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If the member-reported earnings amount is not reasonably compatible (based on the household’s total reported income), verification of earnings will be required at the same time verification is required for unearned income, self-employment, and/or tax deductions. A second verification request will be required if the initial test leads to a determination of reasonable compatibility but the earnings are no longer reasonably compatible after other income types or deductions have been verified. If earnings are determined to be reasonably compatible, the amount reported by the member should be used to determine eligibility and premium amounts for health care. If the earnings are later verified (for example, because verification is required for another program), the verified earnings must be used to determine eligibility and premium amounts for health care. See SECTION 22.2.1.2.4 ELIGIBILITY AND PREMIUM DETERMINATIONS BASED ON REASONABLE COMPATIBILITY for information about when members with eligibility or premium determinations based on income that was reasonably compatible can be subject to overpayments. 20.3.8.1.4 Use of Equifax Data for Verification of Income If Equifax data is available for a given employment, and the Equifax amount is the same as the amount reported by the applicant or member, the earned income must be considered verified. Earned income that is verified is not subject to a reasonable compatibility test. If the amount reported by the applicant or member is not the same as the Equifax amount, the earned income is not considered verified. The reasonable compatibility test is completed for earned income that has not otherwise been verified. If the amount reported by the applicant or member is not reasonably compatible, the applicant or member is required to provide verification of earned income. IM agencies must assist the applicant or member in obtaining verification if they request help or tell their agency that they are having difficulty obtaining it (see SECTION 20.1.4 GENERAL RULES).

If the applicant/member and/or worker have made reasonable efforts to obtain verification and are not able to do so, then the agency should determine the income amount based on “best available” information and then document how this amount was determined. Health care benefits cannot be denied or terminated based on earned income data received from Equifax without giving the applicant or member an opportunity to verify their reported earned income amount. Note The same policy applies when a member is reporting a change in earned income. If the Equifax amount is the same as the amount reported by the member, the earned income must be considered verified.

Example 5 Anya applies for health care for herself. She is 65 years old but does not yet receive Social Security income. The only income she reports is earned income. The monthly earned income amount she reports is different than the monthly earned income amount returned by Equifax, so earned income is not considered verified and the reasonable compatibility test occurs. The earned income amount