS NOTICE COPIES FIP, SDA, MA and FAP A copy of the notice may be obtained under certain circumstances from the DSP. Request for Duplicate IRS Notice If a client, his representative or a specialist requests a replacement of an IRS notice (for example lost or never received the original); the DSP can reprint through Central Print or Local Print from Bridges correspondence. When the copy is printed locally, the DSP must: • Log on DHS-4488.
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• Hand-deliver it and request ID to ensure the appropriate client or representative or specialist receives the information. REPORTING UNAUTHORIZED FEDERAL TAX INFORMATION (FTI) ACCESS Upon discovery of a possible improper inspection or disclosure of federal tax information by a federal employee, a state employee or any other person, the individual making the observation or receiving information should, within 24 hours: 1. Contact the office of the appropriate Special Agent in Charge at the Field Division of Treasury Inspector General for Tax Administration (TIGTA). Field Division State Served by Field Division Telephone Chicago Michigan 312-554-8751
The mailing address is: Treasury Inspector General for Tax Administration PO Box 589, Ben Franklin Station Washington, DC 20044-0589 2. Take appropriate steps to contain the incident, if still in process. If uncertain what steps need to be taken to contain the incident, go directly to step 3. 3. Contact the MDHHS Compliance Office at 517-284-1018 to report the incident. Ask for the MDHHS information security officer and identify the purpose of the call as a report of breach of information. 4. Complete form DHS-0097, Breach of Federal Taxpayer Information Incident Report, as fully as possible and email the form to DHS-FTI-Disclosure@michigan.gov.
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EXHIBIT I – IRC SEC. 7213 UNAUTHORIZED DISCLOSURE OF INFORMATION (a) RETURNS AND RETURN INFORMATION.
(1) FEDERAL EMPLOYEES AND OTHER PERSONS.-It shall be unlawful for any officer or employee of the United States or any person described in section 6103(n) (or an officer or employee of any such person), or any former officer or employee, willfully to disclose to any person, except as authorized in this title, any return or return information [as defined in section [6103(b)]. Any violation of this paragraph shall be a felony punishable upon conviction by a fine in any amount not exceeding $5,000, or imprisonment of not more than 5 years, or both, together with the costs of prosecution, and if such offense is committed by any officer or employee of the United States, he shall, in addition to any other punishment, be dis- missed from office or discharged from employment upon conviction for such offense.
(2) STATE AND OTHER EMPLOYEES.-It shall be unlawful for any person [not described in paragraph (1)] willfully to disclose to any person, except as authorized in this title, any return or return information [as defined in section 6103(b)] acquired by him or another person under subsection (d), (i)(3)(B)(i), (1)(6), (7), (8), (9), (10), (12), (15) and (16) or (m)(2), (4), (5), (6), or (7) of section 6103. Any violation of this paragraph shall be a felony punishable by a fine in any amount not exceeding $4,000, or imprisonment of not more than 5 years, or both, together with the cost of prosecution.
(3) OTHER PERSONS.- It shall be unlawful for any person to whom any return or return information [as defined in section 6103(b)] is disclosed in a manner unauthorized by this title thereafter willfully to print or publish in any manner not provided by law any such return or return information. Any violation of this paragraph shall be a felony punishable by a fine in any amount not exceeding $5,000, or imprisonment of not more than 5 years, or both, together with the cost of prosecution.
(4) SOLICITATION.-It shall be unlawful for any person willfully to offer any item of material value in exchange for any return or return information [as defined in 6103(b)] and to receive as a result
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of such solicitation any such return or return information. Any viola- tion of this paragraph shall be a felony punishable by a fine in any amount not exceeding $5,000, or imprisonment of not more than 5 years, or both, together with the cost of prosecution.
