Information and guidance on COVID-19 changes frequently. This Worker Guide will be updated to reflect changes as quickly as possible. Please review carefully.
1. Background and general information about ONE
On March 7th, Governor Kate Brown signed Executive Order No. 20-03 declaring a state of emergency to address the spread of the novel coronavirus (COVID-19). In addition, on March 18, 2020 President Trump signed the Families First Coronavirus Response Act (FFCRA; P.L. 116-127) into law in response to the Public Health Emergency (PHE) for coronavirus disease 2019 (COVID-19). These orders require agencies to develop and implement procedures, including waiving rules or adopting temporary rules, designed to prevent or alleviate the public health threat.
This Worker Guide provides guidance on the policy and procedural changes that have been implemented during this health emergency. Please also refer to the transmittals and resources listed on the COVID-19 Response page.
ONE functionality has been updated to incorporate COVID-19 provisions, including but not limited to:
During the public health emergency, eligibility workers should accept self-attestation of all financial and non-financial eligibility factors, except citizen/non-citizen status.
Self-attestation can be accepted for:
The interview requirements have not changed and the redetermination/review date should be set at 12 months per the current process. Workers can still request additional verification if the individual is not able to self-attest to any needed information; however, keep in mind that the individual can later self-attest to that information. We still require the same information to determine eligibility, the only difference is that we can accept self-attestation for all verification factors other than citizen/non-citizen status.
New applicants (including those applying for a new benefit) may still be denied if they fail to meet the financial or non-financial eligibility requirements according to the self-attested information.
When accepting self-attestation, workers must select “Client Statement” from the verification source dropdown menus on the applicable screens. Cases in legacy must be coded with the COV case descriptor and workers must narrate when self-attestation is being accepted in lieu of documentation due to the COVID-19 emergency.
If information from electronic sources (IEVS) differs from the individual’s statement and it cannot be easily explained, then it is appropriate to send a 210 or 210A to request clarification. But remember that the individual can self-attest to the reason for the discrepancy.
Remember: Adverse actions on ongoing cases have been temporarily suspended as part of H.R. 6201 (see APD-PT-20-034), so even if the Dept. subsequently receives information that contradicts the self-attested information and results in ineligibility, benefits cannot be closed or reduced during the emergency period unless the individual requests voluntary closure, is deceased, is incarcerated, moves out of state, or was opened due to administrative or agency error.
Citizens/Non-Citizens
Staff should rely on self-attestation of citizen/non-citizen status following current Reasonable Opportunity Period (ROP) practices. Citizenship and non-citizen status do not need to be verified before benefits are opened for the first time if the individual attests to citizenship or qualified non-citizen status. Staff should continue current verification practices for citizenship and use the Verify Lawful Presence (VLP) interface for anyone requesting medical benefits to verify immigration status. Please refer to the Capturing Noncitizen Information Quick Reference Guide for more information. Note: You will continue to use SAVE for non-medical benefits, unless the individual is applying for both (e.g. medical and SNAP), in which case the worker would only have to verify with VLP.
The ROP can be extended if the non-citizen is making a good faith effort to resolve any inconsistencies or obtain any necessary documentation, or the Department needs more time. No reductions should happen during the extension.
Electronic Sources
Staff should continue to utilize available electronic sources such as BENDEX, SDX, SOLQi, Work Number, WAGE, and DMV screens. For example, if ECLM indicates a payment that differs from what the applicant reported, you will still request verification to explain the discrepancy (except for SSA income); but that verification can be self-attestation.
If information from electronic sources (IEVS) differs from the individual’s statement and it cannot be easily explained, then it is appropriate to send a 210 or 210A to request clarification. But remember that the individual can self-attest to the reason for the discrepancy.
For SSA benefits only, if the applicant attests to income information that differs from what BENDEX, SDX, or SOLQi shows, the worker should use the information received from the interfaces.
Information received from AVS
Workers should continue to run AVS; however, staff should rely on self-attestation of resources when determining eligibility. It is not necessary to wait for AVS results to approve benefits during the COVID-19 emergency period. However, if AVS results are returned before initial benefits are approved, and the AVS results show that the individual is potentially ineligible or show undisclosed resources, then the worker should send a DHS 0210 and request information to explain the discrepancy.
Waiting for AVS results is different than scenarios where AVS results are returned first due to other delays (such as waiting for the service case manager to complete an assessment and send the SELG record).
