Beginning this year, AHCCCS started using Accuity Asset Verification Services, Inc.’s asset verification system (AVS) to streamline the asset verification process of Arizona Long Term Care System (ALTCS) applications for long term care benefits. The contract allows financial institutions to transmit an applicant’s account balance to Acuity AVS for verification. The goal, of course, is for AHCCCS to independently obtain and confirm financial information and to reduce opportunity for fraud. This new system, however, can also create unexpected difficulties for the applicant/authorized representative. If you thought processing an application was difficult and time consuming before, it will be more difficult now in many cases.

In short, AHCCCS is using this system to review the last 5 years (60 months) of financial records of ALTCS applicants. The challenge is that the report, which AHCCCS will not give you, does not accurately identify individual deposits and withdrawals by date and specific amount. This system reviews patterns in accounts, even closed accounts. If there is a difference of more than $2,000.00 between the high and the low monthly account balance the AVS generates a report with the differential amount and a date during that period. The AHCCCS eligibility worker then asks for a detailed explanation of the amount(s) in question. If there is no response to this request for information within 10 days or if the last 60 months of financial activity cannot be verified the eligibility worker can deny the application.

What does this mean for you? Let’s say your father was handling his own financial matters until his recent disabling stroke.  You are now handling his financial matters and submit an ALTCS application. If three years prior he closed a bank account with balance of $9,872.13 and you cannot trace where all the proceeds were deposited your application may be denied, or potentially approved with a penalty period. Worse yet, let’s say AHCCCS asks you to explain an alleged withdrawal of $10,515.42 on January 3, 2017, and $8,363.15 deposit on March 18, 2018.  The specific inquiries may not equate to any deposits/withdrawal(s) on that date in the stated amounts. Rather, the amount in question is the difference between the high and low balance. You will have to explain all deposits (including source) and all withdrawals (including payee and purpose of purchase/withdrawal) during that period and back your way into the request for information and verify all transactions with bank and financial records. If your father is no longer competent, didn’t keep good records, and/or does not recall the specific transactions from years ago, how would you explain them?

By AHCCCS’ own estimates, over 70% of ALTCS applications are denied for numerous reasons, whether medical or financial. Now, it will certainly be more difficult without proper legal counsel and guidance. If you do not have the last five years (60) months of financial records, including receipts, cancelled checks, invoices paid, or similar records, verification will certainly take more than the standard allotted 10 days response time. In cases where withdrawals cannot be adequately explained and verified, ALTCS may presume there was an uncompensated transfer and delay ALTCS benefits, until after expiration of the resulting penalty period. If you are considering applying for ALTCS benefits, we are here to help!

-Stephanie Bivens, Esq.