(5) SHAREHOLDERS.--It shall be unlawful for any person to whom return or return information [as defined in 6103(b)] is dis- closed pursuant to the provisions of 6103(e)(1)(D)(iii) willfully to dis- close such return or return information in any manner not provided by law. Any violation of this paragraph shall be a felony punishable by a fine in any amount not exceeding $3,000, or imprisonment of no more than 5 years, or both, together with the cost or prosecu- tion. SEC. 7213A. UNAUTHORIZED INSPECTION OF RETURNS OR RETURN INFORMATION (a) PROHIBITIONS.-
(1) FEDERAL EMPLOYEES AND OTHER PERSONS.-It shall be unlawful for-
(A) any officer or employee of the United States, or
(B) any person described in section 6103(n) or an officer willfully to inspect, except as authorized in this title, any return or return information
(2) STATE AND OTHER EMPLOYEES.-It shall be unlawful for any person [not described in paragraph (1)] willfully to inspect, except as authorized by this title, any return information acquired by such person or another person under a provision of section 6103 referred to in section 7213(a)(2). (b) PENALTY.-
(1) IN GENERAL.-Any violation of subsection (a) shall be punishable upon conviction by a fine of any amount not exceeding $1,000, or imprisonment of not more than 1 year, or both, together with the costs of prosecution.
(2) FEDERAL OFFICERS OR EMPLOYEES.-An officer or employee of the United States who is convicted of any violation of
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subsection (a) shall, in addition to any other punishment, be dis- missed from office or discharged from employment. (c) DEFINITIONS.-For purposes of this section, the terms “inspect”, “return”, and “return information” have respective earnings given such terms by section 6103(b). EXHIBIT II - IRC SEC.7431 CIVIL DAMAGES FOR UNAUTHORIZED DISCLOSURE OF RETURNS AND RETURN INFORMATION (a) IN GENERAL.-
(1) INSPECTION OR DISCLOSURE BY EMPLOYEE OF UNITED STATES.-If any officer or employee of the United States knowingly, or by reason of negligence, inspects or discloses any return or return information with respect to a taxpayer in violation of any provision of section 6103, such taxpayer may bring a civil action for damages against the United States in a district court of the United States.
(2) INSPECTION OR DISCLOSURE BY A PERSON WHO IS NOT AN EMPLOYEE OF UNITED STATES.-If any person who is not an officer or employee of the United States knowingly, or by reason of negligence, inspects or discloses any return or return information with respect to a taxpayer in violation of any provision of section 6103, such taxpayer may bring a civil action for damages against such person in a district court of the United States. (b) EXCEPTIONS.-No liability shall arise under this section with respect to any inspection or disclosure-
(1) which results from good faith, but erroneous, interpretation of section 6103, or
(2) which is requested by the taxpayer. (c) DAMAGES.-In any action brought under subsection (a), upon a finding of liability on the part of the defendant, the defendant shall be liable to the plaintiff in an amount equal to the sum of-
(1) the greater of-
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(A) $1,000 for each act of unauthorized inspection or disclosure of a return or return information with respect to which such defendant is found liable, or
(B) the sum of-
(i) the actual damages sustained by the plaintiff as a result of such unauthorized inspection or disclosure, plus
(ii) in the case of a willful inspection or disclosure or an inspection or disclosure which is the result of gross negligence, punitive damages, plus
(2) the cost of the action. (d) PERIOD FOR BRING ACTION.-Not withstanding any other provision of law, an action to enforce any liability created under this section may be brought, without regard to the amount in contro- versy, at any time within 2 years after the date of discovery by the plaintiff of the unauthorized inspection or disclosure. (e) NOTIFICATION OF UNLAWFUL INSPECTION AND DISCLO- SURE.-If any person is criminally charged by indictment of informa- tion with inspection or disclosure of a taxpayer’s return or return information in violation of-
(1) paragraph (1) or (2) of section 7213(a),
(2) section 7213A9(a), or
(3) subparagraph (B) of section 1030(a)(2) of title 18, United States Code, the Secretary shall notify such taxpayer as soon as practicable of such inspection or disclosure. (f) DEFINITIONS.-For purposes of this section, the terms “inspect”, “inspection”, “return”, and “return information” have respective earnings given such terms by section 6103(b). (g) EXTENSION TO INFORMATION OBTAINED UNDER SEC- TION 3406.-For purposes of this section-
(1) any information obtained under section 3406 (including information with respect to any payee certification failure under sub- section (d) thereof) shall be treated as return information, and
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(2) any inspection or use of such information other than for purposes of meeting any requirement under section 3406 or (sub- ject to the safeguards set forth in 6103) for purposes permitted under section 6103 shall be treated as a violation of section 6103. For purposes of subsection (b), the reference to section 6103 shall be treated as including a reference to section 3406. EXHIBIT III - SEC 6103(P)(4) SAFEGUARDS
(4) SAFEGUARDS.-Any federal agency described in subsec- tion (h)(2), (h)(5), (i)(1), (2), (3), or (5), (j)(1), (2), or (5), (k)(8), (1)(1), (2), (3), (5), (10), (11), (13), (14), (15), or (17) or (o)(1), the Government Accountability Office, or any agency, body, or commission described in subsection (d), (i)(3) (B)(i) or (1)(6), (7), (8), (9), (12) or (15), or (16), or any other person described in subsection (1)(16) shall, as a condition for receiving returns or return information-
(A) establish and maintain, to the satisfaction of the Secretary, a permanent system of standardized records with respect to any request, the reason for such request, and the date of such request made by or of it and any disclosure of return or return information made by or to it;
(B) establish and maintain, to the satisfaction of the Secretary, a secure area or place in which such returns or return information shall be stored;
(C) restrict, to the satisfaction of the Secretary, access to the returns or return information only to persons whose duties or responsibilities require access and to whom disclosure may be made under the provisions of this title;
(D) provide such other safeguards with the Secretary determines (and which he prescribes in regulations) to be nec- essary or appropriate to protect the confidentiality of the returns and return information;
(E) furnish a report to the Secretary, at such time and containing such information as the Secretary may prescribe, which describes the procedures established and utilized by such agency, body, or commission or the Government Accountability Office for ensuring the confidentiality of returns and return information required by this paragraph; and
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(F) upon completion of use of such returns or return information-
(i) in the case of agency, body or commission described in subsection (d), (i)(3)(B)(i), or (1)(6), (7), (8), (9) or (16) or any other person described in subsection (1)(16) return to the Sec- retary such returns or return information (along with any copies made there from) or make such return information undisclos- able in any manner and furnish a written report to the Secretary describing such manner
(ii) in the case of an agency described in subsection (h)(2), (h)(5), (i)(1), (2), (3), or (5), (j)(1), (2), or (5), (1)(1), (2), (3), (5), (10), (11), (12), (13), (14), (15), or (17), or (o)(1), or the Government Accountability Office, either-
(1) return to the Secretary such returns or return information (along with any copies made there from)
(2) otherwise make such returns or return information undisclosable, or
(3) to the extent not so returned or made undisclosable, ensure that the conditions of subparagraphs (A), (B), (C), (D), and (E) of this paragraph continue to be met with respect to such returns or return information, and
(iii) in the case of the Department of Health and Human Services for purposes of subsection (m) (6), destroy all such return information upon completion of its use in providing the notification for which the information was obtained, so as to make such information undisclosable; except that conditions of subparagraph (A), (B), (C), (D), and (E) shall cease to apply with respect to any return or return information if, and to the extent that, such return or return information is dis- closed in the course of any judicial or administrative proceedings and made a part of the public record thereof. If the Secretary deter- mines that any such agency, body, or commission including an agency or any other person described in subsection (1)(16) or the Government Accountability Office has failed to, or does not, meet requirements of this paragraph, he may, after any proceedings for review established under paragraph (7), take such actions as are necessary to ensure such requirements are met, including refusing to disclose returns, or return information to such agency, body, or commission including an agency or any other person described in
