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financial services, or insurance broker, home health or other service provider, public or private auditor, public accountant, actuary, or attorney. D. Any transfer that involves a promise to provide future payments or services is considered a disqualifying transfer of assets for less than fair market value if the State is unable to discern the FMV or if the transaction is not embodied in a valid contract that is legally and reasonably enforceable by the applicant, member, or spouse. E. The treatment of income or resources resulting from both allowable and disqualifying transfers is considered in the financial eligibility determination process. For disqualifying transfers, increases in the countable income and resources of the otherwise eligible LTSS recipient resulting from the transfer, or any subsequent transactions, may affect access to other non-LTSS forms of Medicaid during the penalty period or Medicaid LTSS eligibility once the penalty period expires. Redetermination of financial eligibility before Medicaid LTSS coverage begins may be required. F. When conducting the initial financial eligibility determination for Medicaid LTSS, and at the time of renewal, the State examines the value of assets on the first (1st) and last day of each month to identify transfers that may be disqualifying and subject to a penalty. In accordance with 42 U.S.C. § 1396w, an electronic asset verification system is used along with city property assessments, tax rolls and financial and legal documents during this review and verification process. G. A Medicaid LTSS beneficiary is required to report changes in assets in the interim between renewals within ten (10) days from the date the change occurs. Timely determinations of financial eligibility require that applicants provide all information and documentation requested at the time of application and during the period of review in accordance with the requirements set forth in Part 4 of this Subchapter. 6.6.1 Penalty Periods A. The State establishes a penalty for disqualifying transfers made during the look- back period. The penalty is a period of Medicaid LTSS ineligibility. During the penalty period, the State does not pay for LTSS provided in a health institution such as a nursing facility, or at home, or in a community setting, including community residences for people with intellectual/developmental disabilities, and shared living and assisted living residences. This provision does not impact eligibility for non-LTSS services such as physician, hospital, and other medical services. B. The look-back period and date a penalty period begins is a function of when a person applied for and began receiving Medicaid LTSS and several other factors as follows: