Updated May 26, 2022
In This Section |
This section contains the following topics:
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1. IVM Procedures
Introduction |
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This topic contains information on income verification, including
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Change Date |
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May 26, 2022
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XIV.4.D.1.a. Processing IVM Reports |
The table below outlines the steps the pension management centers (PMCs) must follow when processing Income Verification Match (IVM) reports.
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2. Income Verification
Introduction |
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This topic contains information on income verification, including
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Change Date |
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November 4, 2016
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XIV.4.D.2.c. Payer Will Not Furnish Information |
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If a response is received that essentially states that the payer will not furnish the information requested, the verification requirement has been met.
Reference: For more information on the efforts to clarify disputed amounts, see M21-1, Part XIV, 4.D.12.
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3. Initial Verification Requests
Introduction |
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This topic contains information on initial verification requests, including
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Change Date |
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November 4, 2016
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XIV.4.D.3.e. Incompetent Payees |
Hines ITC does not send a verification letter to a recipient or a recipient’s spouse if the corporate record shows the beneficiary is incompetent and not paid directly.
Hines ITC will, however, send letters to the payers of earned income in these types of cases.
Reference: For more information on instructions and limitations on fiduciary contacts, see M21-1, Part XIV, 4.B.4.
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XIV.4.D.3.f. Worksheets |
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At the same time the Hines ITC sends letters, it produces worksheets and refers them to PMCs for matched cases.
If there is more than one income recipient (for example, beneficiary and spouse) there is a separate worksheet section for each person’s income.
Reference: For a sample of an IVM worksheet, see M21-1, Part XIV, 4.D.15.
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4. Operational Performance and Establishing Controls
Introduction |
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This topic contains information on operational performance and establishing controls, including
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Change Date |
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November 4, 2016
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XIV.4.D.4.b. Establishing an EP |
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Establish an EP when the worksheet is received. Use date of receipt of the worksheet as date of claim.
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XIV.4.D.4.c. Suspense Date |
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The suspense date is automatically set for 60 days. Leave the EP pending until final action is taken.
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5. Initial Screening
Introduction |
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This topic contains information on initial screening, including
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Change Date |
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November 4, 2016
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XIV.4.D.5.a. Verification of Income Not Required |
When the worksheet is received, compare information on this sheet with information in the corporate record and/or claims folder. Verification of income and further development are not required if any one of the following applies:
Note: Do not consider amounts received from participation in the Veterans Health Administration’s (VHA’s) Compensated Work Therapy (CWT) Program as income for pension or IU purposes.
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XIV.4.D.5.d. Verification of Income and Employment Needed |
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If verification of income and employment is needed:
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6. Effective Dates of Adjustment for Pension and Parents’ DIC Due to IVM
Introduction |
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This topic contains information on effective dates of adjustment for pension and Parents’ DIC, including
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Change Date |
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November 4, 2016
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7. Differing Responses From Payer and Recipient
Introduction |
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This topic contains information on differing responses from payer and recipient, including
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Change Date |
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November 4, 2016
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XIV.4.D.7.a. Differing Response Procedures |
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Use the table below to determine what to do when receiving differing responses from the payer and the recipient, including the spouse of the beneficiary.
Reference: For more information on the efforts to clarify disputed amounts, see M21-1, Part XIV, 4.D.12.
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8. Income Payer Response Only
Change Date |
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November 4, 2016
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XIV.4.D.8.a. Payer’s Report Only |
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When the income payer responds, but the recipient does not respond to the income match query, send a notice of proposed adverse action based on the payer’s report.
Reference: For more information on the efforts to clarify disputed amounts, see M21-1, Part XIV, 4.D.12.
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9. Income Recipient Response Only
Change Date |
May 26, 2022
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XIV.4.D.9.a. Response to FTI Match |
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Use the guidelines in the table below when
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10. No Response From Payer or Recipient Within 30-Day Period
Introduction |
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This topic contains information on handling no response from payer or recipient within the 30-day period, including
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Change Date |
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November 4, 2016
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XIV.4.D.10.b. Payer Will Not Furnish the Information |
If a response is received that indicates that the payer will not furnish the information, consider the verification process complete and adjudicate the claim based on the evidence of record.
