2305 Commingled Funds

Georgia State Seal

Georgia Division of Family and Children Services
Medicaid Policy Manual

Policy Title:

Commingled Funds

Effective Date:

April 2020

Chapter:

2300

Policy Number:

2305

Previous Policy Number(s):

MT 25

Updated or Reviewed in MT:

MT-59

Requirements

Excluded liquid resources may be commingled in various financial instruments, such as a checking account, only if they are clearly identifiable. However, there are some exceptions. Burial funds may not be commingled with non-burial funds for any ABD Medicaid COA.

Basic Considerations

Identifiability does not require that excluded funds be kept physically apart from other funds, such as in a separate bank account.

Procedures

When withdrawals are made from an account with commingled funds, always assume that non-excluded funds are withdrawn first, leaving as much of the excluded funds in the account as possible.

If excluded funds are withdrawn, the excluded funds left in the account can be added to only in one of the following ways:

  • deposits of subsequently received funds that are excluded under the same provision

  • excluded interest.

Interest earned by funds excluded under this provision may or may not be excluded from resources and income. Refer to Section 2399, Treatment of Income Retained After the Month of Receipt, and Interest in Chart 2399.2, Treatment of Income in ABD Medicaid, for resource and income treatment of interest earned on commingled funds.