IRS Asset Match & FTB Asset Match

Overview

Internal Revenue System (IRS) Asset Match 

The annual Internal Revenue System (IRS) Asset match provides information on unearned income reported to the IRS such as out-of-state accounts, lottery winnings, stocks and bonds, and any other income information not found in FTB files. The MEDS beneficiary file is matched against the IRS Unearned Income File. The IRS and FTB Asset matches are cross-matched before they are sent to the IEVS Unit in order to avoid duplication. IRS Asset Matches are processed by the IEVS Unit. 

Important: DUE TO CONFIDENTIALITY REQUIREMENTS, IRS ASSET MATCH RECORDS ARE ONLY AVAILABLE TO IEVS STAFF.

Designated IEVS EEs will compare the information in the case record with the IRS Asset match information.

Franchise Tax Board (FTB) Asset Match 

The annual Franchise Tax Board (FTB|0 Asset match is a match of the Medi-Cal Eligibility Data System (MEDS) beneficiary information against FTB’s interest and dividend file. The income information includes those submitted to FTB by banks, insurance companies, and financial & investment institutions based in California or which have offices in California.

The county is required to process match reports on all open cases with reported income from assets of $50 or more. Information is 12 to 23 months old and shows only the interest and dividend unearned income from assets, not the account balances which is usually more. Matches are made on the SSN and last name.

If the case is closed, and the income from the asset is less than $250, no further action is required.

The Eligibility Examiner (EE) from the IEVS unit is responsible for processing all annual FTB Asset Matches for the recipient system. They will review the case record for all matches and determine if the asset has been reported.

The annual IRS Asset match provides information on unearned income reported to the IRS such as out-of-state accounts, lottery winnings, stocks and bonds, and any other income information not found in FTB files. The MEDS beneficiary file is matched against the IRS Unearned Income File. The IRS and FTB Asset matches are cross-matched before they are sent to the IEVS Unit in order to avoid duplication.

Important: DUE TO CONFIDENTIALITY REQUIREMENTS, IRS ASSET MATCH RECORDS ARE ONLY AVAILABLE TO IEVS STAFF.

Designated IEVS EEs will compare the information in the case record with the IRS Asset match information.

Asset Match Information

The information on the asset matches:

  • Is thirteen to twenty-four months old and shows only the interest or dividend income from the assets, not the amount of the assets themselves.
  • Is made on the SSN and only the FIRST FOUR CHARACTERS of the last name.
  • Data sources are interest and dividend income reports submitted to FTB by:
    • Banks
    • Insurance Companies
    • Financial and investment institutions with an office in California.
  • The dollar amount of interest income reported may be for one day or up to one year of accrued interest/dividends. EWs will have to obtain verification of the account to determine the period of time for which the dollar amount of interest covers.
  • Stocks, bonds, and accounts with interest paid from $.01 to $.99 will show a value of $1. The EW must follow up on this asset because there is no way of knowing if the interest is for one day or one year.
  • The only accounts showing $0 in interest should be from trust accounts. These also require follow-up.
  • Income from out of state institutions generally is not available.
  • Income/taxes from real property is not included.

 

The following information is contained in Asset Match abstracts:

SECTION DESCRIPTION
HEADER The asset information reported by FTB as of the tax year noted and the date that the match was made.
NUMBER OF PAYORS

Total number of accounts the individual has, a maximum of five accounts will be displayed.

Note: If there are more than five accounts, the additional payers can be viewed on the IEVS On-line Summary screen.
TOTAL UNEARNED INCOME The total interest/dividends on matched accounts (not the account balance). There is no way of knowing if this is one day’s interest or one year’s interest; so small amounts cannot be overlooked.
The following information will be listed for each payor:
NO The list begins with the number 1 and lists sequentially down. The accounts are listed in descending value.
AMOUNT The total amount of interest income earned from the individual account.
PAYEE The person identified as the owner or payee of the interest income and the address that is identified on the account.
PAYOR The payor, financial institution identified as paying the interest income and the address.
ACCOUNT NUMBER The account number for this account is in a Federal Employer identification format. When only the FEIN is listed, see procedures below.

When the State of California “Franchise Tax Board” is listed, it is not an account, but interest paid to the client on a tax return or interest paid on a Renter's Credit rebate.

Other unique payments:

  • State of California “State Controllers Office” is interest paid to retirees by Public Employees Retirement System. It is customarily included in their retirement annuity.
  • “County of Sacramento Substitute Payee” is interest on Public Guardian Accounts.

Asset Match with FEIN Numbers Only

The asset match information that only lists a FEIN will have the following information:

  1. The tax year the interest/dividend was received.
  2. Total number of accounts.
  3. Total interest/dividends on matched accounts (not the account balance). You have no way of knowing if this is one days interest or one years interest, so small amounts cannot be overlooked.
  4. If $0 appears the interest/dividend is less than $1, the cents are dropped off.

Match But Not For Given Name

Helpful Hints

Ask the client for other last names they may have used.

You must resubmit this inquiry under as many alternate names that you can find. Review the case record for other names that may have been used such as:

  • Maiden name
  • Children's last name
  • Former married name
  • Client's mother's maiden name
  • Step-parent name.

Reverse first and last name.

  • Try misspellings of last name:
    • MCARTHUR
    • MACARTHUR
    • MC ARTHUR
    • MAC ARTHUR

Try dropping the prefix part of the name using ARTHUR instead of MC ARTHUR or MAC ARTHUR.

List all names on the SCD 1296 in order to avoid separate transactions for each name by the EW.

Take an affidavit from the client only after all alternatives have been explored.

Processing FTB Asset Match Abstracts

Use the following chart to process FTB asset match abstracts for all programs:

STAGE WHO ACTION
1 IEVS EE
  • Reviews the case record to determine if the asset was reported. The match will show the last 36 months of Medi-Cal usage data at the bottom.
  • If the asset was:
    • Reported:  
      • Write “no impact” on the asset match. Sign, date and sends report for imaging.
    • Not reported:    
      • Sends the copy of the asset match to be imaged.
      • Sends the district office liaison an SCD 1604 form indicating “IEVS Unit is Investigating This Case”.
2 EW
  • Determine if any further action is needed when the case is returned from the EE.
  • If the RD is:
    • Not due:  
      • Take no further action unless notified by the EE at IEVS.
      • Follow up at the RD due month to make sure to discuss and resolve the discrepancy at that time.
    • Due:    
      • Resolve the asset discrepancy with the client before aid is continued. Contact IEVS, if necessary, to facilitate this process.
3 EE from IEVS
  • Obtains asset verification.
  • If after investigation eligibility:
    • Is not affected: 
      • Sends an Alert to District Office liaison notifying him/her that there is NO discrepancy.
    • May be affected: 
      • Sends a task to the district office giving sufficient information to discontinue the case because the:
        • Client has failed to cooperate, or
        • Client is not eligible.
      • The task lists the reason for ineligibility. Return the case to the district office caseload.
4 EW
  • Documents in the case journal what actions were taken.
  • Includes the following information on the NOA when a case is discontinued:
    • Name of asset
    • Account number (if applicable)
    • Amount of interest known
    • Action needed by the client.
  • If the EW assigned to the task has new information or knowledge regarding IEVS findings, the EW must communicate the new information with IEVS to resolve the discrepancies.
  • If IEVS is investigating the case and the client reveals assets to the EW rather than the IEVS EE, the EW must:
    • Resolve the asset discrepancy with the client and take appropriate action immediately
    • Email IEVS with the new information
      • Send copies of all verifications provided by the client to IEVS.

Processing IRS Asset Matches

Use the following chart to process the IRS Asset match abstracts for all programs:

STAGE WHO ACTION
1 IEVS EE
  • Review the case record to determine if the information on the IRS Asset match was reported.
  • If the asset/income was:
    • Reported:    
      • Documents in the case journal.
      • Updates finding(s) as “non-discrepant” on the IEVS - Recipient SSA Wages (IRS) Roster.

      • Reminder: FTI must not be mentioned when documenting in the case journal.

    • Not reported:     
      • Sends the client (case payee or responsible reporting party) an “Income and Eligibility Verification” form (CW 63) requesting the asset information within 10 days.
      • Follow up in 10 days.

  • REMINDER: The IRS Asset match MUST NOT be imaged. The IRS Asset match abstracts and the IEVS - Recipient SSA Wages (IRS) Roster must be kept in a locked room at all times except for when EEs are reviewing/processing the abstract.
2 IEVS EE
  • Obtains asset verification.
  • After review if it is:
    • Not discrepant:
      • Follows the Simple Close case procedure and file the abstract in a secured cabinet in a locked room.
    • Discrepant:  
      • Computes OP/OI and sends Notice of Action
      • If applicable, completes the “IEVS Communication” (SCD 1604) form giving sufficient information for EW to determine:
        • If income and/or assets affect the current and future benefit eligibility
        • If the case must be discontinued as a result of the income and/or asset findings.
  • If the client failed to return the requested verification, discontinues the case and documents in the case journal that the result was due to the client’s failure to cooperate with IEVS review.
3 EW
  • Reviews request on SCD 1604 form and completes actions:
    • Discontinues case if applicable
    • Sends a timely Notice of Action (NOA) which contains all of the pertinent information regarding the OP/OI or ineligibility
    • Documents action taken in the case journal.
    • Refer to IEVS Communication (SCD 1604) Form. 

  • Reminder: FTI must not be mentioned when documenting in the case journal.

  • If IEVS is reviewing the case and the client reveals assets to the EW rather than the IEVS EE, the EW must:
    • Resolve the asset discrepancy with the client and take appropriate action immediately
    • Email IEVS with the information
  • If the EW assigned to the task has new information or knowledge regarding IEVS findings, communicate the new information with IEVS to resolve the discrepancies.

If the case was discontinued/closed at the request of the IEVS EE for failure to cooperate or failure to report assets and the client reapplies, EW must clear all eligibility factors with IEVS unit before the case can be restored, regardless of whether restoration is in continuing or intake.

Reviewing Asset Match 

Review the questions on the Statement of Facts which relate to resources plus the verifications provided by the applicant as follows:

IF THE...

AND...

THEN...

Resources are declared

The information provided by the client and verification in the case record agrees with abstract,

No further action on the resource is needed.

Interest is received,

The asset must be explored.

Note: If the income is posted monthly and can reasonably be anticipated, i.e., it fluctuated somewhat, but is at least $10 each month, it shall be counted in the income computation.

Resources are Not declared

IEVS data is received before the interview or the Statement of Facts is received,

The EW shall question the applicant at the interview and document all findings.

IEVS data is received after the interview or Statement of Facts is received,

The EW must send the “Income and Eligibility Verification Form” (CW 63) to the client to follow up on the asset.

Unrestricted Access to Accounts

If the applicant has unrestricted access to accounts, follow these guidelines:

IF THE...

THEN...

Applicant has unrestricted access (only one name or more than one name with “or” on the account),

Reevaluate eligibility to determine if the resource is exempt or if the value of the non-exempt resource plus other resources is within the property limit.

Value of the resource plus other resources exceeds the property limit,

The case is ineligible for the months that resources exceeded the property limit.

Client received aid during the period the asset was concealed,

Complete a fraud and/or overpayment referral as appropriate.

Restricted Access to Accounts

If the applicant has restricted access to accounts, follow these guidelines:

IF...

THEN...

The applicant has restricted access, (joint accounts which require another signature to sell, withdraw funds, etc.) and the co-owner is in the AU, MFBU, or CalFresh household,

The resource is available.

The co-owner is not in the AU, MFBU, or CalFresh household,

The availability of the asset must be established according to each program.

There is a spouse or conservator, or the person acting on the client's behalf does have the authority,

Evaluate availability of resources.

Processing Asset Match

Based upon the applicant's response, the following procedures are to be used to determine whether the asset affects eligibility:

IF THE...

THEN...

Resource is Spent Down,

The applicant must provide verification/information which shows that the asset was spent down prior to establishing eligibility.

Resource is given away and/or transferred,

The regulations regarding “Transfer of Property” for the specific assistance program involved must be considered before eligibility is established or denied.

Applicant is Incompetent

If the applicant is incompetent follow these guidelines:

IF...

THEN...

The applicant has the resource,

Include in resource level to determine eligibility.

The applicant is senile or otherwise mentally incompetent, and there is no spouse or conservator and the person acting on the applicant's behalf does not have the “right, power or authority” to access the accounts,

Appropriate action must immediately be taken to make the accounts available.

Make a referral to the Public Guardian’s Office.

There is a spouse or conservator, or the person acting on the client's behalf does have the authority,

Evaluate availability of resources.

All determinations must be thoroughly documented in the case journal.

Resolving Asset Match Discrepancies

This section covers the processing of asset matches.

When IEVS Applicant System Asset Match information does not agree with information supplied by the applicant/beneficiary, regulations require the case-carrying EW to contact individuals in writing and inform them of:

  • The information received from IEVS
  • Its potential impact on eligibility
  • The requirement to respond within ten days
  • The consequences of failure to respond.

The Income and Eligibility Verification Form (CW 63) must be sent to the client to meet this requirement. When the client contacts us, the EW determines based on the information provided whether it will be necessary for the applicant/beneficiary to come in for an interview.

Client is Required to Come In

When the EW determines that the client is required to come in for an interview the EW shall send a CSF 6 appointment letter.

Send the appointment letter to the client, or to the person who has completed and signed the Statement of Facts on behalf of a mentally incompetent client.

Client is NOT Required to Come In

When the EW determines it is not necessary for the client to come in to the office, the EW shall send a “Notice” (SCD 50/MC 355) requesting the required verification by a specific date, allowing at least 10 days for it to be provided.

Send the notice to the client or the client's representative if the client is unable to act on his own behalf.

Requesting Information

Use the following guidelines when requesting information from the applicant:

IF THE CLIENT AND/OR REPRESENTATIVE...

THEN...

Responds,

Evaluate the information and question the disposal/transfer of property. Inform the client/representative of the outcome.

Fails to respond,

Contact the client by sending an SCD 50 or by telephone, and document in the case record. If there is no response after ten working days, send an adequate and timely NOA for “Failure to provide information” and discontinue the case.

Note: EWs must follow SB 87 procedures and time-frames before discontinuing Medi-Cal benefits.

Fails to respond then disagrees with the discontinuance,

Evaluate good cause. Good cause applies to the beneficiary or to the person who is acting on their behalf.

Examples of good cause are:

  • The person was out of town and did not receive the letter in time to respond within ten days.
  • There were problems with the mail delivery so the person did not receive the letter.
  • The person was very ill and did not have access to a telephone.

If good cause exists, rescind the discontinuance, reinstate eligibility, and allow the person to provide the requested verifications. Continue eligibility as long as the person is attempting to obtain necessary verification and is cooperating to the best of their ability.