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4. What is the process if multiple LIS applications are submitted for the same individual?
The process for subsequent applications depends on the agency(ies) to which the individual applied-- Social Security or the State Medicaid Office.  If both applications were submitted to Social Security, the process then depends on specific details about the applications:

(Back to Questions about the Low Income Subsidy)

Subsequent Application Chart

If the first application is/was

Was a subsidy changing event reported?

Subsequent application received within appeal period?

System Action

FO/OCO ACTION

Pending

N/A

N/A

Subsidy Determination will mark the application as a Duplicate (DUP) application and will normally send it to OCO/ICTU. (NOTE: If a FO/SAU is processing a case with a pending duplicate application, the office should also process the duplicate application.)

Review and compare both applications to determine which application has the oldest application date since that application date must be used. Also, determine who filed each application (individual or third party). If the alleged income or resources is higher on the individuals’s application or if the differences between the two applications are not material, process the application using the individual’s alleged amounts. If you cannot resolve the discrepancies by reviewing the applications, contact the individual to resolve them. Update the application that will be processed with information from the application that will be canceled, as appropriate. See the Edit/Cancel Application function chart (HI 03010.039E.1. and HI 03010.039E.2) for appropriate action for editing and canceling applications.

Denied

N/A

Yes

Process as a new application unless there is an appeal pending. If there is an appeal pending, it will go to the ICTU to be forwarded to the jurisdictional SAU.

N/A

Denied

N/A

No

Process as a new application

N/A

Partial subsidy awarded

No

Yes

Process as a duplicate application unless there is an appeal pending. If there is an appeal pending, forward to the jurisdictional SAU.

Compare applications. If the subsequent application was submitted by the individual, contact the individual to determine if this is an appeal or report of change and take the appropriate action.

If the subsequent application was submitted by a third party, issue Important Information Notice 1 as described in HI 03010.010F.5.a. (NOTE: Notice 1 is a decisional notice and since this is being sent, the duplicate application must not be cancelled.)

Partial subsidy awarded

No

No

Send Important Information Notice 2 as described in
HI 03010.010F.5.a.

N/A

Partial subsidy awarded

Yes

N/A unless the event occurred in the month of initial filing. (Per HI 03050.005, a subsidy changing event is effective with the month after the month of the report.

Process as a Subsidy Changing Event (SCE) Redetermination

N/A

Full subsidy awarded

No

Yes

Send Important Information Notice 2 as described in HI 03010.010F.5.a.

N/A

Full subsidy awarded

No

No

Send Important Information Notice 2 as described in HI 03010.010F.5.a.

N/A

Full subsidy awarded

Yes

N/A

Process as a redetermination

N/A

 
 
If the multiple applications are submitted to both SSA and State Medicaid, CMS determines which decision is valid as follows:
 

SSA
determination was:

State
determination was:

Outcome

Denial

Approval

Approval is official determination. Beneficiary may appeal either decision.

Approval

Denial

Approval is official determination. Beneficiary may appeal either decision.

Denial

Denial

The beneficiary may appeal either decision. If both are appealed and overturned, see the corresponding “approval” scenarios.

Approval

(Different Month)

Approval

(Different Month)

If the subsidy application dates are in different months, the decision on the earlier application is the official determination. The second decision is void.

Approval

(Same Month)

Pending

Approval

(Same Month)

Approval

If the subsidy application dates are in the same month, the SSA decision is the official determination. The beneficiary may appeal either decision.

The system compares the applications. If the SSA application has the same application date as an approved State application or has an earlier date, SSA will continue processing the application. If the State application has an earlier application date, SSA will discontinue processing the application and issue the notice described in the third bullet in HI 03010.010F.4.a.

 
These tables are taken from the SSA Program Operations Management System (POMS).

(Back to Questions about the Low Income Subsidy)

 

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