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State of Wisconsin |
Release 24-01 |
Agencies may not request verification from health care applicants and members unless the information cannot be obtained through an electronic data source, the income is jail or prison earnings of an inmate (see Section 9.9.6.1 Prison or Jail Job), or information from the data source is not “reasonably compatible” with what the applicant has reported. Information from a data source that supports an eligibility determination based on the attested information provided by an applicant or member is considered “reasonably compatible.”
The following list describes the potential scenarios and whether the scenario results in a determination of reasonable compatibility:
The reasonable compatibility test is only applied to job earnings that have not otherwise been verified (for example, as part of another program’s verification process). It can only be applied when earnings information is available through the State Wage Information Collection Agency (SWICA) or through Equifax from the Federal Data Services Hub (FDSH).
Unearned income (as defined in Section 16.5 Other Income) is verified as outlined in this chapter and in Process Help, Chapter 44 Data Exchange. If there is an electronic data source available to use for verifying a type of unearned income, it should be used as verification for that income. If no data source is available, the applicant or member must provide verification of the unearned income.
Self-employment and in-kind job income are verified as outlined in Process Help, Section 16.2 Self-Employment Income, Process Help, Section 16.6 In-Kind and Volunteer Hours, and Section 16.4.3 Self-Employment Income.
The reasonable compatibility test will be performed as part of any eligibility determination for the following categories of BadgerCare Plus:
Populations not subject to an income test (for example, Former Foster Care Youth) will not have a reasonable compatibility test.
The reasonable compatibility test will apply to each assistance group (AG) for which earned income is reported, has not already been verified, and for which SWICA or Equifax data is available. Because different AGs are subject to different income thresholds, the following thresholds will be used by population as the first step in determining whether reported information is reasonably compatible. In some cases, the threshold will be an FPL percent, while in others it will be a fixed dollar amount.
| Population | Threshold(s) |
|
Adults (MAGS, MAGA and MAGN) |
100% FPL |
|
Children – under age 1 |
306% FPL |
|
Children – ages 1 through 5 |
191% FPL Premium thresholds (unless the child is exempt): 201, 231, 241, 251, 261, 271, 281, 291, and 301% FPL 306% FPL |
|
Children – ages 6 through 18 |
133% FPL 156% FPL Premium thresholds (unless the child is exempt): 201, 231, 241, 251, 261, 271, 281, 291, and 301% FPL 306% FPL |
|
Pregnant women |
306% FPL |
|
FPOS |
306% FPL |
If both the total countable income using information reported by the applicant or member and the total countable income using information from the electronic data source are equal to or less than the threshold, the reasonable compatibility standard is met, and no further verification is required.
If the total countable income using information reported by the applicant or member is equal to or less than the threshold and the total countable income using information from the electronic data source is greater than the threshold, a second step occurs.
In this second step, the total countable income using information from the electronic data source is compared to a threshold that is equal to 120% of the total countable income using information reported by the applicant or member. If the total countable income using information from the electronic data source is equal to or less than 120% of the total countable income using information reported by the applicant or member, the reasonable compatibility standard is met, and no further verification is required.
For populations with multiple thresholds, the lowest threshold that is higher than the reported income is used.
| Note | Because different thresholds are used for different populations, individual members of a household or a given AG may pass the reasonable compatibility test while others do not. |
| Example 1 |
Marty and Jen have two sons, Alex (age 9) and Warren (age 4). They apply for BadgerCare Plus and report that Marty has earnings of $4,914 per month. Equifax data is not available. SWICA reports that Marty has earnings of $5,174 per month. For a group size of four, the reported household income is 189% FPL, while the household income based on SWICA data is 199% FPL. As parents, Marty and Jen are ineligible for BadgerCare Plus based on their reported income of 189% FPL. Each child is subject to a reasonable compatibility test based on the next highest relevant threshold for his age group. For Alex, the reasonable compatibility threshold is 201% FPL. The household’s income based on both the reported income and SWICA is below this threshold, so the reasonable compatibility standard is met, and no further verification is required for Alex. For Warren, the reasonable compatibility threshold is 191% FPL (the threshold for T19 vs. T21 funding of BadgerCare Plus benefits). The household’s income based on reported income is below this threshold, while the household’s income based on SWICA is above this threshold. Therefore, the 20% threshold test is applied. The 20% threshold is $5,897 (the reported income of $4,914 multiplied by 120%, or 1.2). The income based on SWICA data ($5,174) is less than the 20% threshold ($5,897), so the reasonable compatibility standard is met, and no further verification is required for Warren. |
Reasonable compatibility will first be tested based on the household’s total countable income as reported to the agency or verified through other sources. This test will determine whether the member is required to provide verification of earnings.
