Multiple Transfers (Archive)

Clients who have made multiple transfers must have the transfer penalty periods evaluated for potential overlap. This section provides the steps to follow when a client has overlapping penalty periods.

MA.

MA - Multiple Transfer Examples.

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MA

When a client has multiple transfer penalties follow these steps:

Note:  If the transfer was made prior to April 13, 1996, see Archived Transfer Information.

1. Determine if there is an overlapping transfer period for any of the transfers, by comparing the months of penalty to one another starting with the oldest transfer and moving forward.

2. If transfer penalty periods overlap:

l  For transfers where the overlapping transfers were made before February 8, 2006, add the uncompensated value of each of the overlapping transfers together and determine a new transfer penalty.

l  For overlapping transfers when one of the overlapping transfers was made on or after February 8, 2006, add the transfer penalty figures together and determine a new transfer penalty.

3. Repeat Step 1 using the new transfer penalty created in Step 2. Continue to repeat the steps until no transfer penalty periods are overlapping.

Transfer penalty periods cannot be interrupted or suspended. The transfer penalty months run consecutively and continue even if the applicant is no longer eligible for MA or payments of MA LTC services.

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MA - Multiple Transfer Examples

Example:

Joy is applying for MA-LTC for August 2006. She has reported four transfers within the look back period. The SAPSNF in effect for August 2006 is $4438. The transfer dates and their uncompensated values are:

l  January 1, 2005; $6,000.

l  February 1, 2005; $12,000.

l  January 1, 2006; $36,000.

l  May 1, 2006; $12,000.

Action:

1. Determine the penalty period for each of the transfers.

a. January 2005 transfer:  $6,000 divided by $4438 results in a penalty period of 1.35 months. This is applied for February 2005 and for a partial penalty of $1553 for March 2005.

b. February 2005 transfer:  $12,000 divided by $4438 results in a 2.70 month penalty period. This is applied in March 2005 through April 2005 with a partial month penalty for May 2005 of $3106.  

c. January 2006 transfer:  $36,000 divided by $4438 results in a penalty period of 8.11 months. This is applied in February 2006 through September with a partial month penalty for October 2006 of $488.

d. May 2006 transfer:  $12,000 divided by $4438 results in a 2.70 month penalty period. This is applied in August 2006 through September 2006 with a partial month penalty for October 2006 of $3106.  

2. The January 2005 and February 2005 transfers have overlapping penalty periods.

Because the transfers were made prior to February 8, 2006, add together the uncompensated values and determine a new penalty period. $6,000 + $12,000 = $18,000 divided by $4438 = 4.06 months.

The new transfer penalty period is February 2005 through May 2005 with a partial penalty for June 2005 of $266.

3. The new transfer penalty period does not overlap with the next penalty period established for the January 2006 transfer. However, the January transfer penalty does overlap with the May 2006 transfer penalty

4. Add together the transfer penalty periods of the January 2006 transfer and the May 2006 transfer, because one of the overlapping transfers was made on or after February 8, 2006.

The new transfer penalty is 10.81 months (8.11 January 2006 + 2.70 May 2006). Apply the transfer penalty using the policy in affect for the older of the transfers.

The transfer penalty period is February 2006 through November 2006 with a partial month penalty for December 2006 of $3594.

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Example:

Pierre applies for MA on July 12, 2006 when he is approved for Elderly Waiver. He reports a transfer of $25,000 made on January 25, 2006 and another for $10,000 on February 28, 2006.

Action:

Calculate each transfer penalty separately.

The January transfer results in a 5.63 month transfer penalty. The February transfer results in a 2.25 month penalty.

Action:

Calculate the transfer penalty as follows:

l  The combined transfer penalty is the total of the January transfer of 5.63 months and the February penalty of 2.25 months (7.88 months).

l  The transfer penalty begins February 2006 (the month after the month of the January transfer) and runs through August 2006.

l  A partial penalty is applied in September 2006.

Pierre is ineligible for payment of LTC services in July and August, and is responsible for the partial transfer amount in September. He is eligible for payment of MA non-LTC services as of July.

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Example:

A client applying in August 2006 for payment of LTC services and has the following uncompensated transfers:

l  March 2006 of $10,000.

l  February 2006 of $1000.

l  April 2006 of $1000.

Action:

Take the following action:

1. Review for fractional transfers on or after February 8, 2006. Two of the three transfers are for less than the SAPSNF total.

2. Determine the transfer penalty for the March transfer ($10,000 March / $4,438 SAPSNF = 2.25 months transfer penalty).

3. Determine the partial transfer penalty amount (.25 X $4,438 SAPSNF= $1109.50).

4. Add the fractional transfers from February and April, which do not meet a transfer exception, to the partial transfer penalty amount ($1109.50 + $1000 + $1000 = 3109.50, new partial penalty amount).

This client is ineligible for August and September 2006 and is responsible for the first $3109 of October 2006.

GAMC - Multiple Transfers

If transfer penalty periods overlap, add the transfer penalty figures together and determine a new transfer penalty.

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