QIT Update. July 28, 2016

Transcription

1 QIT Update July 28, 2016

2 CMS Approval CMS finally approved Ohio s proposal to change to a 1634 state According to ODM, the proposed deferral of the QIT requirement for existing Medicaid LTSS beneficiaries is routed for signature

3 Timing Reminders Only new Medicaid LTSS applicants who apply on or after August 1, 2016, and who are over income ($2,199) need a QIT immediately Any current Medicaid LTSS beneficiaries or pending applicants as of August 1 have the QIT requirement deferred until their redetermination date in 2017 Monitor patient income going forward - a Medicaid beneficiary whose income increases after August 1 from below the SIL to above it must get a QIT immediately We are still trying to determine if there are any circumstances that cause a person who is already over the SIL to lose the deferral and need a QIT See the ODM timeline for a graphic representation:

4 New Questions & Answers Document News Q&A document posted to the OHCA website at s%207%2020%2016%20(002).pdf It is largely based on OHCA s FAQ plus various other questions we asked ODM separately ODM reviewed, edited, and endorsed the new Q&A It contains extensive information about all aspects of the QIT requirement We expect this document to continue to evolve

5 QIT Verification Form The verification form is available on the OHCA website at It is not a required form, but it is a convenient way of gathering information that must be reported to the county for Medicaid eligibility Submit both the form and a copy of the QIT to the caseworker

6 New QIT Template The new template is available on the OHCA website at The template is not mandatory a QIT is valid if it meets the requirements of the now-final ODM rule on QITs ( 03$2_FF_N_RU_ _0953.pdf) The changes are designed to provide clarification and comfort to banks that are asked to set up a QIT account Includes an additional page for this purpose: Certification of Trust If the center holds the account, these changes are irrelevant The original template is still valid

7 A Simple QIT Process As soon as a patient/potential patient s need for Medicaid arises, determine their gross income If their income is over the SIL, give them the QIT template and help them complete and sign it Unless the individual wants someone else, designate the center as the trustee in the QIT Collect from the patient at least the portion of their income for that month that exceeds the SIL Create a QIT account for the person in your resident funds accounting system (separate from their personal account) Give a copy of the QIT and the verification form to the county caseworker If the QIT is not established in time and there is an eligibility gap, apply for past medical (Act 52)

8 The Incompetent Patient ODM s perspective: if a person has not been declared incompetent by a court of law, they are competent Is there a legal guardian? Is there a power of attorney that gives the attorney-in-fact the authority to execute trusts (does not need to specify QITs)? Can the individual sign the QIT with help? Possible last resort: someone else creates the QIT as the grantor, with the patient as the primary beneficiary

9 The QIT Account We recommend encouraging residents to maintain their QIT account with the facility We are not aware of anything that would preclude using a combined resident funds account for both the PNA account and the QIT account, so long as a detailed accounting is maintained Remember, at minimum, the income over the SIL must be deposited/allocated to the resident QIT account with payments made for only the prescribed purposes in rule In most cases, the QIT account should have a zero balance at month end The certification regulations requiring an interest-bearing account apply to residents personal funds, which probably do not include the QIT account

10 Tax Issues A tax identification number (EIN) is not needed An IRS form 1041 is not required if the QIT does not generate interest income, although OHCA legal counsel suggests filing an informational return

11 We are Available for Questions Now and After August 1! Diane Dietz: Debbie Jenkins: Pete Van Runkle: