Change in the Matching Logic for Income at the FFM?

kgmom219

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This came out today....

How is the annual income threshold changing?
Annual household income data matching issues are currently created whenever an applicant’s annual household income attestation is more than 10% less than the income data received from trusted data sources shows, or if no household income data is available from those sources. The HHS Notice of Benefit and Payment Parameters for 2017 granted authority to Marketplaces, subject to HHS approval, to set a reasonable threshold for the generation of annual household income data matching issues that would require additional verification. The regulation (45 C.F.R. §155.320(c)(3)(vi)) stated that the threshold could not be less than 10% and that it could include a dollar threshold. HHS has determined that it is a reasonable threshold to generate an annual income data matching issue for a consumer if their attested income is more than 25% or $6,000 (whichever is greater) lower than data from our trusted data sources; we maintain the policy that a data matching issue is generated if no data is available from our trusted data sources. This threshold change, which we expect will simplify the process while maintaining program integrity, will be in place in the FFM prior to the start of open enrollment for plan year 2017.

I'm hoping this means we will see less "income verification letters" during OEP
 
Per the body of the CMS email:

The change will reduce the number of consumers that have to follow-up and submit documentation to verify their household income while maintaining important program integrity controls
 
IMHO simple item, "Mr. Customer, if in years past you have had to submit info to verify income the reason was the threshold which triggered that has been changed so just need to make sure the income you told me of $X is not more than <info from CMS guidance>. If it is outside this it will trigger going through that PITA of sending in documentation, so just to make sure, your income will be $X right?"

Dont get me wrong, I am not taking CMS side, etc. but this is a <maybe small> positive for agents if used and communicated correctly.
 
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