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State of Wisconsin |
HISTORY |
The policy on this page is from a previous version of the handbook.
Agencies may not request verification from health care applicants and members unless the information cannot be obtained through an electronic data source, or information from the data source is not “reasonably compatible” with what the applicant has reported. Information from the data source is “reasonably compatible” if it results in the same eligibility outcome as member-reported information:
The reasonable compatibility test will only be 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 Chapter 16.5) will continue to be verified as outlined in this chapter and in PH Chapter 44. 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 will continue to be verified as outlined in PH 16.4.4 and Section 16.2.
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 AG for which earned income is reported, has not been already been verified, and for which SWICA and/or Equifax data is available. Because different AGs are subject to different income thresholds, the following thresholds will be used by population to determine whether reported information is reasonably compatible. In some cases, the threshold will be a FPL percent, while in others it will be a fixed dollar amount.
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.
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Population |
Threshold(s) |
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Adults (MAGS, MAGA and MAGN) |
100% FPL |
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Adults in extensions with a premium |
Premium thresholds: 133, 140, 150, 160, 170, 180, 190, 200, 210, 220, 230, 240, 250, 260, 270, 280, 290, and 300% FPL |
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Children – under age 1 |
306% FPL |
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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 |
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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 |
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Pregnant women |
306% FPL |
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FPOS |
306% FPL |
For populations with multiple thresholds, the lowest threshold that is higher than the reported income is used.
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Example 1: Fatima is in an extension and reports earnings for a total monthly income of 141% FPL. The reasonable compatibility test would be based on the next highest threshold listed above, which is 150% FPL. |
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Example 2: 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 $3,750/month. Equifax data is not available. SWICA reports that Marty has earnings of $3,955/month. For a group size of 4, 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, at age 9, the reasonable compatibility threshold is 201% FPL. The household’s income based on both the reported income and SWICA are below this threshold, so the reasonable compatibility standard is met and no further verification is required for Alex.
For Warren, at age 4, 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. As a result, the amounts are not reasonably compatible and verification must be provided in order for Warren to become eligible.
If the family provides paystubs that show actual monthly income of more than 200% FPL, both children would be subject to a premium based on the income verified by paystubs. |
The reasonable compatibility test is based on whether using member-reported information about earnings and information about earnings from data exchanges results in the same eligibility outcome when all other countable income is taken into account.
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 that verification is required for unearned income, self-employment, and/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 should then be used to determine eligibility and premium amounts for health care.
In this situation, members are not liable for overpayments because the initial determination was based on income that was reasonably compatible with a data exchange.
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 his or her earned income amount.
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Example 3: Joe is a single childless adult with an income limit of $980.83 for BadgerCare Plus. He reports that his earnings are $500/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 to be reasonably compatible with the SWICA reported income, and the agency must use the $500 amount he reported without requesting additional verification. |
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Example 4: Lon is a single childless adult with an income limit of $980.83 for BadgerCare Plus. He reports that his earnings are $900/month. Equifax reports that he is paid twice a month at $510.50 per month, for a monthly amount of $1021.00. Because there is a difference in the eligibility outcome when applying the Equifax reported income, his reported information is not considered to be reasonably compatible, and the agency must request additional verification. |
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Example 5: Melanie is a single childless adult with an income limit of $980.83 for BadgerCare Plus. She reports that her earnings are $1,200/month. CARES will base the denial on this reported income amount, regardless of the income amount from SWICA or Equifax. |
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Example 6: 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/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. |
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Example 7: Katie is a single childless adult with an income limit of $980.83 for BadgerCare Plus. She applies for FS and BadgerCare Plus. She reports that her earnings are $800/month. Equifax data is not available. SWICA reports that her quarterly earnings are $2550, for a monthly amount of $784.62. Because she is eligible for BadgerCare Plus using either amount, her reported information is considered to be 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 FS eligibility, however, will pend for verification of her earnings. If she returns her paystubs and they show income of $990/month, this information would replace the member-reported information and her health care benefits would be terminated. If she failed to provide the requested verification, her FS 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 (4) 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 and use the verification code of “DE – Data Exchange”. If the worker is completing intake during 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 and a verification code of “DE – Data Exchange.” Because the wage has already been verified, the reasonable compatibility test will not be triggered for this employment.
If the worker is completing intake 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 with a verification code of either ? or Q?. 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 he or she is unable to obtain the requested verification, the worker should assist the member in obtaining verification (see Chapter 9.8). 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.
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Example 8: 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/hour at 30 hours/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 most recent weekly paycheck amount was for an hourly rate of $9.55/hour but for 33 hours/week, for a paycheck of $315.15. The worker then confirms with Ryan that this amount is correct, enters this amount on the employment page and uses DE as the verification code. 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 reasonable compatibility test is not invoked. |
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Example 9: Mindy applies online for herself and her 2-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 enters a Q? on the Employment page and runs eligibility. 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 (3), the reported household income is $1600/month, or 97% FPL, while the household income based on FDSH data is $1960/month, or 119% 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 on the employment page and changes the verification to DE. When eligibility is re-run for all programs, the employment is considered verified and no further verification is needed. |
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Example 10: 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 leave the Q? as the verification code for the employment and issue a verification checklist.
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This page last updated in Release Number: 17-01
Release Date: 04/11/2017
Effective Date: 04/11/2017
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.
Publication Number: P-10171