IBA Compliance Connection

Your go to source for compliance!

We received a letter from Accuity Asset Verification Services, which presents itself as a vendor that verifies assets of applicants for various federal and state benefit programs. We haven’t seen official correspondence from any Illinois agencies on this program, and we are leery of moving from participation by snail mail to electronic verification. Do you have insight on this program?

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We believe that Accuity is the vendor providing Medicaid asset verification services to the Illinois Department of Human Services. Accuity has provided its services in Illinois for the last ten years, and it has sent letters over those years requesting that our members switch to an electronic method to complete its asset verification requests.

Recent developments related to Medicaid eligibility requirements may have prompted a new round of correspondence from Accuity. It has been reported that after a COVID-related pause of over three years, Medicaid recipients now must prove their eligibility, and Illinois began processing Medicaid redeterminations last month.

As in the past, Accuity’s correspondence requests that your bank voluntarily switch from paper communications to electronic communications for case-by-case asset verification requests and responses.  Provided that Accuity complies with the disclosure and consent requirements in the Social Security Act, which we are assuming will be the case, we do not anticipate any issues in continuing to participate in paper-based asset verification requests or in switching to one of the electronic methods listed in Accuity’s letter.

For resources related to our guidance, please see:

  • Social Security Act, 42 USC 1396w(b)(1) (“For purposes of this section, an asset verification program means a program described in paragraph (2) under which a State

(A) requires each applicant for, or recipient of, medical assistance under the State plan under this title on the basis of being aged, blind, or disabled to provide authorization by such applicant or recipient (and any other person whose resources are required by law to be disclosed to determine the eligibility of the applicant or recipient for such assistance) for the State to obtain (subject to the cost reimbursement requirements of section 1115(a) of the Right to Financial Privacy Act but at no cost to the applicant or recipient) from any financial institution (within the meaning of section 1101(1) of such Act any financial record (within the meaning of section 1101(2) of such Act held by the institution with respect to the applicant or recipient (and such other person, as applicable), whenever the State determines the record is needed in connection with a determination with respect to such eligibility for (or the amount or extent of) such medical assistance; and

(B) uses the authorization provided under subparagraph (A) to verify the financial resources of such applicant or recipient (and such other person, as applicable), in order to determine or redetermine the eligibility of such applicant or recipient for medical assistance under the State plan.”)