If the member-reported earnings amount is not reasonably compatible (based on the household’s total reported income), verification of earnings will be required at the same time verification is required for unearned income, self-employment, or tax deductions.
A second verification request will be required if the initial test leads to a determination of reasonable compatibility, but the earnings are no longer reasonably compatible after other income types or deductions have been verified.
If earnings are determined to be reasonably compatible, the amount reported by the member should be used to determine eligibility and premium amounts for health care.
If the earnings are later verified (for example, because verification is required for another program), the verified earnings must be used to determine eligibility and premium amounts for health care.
| Note |
For simplicity, the examples below include households with earned income as the only source of income. It is important to remember that reasonable compatibility is based on the individual’s total countable income, not just their earned income amount. |
| Example 1 |
Joe is a single childless adult with an income limit of $1,255 for BadgerCare Plus. He reports that his earnings are $500 per month. Equifax is not available for his employment. SWICA reports that his quarterly earnings are $2,700, for a monthly amount of $830.77. Because his income is below the income threshold using either amount, his reported information is considered reasonably compatible with the SWICA reported income, and the agency must use the $500 amount he reported without requesting additional verification. |
| Example 2 |
Lon is a single childless adult with an income limit of $1,255 for BadgerCare Plus. He reports that his earnings are $900 per month. Equifax reports that he is paid twice a month at $650 per paycheck, for a monthly amount of $1,300. Lon's reported income is below the income threshold and the Equifax reported income is above the income threshold, so the 20% threshold test is applied. The income reported by Equifax ($1,300) is greater than the 20% threshold amount (120% of $900, or $1,080). Therefore, his reported information is not considered to be reasonably compatible, and the agency must request additional verification. |
| Example 3 |
Melanie is a single childless adult with an income limit of $1,255 for BadgerCare Plus. She reports that her earnings are $1,300 per month. CARES will base the denial on this reported income amount, regardless of the income amount from SWICA or Equifax. |
| Example 4 |
Michelle applies for BadgerCare Plus for herself and her two children. She reports that she started a job last month and is earning $1,400 per month. Because the job is new, neither SWICA nor Equifax data is available. Since these data exchanges are not available, the reasonable compatibility test will not be performed, and Michelle will be required to verify her earnings using paystubs, an EVF-E form, or other documentation. |
| Example 5 |
Katie is a single childless adult with an income limit of $1,255 for BadgerCare Plus. She applies for FoodShare and BadgerCare Plus. She reports that her earnings are $800 per month. Equifax data is not available. SWICA reports that her quarterly earnings are $2,550, for a monthly amount of $784.62. Because she is eligible for BadgerCare Plus using either amount, her reported information is considered reasonably compatible. The agency must use her reported income for BadgerCare Plus, and based on this amount, she would be made eligible for BadgerCare Plus. Her FoodShare eligibility, however, will pend for verification of her earnings. If she returns her paystubs and they show income of $1,300 per month, this information will replace the member-reported information and her health care benefits would be terminated. If she failed to provide the requested verification, her FoodShare benefits would be denied but she would continue to remain eligible for BadgerCare Plus. |
The following rules will be used to determine the data exchange information that will be used for the reasonable compatibility test:
If SWICA data is used, CARES will divide the most recent quarterly SWICA wages by 13 and multiply by four to determine a monthly amount for use in the test.
If Equifax data is used, the following rules will determine the monthly amount for use in the test:
Agencies may not consider Equifax data to be the final “verified” income amount unless the Equifax data is the same as what the member reported. Agencies may not deny or terminate health care benefits based on earned income data received from Equifax without giving the applicant or member an opportunity to verify their reported earned income amount.