Remember that no adverse actions are allowed during this period for existing Medicaid recipients. Therefore, when the AVS report is returned after benefits are approved, workers may only act on the results after the COVID-19 emergency period has passed (if necessary).
Example 1: The Work Number indicates higher income than what the applicant reported. The worker requests verification to explain the discrepancy. The applicant calls to attest that work hours have been reduced due to COVID-19. Accept the self-attested current income amount.
Example 2: Applicant lists one vehicle on the application, but WVIR shows that he owns two vehicles that are currently registered. The worker requests verification to explain the discrepancy, and the applicant calls to attest that his wife's vehicle was repossessed a week before the DOR. No additional verification is needed.
Example 3: An LTC applicant self-attests to $800 in checking and savings and no disqualifying transfers. The worker opens the case based on self-attestation. When the AVS results are returned, they show additional resources and several flags for potential disqualifying transfers. No additional verification is needed at this time; however, the worker should follow the instructions in the COVID-19 Alternative Processes QRG for how complete the necessary screens in ONE. For cases still in Legacy, the worker codes the case with COV case descriptor and clearly narrates the situation for follow-up after the emergency period ends.
Complex Eligibility Factors
For the more complex eligibility factors that may require more information than is entered on the application, such as specific details about trusts, annuities, pension/retirement accounts, burial arrangements, asset transfers, etc., staff should attempt to gather the information from the applicant by asking them specific questions needed to make a determination over the phone during the interview. Again, if they are not able to provide the answers at the time, send a pending notice for whatever information is still needed, but as stated above, they can later self-attest to that information. See below for some examples of possible scenarios.
Examples
Income Cap Trust Questions:
Other Trust Questions:
Annuity Questions:
These questions are illustrative of the requirements for an annuity excluded under OAR 461-145-0022(10).
NOTE: For annuities involving other time periods, or for non-OSIPM cases, there would be similar but different questions. See, generally, 461-145-0022(6) through (8), and 461-145-0020.
Pension/Retirement Plans Questions
Back to topWith the implementation of the ONE system, it is generally possible to obtain verbal signatures on most forms. See the QRGs below for more information:
Call Center Software – Playing Rights and Responsibilities & Capturing Verbal Signature
Call Center Software – Playing the Asset Verification System (AVS) recording & Capturing Verbal Signature
Call Center Software - Video Simulation
Capturing a Verbal Signature on the 457D for Medical Only
Authorized Representative Verbal Signature
For cases still held in Legacy:
Email, text, and over the phone
All electronic forms sent through email must be saved to the individual’s EDMS file. The date it is sent through email should be narrated the same as when the form is sent in the mail.
Instructions on Adding E-Signatures on Oregon ACCESS and Web Forms
Instructions for clients on how to access secure emails sent from DHS
If the individual signs a form via email, text, or over the phone, complete the following for audit purposes:
Physical "Wet" Signatures
A wet signature must still be obtained per the pre-COVID process on the MSC 3010 (Authorization for disclosure of information) for all cases, whether held in ONE or in Legacy.
The following forms may be signed telephonically in ONE, but must have a wet signature when the case is still in legacy:
Back to topDue to the passage of the Families First Coronavirus Response Act (H.R. 6201) on the evening of March 18, 2020, previous guidance was given that no adverse actions may be taken on open Non-MAGI Medicaid cases until further notice (with a few exceptions). This applied to actions with an effective date of 3/18/20 or later. Actions with an effective date prior to March 18, 2020 were not impacted by H.R. 6201.
Example: If a worker took a closure action on 2/27/20 with an effective date of 3/31/20, that action was reversed. If this individual was also on services, and the case manager took the action on 2/27/20 to close the services effective 3/15/20, that action was not reversed.
Recently, the Center for Medicare and Medicaid Services (CMS) adopted 42 CFR 433.400 effective 11/2/20, which represented a change regarding what adverse actions were allowable during the COVID-19 emergency period. As a result, ODHS made the following changes to its COVID-19 emergency period provisions effective March 25, 2021:
Please refer to APD-PT-21-001 for updates to long-term care COVID-19 provisions.
It is important to note that individuals can voluntarily choose to allow any adverse action – we cannot force Medicaid recipients to accept benefits for which they are not eligible if they do not wish to accept them.Note: No overpayment referrals should be made during the COVID-19 emergency period.
