Oregon DHS Partnering with Accuity for Asset Verifications

Accuity has begun sending requests to the financial institution community and volume is soon to increase.

Compliance image12/18/18

The Oregon Department of Human Services (DHS) has sent notices to financial institutions, which provides information regarding the update to the process the DHS uses for verifying the assets owed by individuals applying for or receiving Medicaid benefits.

DHS is transitioning from a paper-based account verification process to an electronic system provided by Public Consulting Group (PCG). This system can search for an individual’s assets with identifying information. Verifying assets electronically is a new federal requirement for Medicaid benefits.

PCG has partnered with Accuity Asset Verification Services Inc., to perform the verifications. Credit unions in Oregon may remember that Accuity AVS was chosen by the Idaho DHS to perform their asset verifications.

Accuity has begun sending requests out to the financial institution community, and the request volume is expected to increase over the next few months as the program expands across Oregon.

Credit unions have a couple options for expediting and/or automating the tasks associated with providing this information.

Accuity offers to work with all financial institutions on full automation at no charge to allow them to securely and efficiently respond to asset verification requests. The two automation options are batch and web service connections. Alternatively, a credit union can use a web-based portal.

The letter sent by the DHS to the CEOs and Managers of the financial institutions in Oregon provides contact information to sign up with Accuity.

Credit unions would still be advised to have your legal counsel review any contract for services prior to setting up the services.

Question of the Week

Is the member responsible for unauthorized EFTs?

Under Regulation E, a member may be liable for an unauthorized EFT only if the credit union provided the required disclosures, the unauthorized transfer involved an access device that the member accepted, and the credit union can identify the member to whom the device was issued.

If the above has occurred, the member may be liable for the lesser of $50 or the amount of the unauthorized transfer, with two exceptions:

  • If the member does not notify the credit union within two business days after learning of loss of the access device, liability to the member changes to the lesser of $500, or the sum of: $50, or the amount of unauthorized EFTs that occur before the close of the two business days, whichever is less, plus the amount of unauthorized EFTs that occurred after the close of the two business days and before notifying the credit union. The credit union would have to establish that the transfers after the close of the two business days would not have occurred but for the failure of the member to notify the credit union within two business days.
  • If the member does not report the unauthorized transfer that appears on a periodic statement within 60 days of the transmittal of that statement, the member is liable for the sum of: the lesser of $50, or the number of unauthorized transfers that appear on the statement or occurring during the 60 day period, plus the number of unauthorized EFTs occurring after the close of the 60 days and before notice was given to the credit union. The credit union must establish that the unauthorized EFTs occurring after the close of the 60 days would not have occurred but for the failure of the member to notify the credit union within 60 days.

Note: Visa rules may impose zero liability on the member; however, this is a separate issue from the liability in Regulation E.

Related Links

12 CFR 1005.6

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The NCUA released the Board actions from the recent NCUA Board meeting. The actions include reducing the normal operating level of the NCUSIF to 1.38 percent, posting the task force recommendations to return to regular three-year rolling review of NCUA’s regulations, and a final rule making technical amendments to agency regulations to correct minor drafting errors and rescind certain unnecessary provisions.

Internal Revenue Service (IRS)

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Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of Dec. 14, 2018. The last update prior to this was Nov. 28, 2018.

Questions? Contact the Compliance Hotline: 1.800.546.4465; compliance@nwcua.org.