If the reported wage amount is the same as the Equifax wage amount, workers may consider the reported wage amount to be verified. If the worker is completing a telephonic application for health care and/or an interview for FoodShare or Child Care, the worker should view the Equifax information during the interview and ask the member if the Equifax-reported amount is correct. If the member agrees that the Equifax-reported amount is accurate, the worker should use the Equifax-reported amount as a verified income amount which is not subject to a reasonable compatibility test.
If the worker is processing an application outside of an interview, and there is a discrepancy between what the member has reported and what Equifax provides, the worker must enter the member-reported information and pend the case for verification. For health care programs, this will trigger a reasonable compatibility test. For other programs, this will cause the case to pend for verification of the member-reported amount.
If the member fails to provide verification and does not contact the agency, FoodShare, Child Care and/or W-2 will fail for lack of verification. Health care will fail for any member whose reported income is not reasonably compatible and who failed to provide requested verification.
However, if the member reports that they are unable to obtain the requested verification, the worker should assist the member in obtaining verification (see Section 9.8 General Rules). If the applicant and/or worker have made reasonable efforts to obtain verification and are not able to do so, then the agency should determine the income amount based on “best available” information, and then document how this amount was determined.
| Note |
The same policies for use of Equifax data apply when a member is reporting a change in income. Equifax data can be used for verification if it is the same as what the member has reported. If it is not the same, health care will apply a reasonable compatibility test to determine whether further verification is required. |
| Example 1 |
Ryan applies online for himself, his wife, and their child, with a request for health care, Child Care and FoodShare. He reports earnings of $9.55 per hour at 30 hours per week from his job at Walmart on the application. The agency does not process the application until the interview for Child Care and FoodShare. During the interview, FDSH is queried for Equifax data and the worker sees that the last four weekly paycheck amounts were for an hourly rate of $9.55 per hour but for 33 hours per week, for a weekly paycheck of $315.15. The worker then confirms with Ryan that this amount is correct and enters this amount on the employment page as verified. Because this information has been reported by the member and verified using Equifax data from the FDSH, it is considered verified for all programs and the income is not subject to reasonable compatibility. |
| Example 2 |
Mindy applies online for herself and her two-year-old twins, with a request for health care, Child Care and FoodShare. She reports $400/week in earnings from her job at Subway. When the worker processes the application for health care (prior to completing the interview for FoodShare and Child Care), the worker finds that Equifax data is available from the FDSH and that her most recent weekly paycheck is $490. Because the member-reported and the FDSH-reported amount are different, the worker pends the case for employment verification. FoodShare and Child Care both pend for interview. Because the employment amount has not yet been verified, a reasonable compatibility test is invoked for health care. For a group size of three, the reported household income is $1,600 per month, or 83% FPL, while the household income based on FDSH data is $1,960 per month, or 102% FPL.
When the worker completes the Food Share/Child Care interview, the worker asks Mindy whether the information provided by Equifax is correct. Mindy confirms that it is. The worker can then use the amount provided by Equifax and consider the income verified. When eligibility is re-run for all programs, the employment is considered verified, and no further verification is needed. |
| Example 3 |
Same as Example 2, except that during the interview, Mindy tells the worker that her hours have changed and that her weekly pay is $400 and not $490. The worker should pend the case for the employment information and issue a verification checklist.
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This page last updated in Release Number: 24-01
Release Date: 04/03/2024
Effective Date: 04/03/2024
The information concerning the BadgerCare Plus program provided in this handbook release is published in accordance with: Titles XI, XIX and XXI of the Social Security Act; Parts 430 through 481 of Title 42 of the Code of Federal Regulations; Chapter 49 of the Wisconsin Statutes; and Chapters HA 3, DHS 2 and 101 through 109 of the Wisconsin Administrative Code.
Notice: The content within this manual is the sole responsibility of the State of Wisconsin's Department of Health Services (DHS). This site will link to sites outside of DHS where appropriate. DHS is in no way responsible for the content of sites outside of DHS.
Publication Number: P-10171