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XIV.4.D.10.c. Verification Process Is Complete |
Once the verification process is complete
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XIV.4.D.10.d. Beneficiary Responds |
Use the table below to determine what action to take once the beneficiary responds.
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11. Recipient Claims Income Belongs to Someone Else
Introduction |
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This topic contains information on recipient claims that income belongs to someone else, including
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Change Date |
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November 4, 2016
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XIV.4.D.11.a. Income Statement |
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Instances may arise where the income recipient indicates that income identified by the match was
In these situations, ask the income recipient to furnish a statement from the financial institution or other source of the income. The statement should show the names of the owner or owners of the funds or property which generated the income during the time frames in question.
Provide 60 days for a response.
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XIV.4.D.11.b. When There Is No Response Within 60 Days |
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If no response is received within 60 days, treat the income as that of the income recipient.
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XIV.4.D.11.c. Jointly Owned Property |
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If the income recipient submits a statement from the financial institution or other source of the income showing that the income recipient and another person or persons jointly owned the property generating the income, count only the income recipient’s proportional share of the income on partial transfer of property by a claimant.
Reference: For more information on partial transfer of property by a claimant, see M21-1, Part IX, Subpart iii, 1.I.10.
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XIV.4.D.11.d. Funds Paid or Credited to Recipient |
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If funds were paid to the income recipient or credited to the income recipient’s account, the income recipient’s proportional share of the income must be counted in determining eligibility for VA benefits, irrespective of any informal arrangements that might have existed.
Reference: For more information on proportional share of income, see M21-1, Part IX, Subpart iii, 1.I.1.
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XIV.4.D.11.e. Handling Reports of Identity Theft |
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If the income recipient reports identity theft, then request the recipient provide proof of the theft. Proof of identity includes, but is not limited to, the following:
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12. Efforts to Clarify Disputed Amounts
Introduction |
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This topic contains information on efforts to clarify disputed amounts, including
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Change Date |
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April 16, 2018
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XIV.4.D.12.a. Clarifying Disputed Amounts |
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If the amount of money reported in the IVM is disputed, either in whole or in part, during the verification process or during due process and that disputed amount will adversely affect the amount of VA benefits payable, further efforts should be undertaken to clarify the discrepancy.
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XIV.4.D.12.b. When the Information Provided Does Not Agree With the IRS |
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VA may notify the payer, income recipient, or both, that the information provided does not agree with information obtained from the IRS and request clarification with supporting documentation.
Likewise, if the income recipient is the spouse, VA may attempt to verify the information with the VA beneficiary. This could be done by letting the Veteran know the spouse was sent a letter on a given date and that the Veteran should provide information regarding that income.
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XIV.4.D.12.c. When Evidence Proving IRS or SSA Data Is Incorrect |
If evidence is received proving the IRS or Social Security Administration (SSA) data is incorrect, adjudicate the claim based on the evidence of record.
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XIV.4.D.12.d. Delay of Letter |
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When it is necessary to clarify a disputed amount, if possible, the notice of proposed adverse action should not be sent until the issue is resolved.
Multiple notices of proposed adverse action, award actions, and final decison letters may confuse the beneficiary.
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XIV.4.D.12.e. When the EP Is Pending |
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Although the EP must be left pending until the issue is finalized, it should not adversely affect timeliness.
If it appears that there will be a long delay while resolving the discrepancy, and the evidence indicates that current benefits are also being overpaid
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XIV.4.D.12.f. When the Criteria Are Not Met for Referral to OIG |
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If the case does not meet the criteria for referral to the Office of Inspector General (OIG), the claims processor may request that a Field Examiner contact the income recipient and obtain copies of needed income tax returns, supporting documents and any other evidence that might be needed.
Reference: For more information on fraud and forfeiture discontinuance provisions, see M21-1, Part X, Subpart iv, 3.A and B.
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XIV.4.D.12.g. When a Potential Fraud Case Meets OIG Criteria |
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If the case is a potential fraud case and meets the criteria for referral to OIG, a field examination could compromise the case as far as the U.S. Attorney or OIG is concerned. The Veterans Services Center Manager shall contact the local OIG to see if they would be willing to conduct any needed investigation.
