We received a letter from Accuity about electronic Medicaid asset verification requests. Is the IBA recommending that banks not participate in this program?

Thank you for forwarding Accuity’s letter regarding electronic Medicaid asset verifications. The request in the letter appears to reflect a different program than the one we addressed in our 2013 letter to Illinois banks, and we do not see it raising the concerns referenced in our earlier letter.  It appears that the Illinois Department of Human Services has switched vendors for administering its federally-mandated asset verification program (from HMS to Accuity), and Accuity’s letter appears be requesting 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 see any legal issues here.