Department of Social Services
Family Support Division
PO Box 2320
Jefferson City, Missouri
TO: ALL FAMILY SUPPORT OFFICES
FROM: KIM EVANS, DIRECTOR
SUBJECT: INTRODUCING UNCLEAR INFORMATION POLICY ADDED TO THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP) MANUAL
New SNAP manual sections have been added for Unclear Information:
Unclear information is information received during a certification period about a household’s circumstances from which the agency cannot easily determine the effect on the household’s continued eligibility for SNAP benefits.
During a certification period, changes may be reported by the household, an outside source, or an automated report. Even if information is verified upon receipt, it can still be considered unclear if additional verification/information is needed to act on the change.
The following three categories of unclear information must be addressed by the agency when:
- Information is less than 60 days old from the date of receipt and is required to be reported by the household, or
- Significantly conflicting with information reported at the time of application and approved certification, enough to bring the household’s eligibility into question, or
- A match with a participant data matching system is received.
For the categories listed above, the agency must contact the household to resolve the unclear information. For the first two bullets above, the primary method of contact should be by telephone; however, if unsuccessful, a request in writing must be sent.
Note: Data matches are handled differently as described later in this memo.
Example 1: Kenia sends in two consecutive weekly wage stubs (representing less than four weeks’ worth of pay) for an employment not entered on her case record. The wage stubs are less than 60 days old. The household is subject to a gross income limit and already has earned income on file for a different job. After calling Kenia, she states this is a new job in addition to her previous employment. Verification of the new income must be requested.
Example 2: When Becky applied for SNAP benefits on August 21, she did not list she was working on her application and no employment information was found at that time; however, information is received on November 5, which indicates that Becky was employed when she applied. Although the information is more than 60 days old, it significantly conflicts with information used during Becky’s certification. After attempting to contact Becky by phone, a request for information must be sent.
If the unclear information is a change to information used for the eligibility determination and can be requested using the Request for Information (RFI, FA-325), a RFI should be generated and sent to the household. If there is not enough information for a RFI, the household should be sent a Request for Contact (RFC, FA-331). The RFI or RFC must clearly advise the household of what is needed to resolve the situation, what will happen if the household fails to act, and allow 10 days for a response.
Note: The RFI should be used any time information is needed on an eligibility factor while the RFC should only be used if there is not enough information provided to send an RFI.
A household that does not respond to the RFI/RFC or does respond but does not provide enough information to clarify/resolve the situation must be sent a notice of adverse action (NOAA). If there is no response to the NOAA, the SNAP case must close.
Eligibility system updates have been made for the RFC (FA-331) to comply with the requirements set for unclear information. Please review Email Memo 52 (10/07/2022) for further instructions for how to resolve a request which used the RFC.
Example 3: Charlotte reported her husband Mike switched jobs and provided one paystub with bi-weekly earnings of $2000.00 showing a sign-on bonus of $750.00. The agency attempted to call Charlotte, and a RFI is sent to Charlotte advising an additional paystub for Mike is needed within 10 days. Charlotte fails to respond to the RFI within 10 days, and a NOAA is sent. When Charlotte does not respond to the NOAA and no additional information is received, her case is closed as she failed to provide the requested verification.
While all unclear information must be documented, not all unclear information requires immediate action from the agency. No case action is required for information that does not meet the unclear information criteria above. For information that is older than 60 days, required to be reported, or significantly different than information used for the certification, case notes should be made in the eligibility system and the information must be explored at the next mid-certification review or recertification.
Example 4: Leonor reports that her children’s daycare provider changed in the last 10 days. She does not state if her expenses have increased or decreased, but a search shows the new daycare is the same number of miles from her work as her old daycare. As this is information Leonor is not required to report and she previously had a daycare expense budgeted, a note is made on Leonor’s case for her daycare expenses to be revisited at her next mid-certification or recertification.
Information from Certain Data Matches:
Periodically, the agency receives matches from certain data sources. These matches are used to verify and ensure SNAP benefits are not issued to individuals who may not be eligible for a variety of reasons. Data matches are considered unclear if the match is not considered verified upon receipt.
Note: Please review 1140.005.60 Changes Considered Verified Upon Receipt for a Household to see what types of information are considered verified upon receipt.
Although considered unclear, data matches must be handled differently from other unclear information. Households must be sent a Notice of Match Results (NOMR). Currently, the NOMR for a Death Match result will be in production 01/22/2023-this memo will be released shortly. Other NOMR’s are still under development. Additional information will be released when other NOMR’s are implemented.
- Review this memorandum with appropriate staff.
- Review Email Memo 52 (10/07/2022) for additional information about the RFC (FA-331)