If OIG chooses not to conduct an investigation, the regional office (RO) may request a field examination.
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13. Due Process
Introduction |
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This topic contains information on due process, including
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Change Date |
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November 4, 2016
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XIV.4.D.13.a. Due Process Requirements |
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After the income is verified, due process procedures require VA to give the beneficiary a 60-day opportunity period to submit evidence to show why a reduction or termination should not be made.
Reference: For more information on due process, see M21-1, Part I, Subpart i, 1.B.
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XIV.4.D.13.b. Separate Income Verification |
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Separate income verification by the income recipient, who is also the VA beneficiary, does not eliminate the need for due process. VA’s agreement with the IRS and SSA states that VA shall provide a notice of proposed adverse action in all cases, no matter who provides the separate verification.
This is an exception to the normal rule that a notice of proposed adverse action is not required if the adjustment is based on self-reported information.
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XIV.4.D.13.c. When Pension Benefits Began During Year of Match |
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In cases where pension benefits began during the year of the match, the notice of proposed adverse action must inform the beneficiary that, in the absence of information to the contrary, the income will be annualized over the entire year.
The letter also will inform the beneficiary that if the income terminated prior to the effective date of the award, or the amount varied from month to month, the beneficiary should provide evidence to explain the
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XIV.4.D.13.d. Example: Due Process |
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Situation:
Result: The notice of proposed action
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14. Considering Earnings in IU and Pension Cases
Introduction |
This topic contains information on considering earnings in IU and pension cases, including
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Change Date |
November 4, 2016
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XIV.4.D.14.a. Referral of IU Cases to ROs |
Only IU cases with earned income over the current poverty threshold are referred to ROs.
Note: Amounts received from participation in VHA’s CWT Program are not considered income for IU purposes.
Reference: For more information on the U.S. Census Bureau’s poverty threshold, see the U.S. Census Bureau’s Historical Poverty Threshold website.
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XIV.4.D.14.b. Verification of Earnings in IU Cases |
If, after initial review, verification of earnings from employment is needed in an IU case, see the references listed below.
References: For more information on
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XIV.4.D.14.c. Referral of IU Cases to Rating Activity |
When verification is received, or after 60 days if no response from payer or Veteran, refer the IU case to the rating activity at the RO of jurisdiction to determine the need for a physical examination.
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XIV.4.D.14.d. Determining the Need for an Examination in IU Cases |
To determine the need for an examination in an IU case, the rating activity shall review the information submitted by the Veteran and/or the Veteran’s employer. If VA Form 21-4140 indicates the Veteran reported the earnings and VA failed to take action, it is an administrative error.
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XIV.4.D.14.e. Rating Proposal to Reduce Benefits in IU cases |
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After all evidence has been reviewed, the rating activity shall prepare a rating proposing to reduce benefits and refer the IU case to the authorization activity. If the rating activity proposes to reduce benefits, follow the provisions of M21-1, Part X, Subpart ii, 3.A.
Reference: For more information on handling fraud, see M21-1, Part X, Subpart iv, 3.A.
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XIV.4.D.14.f. Considering Protected SC Evaluations in IU Cases |
Use the table below to determine when service-connected (SC) evaluations are protected in IU cases.
Reference: For more information on protected evaluations, see 38 CFR 3.951.
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XIV.4.D.14.g. Referral of a Pension Case for P&T Determination |
PMC employees have the discretion to decide whether or not to refer a pension case, in which earned income is established, to the rating activity for a determination of continued permanent and total (P&T) disability status.
Note: Do not refer a pension case for P&T determination if pension can be granted on a presumptive basis for the applicable period in question.
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XIV.4.D.14.h. Pension Terminated Without Referral to the Rating Activity |
If pension is terminated for earned income and the case is not referred to the rating activity, flash the claims folder for referral in case the Veteran files a supplemental claim.
Note: Do not flash the claims folder for referral if pension can be granted on a presumptive basis for the applicable period in question.
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15. Exhibit: Sample IVM Sheet
Change Date |
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November 4, 2016
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XIV.4.D.15.a. Sample IVM Sheet |
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Below is a sample of page one of an IVM sheet.
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