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subsection (1)(16) or the Government Accountability Office until he determines that such requirements have been or will be met. In the case of any agency which receives any mailing address under paragraph (2), (4), (6) or (7) of subsection (m) and which discloses any such mailing address to any agent, or which receives any information under paragraph (6)(A), 12(B) or 16 of subsection (1) and which discloses any such information to any agent or any person including an agent described in subsection (1)(16) this paragraph shall apply to such agency and each such agent or other person (except that, in the case of an agent, or any person including an agent described in subsection (1)(16), any report to the Secretary or other action with respect to the Secretary shall be made or taken through such agency). For purposes of applying this paragraph in any case to which subsection (m)(6) applies, the term “return information” includes related blood donor records (as defined in section 114(h)(2) of the Social Security Act). LEGAL BASE FIP 45 CFR 205.56-.58 MCL 400.83 MA MCL 400.10,.83 SDA Annual Appropriations Act Mich Admin Code, R 400.3165
FAP 7 CFR 273.2 (f)(1)(r)(a)
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DEPARTMENT POLICY Family Independence Program (FIP), State Disability Assistance (SDA), Refugee Cash Assistance (RCA), Food Assistance (FAP) A person in a federal, state, or local correctional facility for more than 30 days is not eligible to receive FIP, SDA, RCA or FAP benefits. Child Development and Care (CDC) Close CDC if the only parent/substitute parent on the CDC case leaves the household (no longer resides with the authorized child) due to incarceration or other reason; see BAM 220, CDC EDG closure reasons. Medicaid (MA) A person can remain eligible for MA during a period of incarceration. Coverage is limited to inpatient hospital services only; see BEM 265. INCARCERATION MATCH DOC All Programs The automated Incarceration Match is a daily match between Department of Corrections (DOC) and Bridges. This match runs for all individuals who are active for any program whose current living arrangement is not prison. If a valid match is found, the interface will update living arrangement of the individual to prison with a prison type of Prison State and create a mass update trigger for all cases where the client is active. Eligibility will then be re-determined for all programs on the cases where the client is active. FIP, SDA, RCA and FAP In addition to updating the living arrangement and prison type, a MDHHS- 6017, Michigan Department of Corrections (MDOC) Incarceration Match Client Notice, will be sent to the group to verify if the group member is in a state prison, before member removal or case closure can be completed, if appropriate. FIP, SDA, RCA and
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FAP will pend for 10 days. Update the living arrangement page if needed and run EDBC. Eligibility will then be re-determined for FIP, SDA, RCA and FAP. Failure to Respond to Notice FIP, SDA and RCA If the verification is not returned, the system will create a mass update trigger for all cases where the client is active. Eligibility will then be re-determined for FIP, SDA and RCA. FAP Only Change reporting FAP groups that do not respond to the State Incarceration Match notice, will have their case closed following negative action rules. If a simplified reporting group does not respond to the State Incarceration Match notice by the due date listed on the notice, the individual on the match will be removed from the group following negative action rules. • If the individual on the State Incarceration Match is the only adult in the group, FAP will close. • If the individual on the State Incarceration Match is the head of household (HOH), the specialist will designate another adult in the FAP group as the HOH. • If the individual on the State Incarceration Match is the only individual in the Group, FAP will close.
Bad Match Process A bad match may occasionally occur. If a bad match is suspected a collateral contact with the client must be completed to verify this cli- ent is not in prison. An authorized person from the local office is to call in a help desk ticket indicating a bad incarceration match with the following infor- mation: • Client name.
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• Case number. • Client ID number. • Program(s) effected. • The release date from prison if the client was incarcerated. • The month(s) effected. The ticket will be assigned and flagged as a bad match and when the report runs for the following month the client's programs will not be affected. SSA PRISONER MATCH The quarterly prisoner match between the Social Security Adminis- tration and Bridges runs for individuals 16 years and older who are pending or active. When a match is found, a task and reminder will be sent to the specialist. Specialists are expected to act on this within 12 days. Be sure to update the living arrangement type to prison and the prison type to Prison SSA, if necessary and run EDBC. If no action is taken within 10 days, it will be escalated to the supervisor. FIP, SDA, RCA and FAP In addition to updating the living arrangement type and prison type, a MDHHS- 5909, Social Security Administration (SSA) Prisoner Match Client Notice, must be sent to the group to verify if the group member is in prison, before member removal or case closure can be completed, if appropriate. FIP, SDA, RCA and FAP will pend for 10 days. A task and reminder will be sent to the specialist after the 10 days. Update the living arrangement page if needed and run EDBC. Eligibility will then be re-determined for FIP, SDA, RCA and FAP. Failure to respond to notice FAP Only Change reporting FAP groups that do not respond to the SSA Prisoner Match notice, will have their case closed following negative action rules. If a simplified reporting group does not respond to the SSA Prisoner Match notice by the due date listed on the notice, the individual on the match will be removed from the group following negative action rules.
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• If the individual on the SSA Prisoner Match is the only adult in the group, FAP will close. • If the individual on the SSA Prisoner Match is the head of household (HOH), the specialist will designate another adult in the FAP group as the HOH. • If the individual on the SSA Prisoner Match is the only individual in the Group, FAP will close.
LOCAL CORRECTIONAL FACILITY Follow current county procedures for verifying an individual in a local facility using the DHS-48, Verification of Imprisonment, which is a manually generated Bridges form. Local Facility Verification Returned When the DHS-48 is returned from the local facility indicating the incarcerated individual is released or on parole, no further action is taken. If the DHS-48 is returned and the individual is still incarcerated change the living arrangement type to jail. Do not recoup FAP benefits for simplified reporters unless the department failed to take timely action. Local Facility Verification Not Returned If the DHS-48 is not returned by the local facility, verify the where- abouts of the incarcerated individual. Verify the recipient’s where- abouts by calling the facility or contact the head of household and ask for verification of the prisoner’s whereabouts. LEGAL BASE FIP 45 CFR 205.56-.58 MCL 400.83
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SDA Annual Appropriations Act Mich Admin Code, R 400.3165 RCA 45 CFR 400.66 CDC The Child Care and Development Block Grant (CCDBG) Act (42 USC § 9858 et seq.), as amended by the CCDBG Act of 2014 (Pub. L. 113-186). 45 CFR Parts 98 and 99. Social Security Act, as amended 2016.
MA
MCL 400.10,.83
FAP
7 CFR 273.2 (f)(9)
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DEPARTMENT POLICY Family Independence Program (FIP), State Disability Assistance (SDA) and Medicaid (MA) Only Michigan law allows a person to contract and pay in advance for a funeral. This is called a prepaid funeral contract; see BEM 400. In this item, the act refers to MCL 328.211. General provisions of the act are as follows: • The contract seller is the person/establishment providing the prepaid funeral contract. The seller may be the funeral provider. • The funeral provider is the person/establishment shown in the prepaid funeral contract as agreeing to furnish specified funeral goods and/or services. The provider need not be a party to the contract. • Contract sellers and funeral providers must be registered with the Michigan Department of Licensing and Regulatory Affairs (LARA). • The purchaser, beneficiary, funeral provider and/or contract seller decide what funeral goods and services are contracted for. • Only a guaranteed price contract may be certified irrevocable. • Only the Michigan Department of Health and Human Services (MDHHS) may certify a funeral contract irrevocable by completing a DHS 8-A, Irrevocable Funeral Contract Certification. • Amounts paid for contracted funeral goods and services may be reallocated to other funeral goods and services. However, an irrevocable contract cannot be terminated. • Interest or dividends earned on an irrevocable contract fund are considered part of that fund and may not be given to the purchaser/beneficiary.