SFMU process for In-Home Service clients during the COVID-19 emergency period:
“If an individual does not pay their liability (aka pay-in) by the end of the month that is due, their SFMU account goes into ineligible (IL) status. Staff will have to adjust off the outstanding liability to bring the SFMU account into current status. Continue using the “OT” code with the comment: “Failure to pay – No OVP referral COVID-19 emergency period." Liability should continue to be paid on-going at the current amount. No overpayment referral should be sent for this missed month during the emergency period.
*Remember* the individual has until the last day of the month to make a payment, so a liability should not be adjusted off until the beginning of the following month. Ex: Do not adjust off an October missed pay-in until November.” See the SFMU Consumer Pay-In Cookbook for complete instructions on how to adjust a liability record.
Examples
Example 1: Frank is receiving SSA retirement benefits and has QMB. Frank’s ex-wife passed away, and Frank reports getting additional survivor benefits starting in April. The worker redetermines eligibility and Frank is now over income for QMB but eligible for SMF. Frank will remain on QMB until the COVID-19 emergency period ends (subject to timely notice requirements).
Example 2: David is receiving OSIPM and services in an ALF but doesn’t pay his liability in April or May (there was no change in income). Even though paying liability is required to remain eligible for services and OSIPM, David will remain on services and OSIPM until the COVID emergency period ends (subject to timely notice requirements).
Example 3: Fran is receiving OSIPM and in-home services. Fran’s best friend died on April 10th and left Fran $10K and a Mercedes in the will. Even though Fran is now over resources for OSIPM, Fran will remain on services and OSIPM until the COVID emergency period ends (subject to timely notice requirements).
Example 4: Jane has been receiving in-home services and has a $0 liability/pay-in. Jane wants to move into an ALF on June 1 which will increase the liability to $150. ONE will increase the liability to $150 after the change is processed.
Example 5: Joan was receiving in-home services and had $0 pay-in. Joan was approved for $800 in VA Aid and Attendance benefits effective April 1, which increases the pay-in to $600. ONE will increase the pay-in to $600 after the income change is processed (subject to timely notice requirements).
Example 6: Don is receiving in-home services and a special diet allowance of $35 dollars per month. Don’s medical condition improved in April, and the doctor recommended going back to a regular diet. Since Don is not eligible for the special diet medical-related payment (MRP) anymore, the worker updates the MRP in ONE with an end date (subject to timely notice requirements).
Example 7: Steve is on SSI and receiving in-home services and the $22 in-home supplement MRP (ISS) every month. When Steve moves into an ALF on May 1, the ONE system will allow the payment to end (subject to timely notice requirements).
EPD-Specific Examples:
Example 1: Shelly is on EPD and reports no longer being employed due to the COVID-19 emergency. The worker is able to verify with the employer that Shelly is no longer employed. ONE will evaluate for other programs and either move to another program for which Shelly is eligible if it is not a reduction in benefits. If ineligible for any other equivalent program, ONE will approve OSIPM for the remainder of the emergency period.
Example 2: Kara is on EPD and services and reports no longer being employed due to the COVID-19 emergency. Kara was paying a $50 participant fee. If not on EPD, Kara’s liability would be $75. The worker is not able to verify with the employer that Kara is no longer employed, so takes self-attestation. ONE will move Kara to LTCSERV with a $75 liability, allowing for timely notice.
Example 3: Lane is on EPD and reports work hours were reduced to 0. The worker verifies that Lane is still employed, but not working due to the Stay Home, Save Lives order. Lane is still considered employed so remains eligible for EPD. ONE will automatically recalculate the participant fee once the worker updates the earned income.
Adverse Actions do not include:
Example 1: Joe was approved for services with a $200 liability. Joe moves into Sunny Acres AFH on April 15. The CM zeros out the liability for April (meaning the CM approves a one-time Community-Based Care MRP under 461-155-0630). Beginning the liability in May is not an adverse action.
Example 2: Fred's ongoing liability is $300. Fred submits a receipt for a $100 dental bill he paid to get a tooth filled in March, so his liability was reduced to $200 for March. Restoring his liability to $300 in April is not considered an adverse action.
Example 3: Frannie is approved for a one-time MRP in March for roof repairs. Ending the payment in April is not considered an adverse action and no additional notice is required after the 541 approval notice is sent.
