6
month. In some cases, results might need to be returned by fax or mail, which can take longer and be more
difficult for states to process automatically. These challenges seem to be more common with smaller banks
and credit unions than with larger institutions (Musumeci et al. 2022, Erzouki and Wagner 2021, MACPAC
2020).
• Limited AVS participation among financial institutions and gaps in the types of assets detected by
AVS require many non-MAGI beneficiaries to provide asset documentation. Financial institutions are not
required to report information on Medicaid applicants’ assets. When financial institutions refuse to participate
in an AVS, states might not be able to verify all asset information and have to ask beneficiaries to respond to
a renewal notice (MACPAC 2020). Roundtable participants mentioned that AVS participation is typically
limited to banks and credit unions. In addition, bank account information returned by AVS does not provide
the kind of transactional details necessary for states to determine whether any of the funds in a particular
account are from an income source that should be excluded.
14
Participants from two states also
acknowledged that a major challenge is verifying assets that the AVS cannot verify, either because the asset
is a type that is not in an AVS (e.g., life insurance) or because the asset is held by a non-participating bank.
As a result, the state must ask the beneficiary for documentation of those assets, which can be burdensome
for the beneficiary and often requires help from assisters or professional benefits counselors in gathering
documentation to comply with state requests. It can also result in loss of eligibility if the beneficiary cannot
comply with the state’s request.
• Beneficiary consent and inaccurate matches can also increase the burden of AVS. An IT vendor who
has worked with multiple states noted that some states have faced challenges using AVS with certain
beneficiary populations (particularly those who move from a MAGI eligibility group into a non-MAGI eligibility
group) due to a federal requirement that beneficiaries must consent to state use of AVS to verify assets.
15
In
addition, two states and a beneficiary advocate noted that false AVS matches, for example, from situations in
which a beneficiary is listed as a secondary name on an account, can result in inaccurate asset information
for beneficiaries. These inaccurate results can be particularly cumbersome to navigate, as it can be difficult
and time-consuming for beneficiaries to prove that they do not own specific assets. These inaccurate matches
can also lead to inappropriate loss of benefits in cases where misidentified assets appear to make the
beneficiary ineligible for Medicaid.
Despite the limitations of AVS, roundtable participants agreed that AVS is an important tool, as it is the only
means to electronically verify assets and process ex parte renewals for non-MAGI beneficiaries. Most participants
also agreed that ongoing exploration of ways to improve the asset verification process is important (Box 2).
Individuals with income that is difficult to verify electronically
Income verification remains a barrier for those with zero or unstable incomes, such as individuals who are self-
employed, seasonally employed, or frequently change jobs. In these cases, income may not be able to be
confirmed with electronic income data sources due to a lack of data, data lags, or other limitations (SHADAC
2020). Verifying zero income via electronic sources is particularly difficult because a lack of data cannot be
assumed to indicate that an individual does not have any income.
16
Verifying self-employment income is typically
done through state income tax or IRS data. However, roundtable participants confirmed that IRS data are often
one to two years old, so it can be of limited use when beneficiary circumstances have changed.
SNAP data can be used to conduct ex parte renewals with SNAP-enrolled households that have zero or self-
employed income (Wagner 2020).
17
Unlike other data sources, which only show that no information was found,
SNAP data can confirm that an individual has no income, as emphasized by one roundtable attendee. States
must typically reverify SNAP eligibility every six months, so the state will also have recent data from those
eligibility determinations. A state participant noted that the state’s integrated eligibility system facilitates verifying
zero income for households with SNAP. Notably, while SNAP data were described as a critical data source for
verifying zero income among households receiving SNAP, no participants mentioned using SNAP data to verify
self-employment income, although the data could be used in a similar fashion.