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• A DHS-8A, Irrevocable Funeral Contract Certification, cannot be used to certify a life insurance funded funeral or annuity funded funeral as irrevocable. • Transfers of a funeral contract with an 8A must be purchased as a prepaid guaranteed price contract with the funeral provider. TYPES OF MICHIGAN FUNERAL CONTRACTS A guaranteed price contract fixes the price to be charged for funeral goods and services listed in the contract. A non-guaranteed price contract states clearly that the price of listed goods and services might fluctuate. Actual costs at delivery might be more or less than the amount in the contract fund. A revocable contract can be terminated by the purchaser and the money refunded. The refund might be less than the contract's total value. A contract is revocable unless certified irrevocable by DHS using the DHS 8-A. For program eligibility purposes, an irrevocable contract means money in the contract fund, including interest or dividends, is permanently unavailable to the purchaser/beneficiary; see conditions to certify contracts irrevocable in this item. OUT-OF-STATE FUNERAL CONTRACTS MDHHS can certify as irrevocable a funeral contract with an out-of- state contract seller or funeral provider only if the seller and provider (if separate) are registered with the Michigan Department of Licensing and Regulatory Affairs. If they are, see conditions to certify contracts irrevocable in this item. A prepaid funeral contract with an unregistered out-of-state seller or provider is controlled by the other state's laws. The contract funds are unavailable if the contract is irrevocable under the other state's law. Assist clients needing help to determine the status of out-of-state contracts. Inform them that revocable contracts with unregistered
BAM 805 3 of 6 PREPAID FUNERAL CONTRACTS BPB 2026-015 6-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
individuals may be reestablished using sellers/providers registered with the Michigan Department of Labor and Economic Growth. Local Office Responsibilities Tell the applicant/recipient in order to certify a funeral agreement as irrevocable they and their funeral director must complete a DHS 8- A (available on the internet or through the funeral director) and return the completed form to the local office. Tell them they must: • Complete Section I, and • Have the contract seller complete Section II, and • Give DHS a copy of the contract. Forward the returned DHS-8A and contract to the local office director or designee for certification (completion of Section III). If a disapproval is necessary, it must be explained on that form. A photocopy, email copy, or facsimile (fax) of a DHS-8A is acceptable. SSI clients might be referred to DHS to have a contract certified irrevocable. The local office must act on these requests as soon as possible. Note: Funeral contracts certified irrevocable are treated as unavailable assets for SSI. CONDITIONS TO CERTIFY CONTRACTS IRREVOCABLE A prepaid funeral contract(s) must be certified irrevocable, provided all of the requirements below are met: 1. The contract purchaser requests via DHS-8A that the contract be certified irrevocable. 2. The contract purchaser is • The beneficiary, and • Alive, and • A FIP/SDA/MA/SSI applicant or recipient.
BAM 805 4 of 6 PREPAID FUNERAL CONTRACTS BPB 2026-015 6-1-2026
BRIDGES ADMINISTRATIVE MANUAL STATE OF MICHIGAN DEPARTMENT OF HEALTH & HUMAN SERVICES
Note: Someone else may act as purchaser for a living beneficiary if the beneficiary’s own money is used. The beneficiary’s name must follow the person's signature on the DHS-8A (for example, John Smith for Sara Smith). 3. MDHHS has a copy of the contract. 4. The principal value(s) (such as amount paid at the time the contract was made, excluding interest or dividends) is not over the Allowable Principal Value explained below. • A revocable contract(s) with a principal value over the maximum may be ended and a new contract made which can be certified irrevocable. The excess, including interest and/or dividends, is a countable asset. • Multiple contracts for a beneficiary may be certified irrevocable if the combined principal values are not over the maximum. Note: The limit is not affected by the types of goods and services contracted for. For example, the value of burial space items is not deducted to decide if the principal value is within the limit. 5. Sections I and II of the DHS-8A are properly completed. This ensures the following: • The purchaser/beneficiary has notice of limits on state liability for additional funeral expenses. Covered expenses are included in ERM 306. • The purchaser/beneficiary has notice that an irrevocable contract remains irrevocable even if assistance ends. • The contract seller asserts that the contract is a guaranteed price contract and complies with the act. • The contract seller is registered with the Michigan Department of Licensing and Regulatory Affairs (LARA). Note: An employer's registration covers his employees. The employer's registration number may be entered in Section II of the DHS-8A. • The contract seller certifies that all funeral providers listed in, or party to, the contract are registered with the
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