Until further notice, all Non-MAGI Medicaid recipients will remain eligible for their current Medicaid benefits through the end of the month in which the Novel Coronavirus/COVID-19 emergency ends, subject to timely notice requirements - even if mail is returned as “Undeliverable” with no forwarding address and for whom no other forwarding address is found (per existing business processes) - unless one of the following applies:
Approved closure reasons:
Please note, reported changes that result in an increase in benefits and/or services or a reduction in liability or participant fees should continue to be processed per normal business process.
Important: MAGI has also implemented temporary no-adverse action provisions (see SS-AR-20-005).
Actions Needed
Administrative Hearings
APD Hearings Unit will be notifying local offices of cases pending hearing without continuing benefits in place and those cases will need to be restored effective March 18, 2020. Individual who previously did not request this benefit should not be restored farther back than this effective date. Once the work resumes, the APD Hearings Unit will proceed to hearing on the timeframe prior to March 18, 2020 that individuals were contesting.
The following information outlines COVID-19 provisions applicable to the Medicare and pursuit of Medicare related changes described in APD-IM-21-012 and the Medicare Enrollment and Buy-In Quick Reference Guide:
We cannot close benefits during the COVID-19 emergency period if existing Medicaid recipients fail to pursue Medicare, but workers must still pend individuals to apply for Medicare if they are eligible to be enrolled. This includes everyone 65 or older who is not receiving or being evaluated for CAWEM. The information must be entered into ONE correctly, and if the individual fails to comply, COVID functionality will prevent closure, but the case will be internally tracked for action when the COVID-19 emergency period ends. Please remember that it is allowable to deny new applicants for Medicaid during the COVID-19 emergency period if they are not eligible for any reason, including if they fail to pursue Medicare.
Back to topIn response to the COVID-19 Pandemic, several payments have been made available to assist individuals through economic difficulty. These payments fall under the disaster relief rule and are all excluded in some way.
CARES Act Stimilus Payments
The first round of recovery rebates equaled up to $1,200 per person ($2,400 for married taxpayers filing a joint tax return) and $500 per child under 17. These amounts phased down for higher-income taxpayers. The second round, which were distributed starting December 29, 2020 totaled $600 per individual, $1,200 per couple, and up to $500 for each qualifying child. The third round began dispersing in mid-March 2021 and totaled $1,400 per eligible individual. These payments are structured as tax credits automatically advanced to households in 2020 and early 2021 if they filed a 2019 income tax return and will be received as a direct deposit or check by mail. If a 2019 return was not filed, rebates will be advanced automatically based on 2018 return information.
The advanced credit amount was estimated by the IRS based on taxpayers’ 2019 income tax return information (if the taxpayer did not file a 2019 income tax return, 2018 income tax return information was used instead). For Social Security and Railroad Retirement recipients, if neither a 2019 nor a 2018 income tax return were filed, the laws allow the IRS to use information from their 2019 Social Security or Railroad Retirement Benefit Statement, meaning that no action is necessary on the part of the Social Security recipient in order to receive these payments.
Non-tax filers and SSI recipients could apply for the payments on the IRS website. For more information and updates, please see and refer individuals with questions about this to the IRS website.
These stimulus payments are excluded for all Medicaid eligibility and liability calculations as income and are excluded from resources for a period of 12 months following receipt.
FFCRA Federal Pandemic Unemployment Compensation (FPUC)
The first round of FPUC benefits totaled $600 per week in addition to an individual’s regular weekly state unemployment benefit. These benefits were authorized by the federal government through July 31st, 2020 and then reauthorized on December 27, 2020 in the amount of $300 per week payable for weeks beginning after December 26, 2020 and ending on or before March 14, 2021.
FPUC benefits are excluded from all Medicaid income eligibility and liability calculations. Benefits are not counted in the month they are received, but any amount held after the month of receipt is counted as a resource.
All other Unemployment Compensation (UC) remains countable for both liability and eligibility. To determine the amount of UC to count, first determine if FPUC is being received. If the weekly benefit amount is greater than the applicable amount of FPUC benefits (either $600 or $300 depending on the time period), FPUC has been added and staff should take the total weekly amount received and subtract $600/$300 prior to coding as regular UC benefits in ONE. If the weekly benefit amount is $600/$300 or less, use the full amount when converting to a monthly amount (do not subtract $600/$300).
ONE Coding of FPUC:
Effective immediately, FPUC should be coded on the Unearned Income Information screen:
All programs are now excluding these payments as of 1/1/21. Previous guidance was to code this income on the Unearned Income screen as Unemployment Compensation – Pandemic Unemployment Compensation; however, ONE currently considers this income type as countable for all programs except medical. The ONE system is being updated to exclude this income type as outlined in the recent guidance. Until this happens, follow the guidance above.
An Interim Business Process (IBP) is being created. Once finalized, a communication will be sent with the IBP number. See SS-PT-21-002 for more information.
Example 1: Sam receives unemployment compensation of $355 per week. Since this is less than $600, Sam is not yet receiving the FPUC, so the worker should count the full $355.
Example 2: Layla receive $785 per week in unemployment compensation. Since this is more than $600, Layla must be receiving the FPUC, so the worker should subtract $600 to get the regular weekly benefit amount of $185.
Lost Wages Assistance (LWA) program and COVID-19 Temporary Paid Leave program
On August 8, 2020, the President made available up to $44 billion from FEMA's Disaster Relief Fund to provide financial assistance to people who have lost wages due to the COVID-19 pandemic.
Lost Wages Assistance (LWA)
This was a temporary emergency program that gives an additional $300 per week to people who are out of work due to the COVID-19 pandemic and are receiving unemployment benefits. LWA is effective from the period of July 26, 2020 through September 5, 2020.
The LWA payments are made through the Oregon Employment Department (OED). OED has not yet issued these payments but they are expected to be sent to individuals at the end of September.
COVID-19 Temporary Paid Leave program
This program is available to people who need to quarantine or isolate because of COVID-19 exposure or are experiencing symptoms and need a medical diagnosis, but do not qualify for COVID-19-related paid sick leave (or do not have access to COVID-19-related paid time off).
Individuals who meet all of the eligibility requirements will get a $120 per-day payment for up to 10 working days ($1,200 total) for the time they need to quarantine or isolate.
These payments are federal funds issued through the Department of Consumer and Business Services (DCBS). Individuals will need to complete an application to qualify at Oregon.gov/covidpaidleave.
Both of these payments are excluded for all Medicaid eligibility and liability calculations as income and are excluded from resources in the months following receipt if the requirements of OAR 461-104-0070 are met. See SS-IM-20-020 for more information.
Coding cases
For those cases in ONE, both incomes will be entered as unearned income. Once on the Unearned Income Information screen:
• For the $300 LWA payments, select “Disaster Relief” for the Unearned Income Category and “Disaster Relief payments from Federal Emergency Management Agency (FEMA)” for Unearned Income Type.
• For the $120 paid leave program, select “Disaster Relief” for the Unearned Income Category and “Disaster Relief payments from state or local governments or disaster assistance organization” for Unearned Income Type.
For those cases still in the Legacy system, the income is not added to the case. Narrate in OACCESS/TRACS the amount the applicant received and the source but do not to add it to the case.
Federal Pandemic Unemployment Assistance (PUA):
PUA is a federal unemployment benefit program created in response to the COVID-19 pandemic. It is for individuals who are self-employed, contract workers, and other workers who are not eligible for regular benefits.
For all programs, PUA retroactive payments are counted as periodic or lump-sum income and all other payments are counted as unearned income.
ONE Coding:
Enter PUA as Unearned Income. On the Unearned Income Information screen:
• Select “Unemployment” for the Unearned Income Category and
• Select “Unemployment Compensation” for Unearned Income Type.
Legacy Coding:
Code PUA as UC. Back to topEligibility staff should process annual renewals of non-MAGI Medicaid benefits (OSIPM, QMB, SMB, SMF) per the normal process with the following exceptions that apply during the COVID-19 emergency period:
Staff must add the COV case descriptor to any case still held in Legacy to which the above exceptions are applied.
Back to top7. Tracking with COV Case Descriptor - Legacy Cases Only
To identify and track situations in which eligibility was processed “differently” in order to improve application processes or prevent benefit reductions/closures, a new case descriptor was made available for use in the Oregon ACCESS/Client Maintenance (CM) systems. The case descriptor will also allow us to evaluate the fiscal, operational, and other impacts of the COVID-19 emergency measures. It is important that staff use the COV case descriptor to achieve these goals. The case descriptor information is as follows:
Note: Staff should remember to carefully narrate so that it is clear what follow up actions must be taken after the emergency period ends.
While this does not represent an exhaustive list of scenarios in which the user may add the COV case descriptor to an Oregon ACCESS/CM case, below are some common examples.
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