Category: Food Stamp Home

FROM: KIM EVANS, DIRECTOR

SUBJECT: ANNUAL INTERNAL REVENUE SERVICE (IRS) SAFEGUARDS INTERNAL INSPECTIONS REPORT-INDIVIDUAL TELEWORK

DISCUSSION:

Federal regulations require Family Support Division (FSD) staff with access to federal tax information (FTI), to complete an annual internal inspection.

Internal Inspections

Federal regulations require agencies to conduct internal inspections of all offices with access to FTI to ensure that the information is adequately safeguarded. To comply with this IRS requirement, all staff, including those working remotely (sometimes known as teleworkers), must complete the electronic Internal Inspections Report.

Complete and submit the Internal Inspections Report annually.  To access the Internal Inspections Report, sign into Employee Learning Center (ELC) and go to Internal Inspection Procedure. Click on the “Internal Inspections Report Individuals Telework Office” button at the top of the page indicating the individual inspection. The required report is also available online at https://apps.dss.mo.gov/FSDIRSSafeguardingForms/ for staff who do not have access to the ELC.

The ELC will email staff a reminder 30 days before an Internal Inspection Report is due.  It is not necessary to complete the course more than once every 12 months, or until a new email reminder is received. 

NECESSARY ACTION:

• Review this memorandum with appropriate staff.
• Complete the online Internal Inspection Report annually.

KE/

FROM: KIM EVANS, DIRECTOR

SUBJECT: COVID-19:  UNEMPLOYMENT COMPENSATION UPDATES RESULTING FROM THE AMERICAN RESCUE PLAN ACT (ARPA) OF 2021 FOR ALL PROGRAMS

DISCUSSION:

Memorandum IM-37, dated April 29, 2020, introduced 3 new types of Unemployment Compensation Benefit (UCB) funds that were created on March 27, 2020, as a result of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. 

Those funds were the Federal Pandemic Unemployment Compensation (FPUC) fund, the Pandemic Unemployment Assistance (PUA) fund, and the Pandemic Emergency Unemployment Compensation (PEUC) fund.

On March 11, 2021, the American Rescue Plan Act (ARPA) of 2021 was signed into law.  The ARPA extends the expiration dates for UCB funds introduced by the CARES Act:

• FPUC-A $300 weekly federal supplement is added to regular UCB funds starting after December 26, 2020. This fund has been extended through September 6, 2021.  FPUC funds are excluded/non-countable income for the Supplemental Nutrition Assistance Program (SNAP) and all MO HealthNet programs (except for sighted spouses on Blind Pension determinations).
• PUA funds provide UCB for eligible individuals who are self-employed, seeking part-time employment, or who would not otherwise qualify for UCB. PUA funds are extended through September 6, 2021.  These funds count for all programs.
• PEUC funds provide an additional 13 weeks of UCB to individuals who have exhausted their regular UCB. PEUC funds are extended through September 6, 2021. These funds count for all programs.

Verification of Unemployment Compensation Income

Use IMES to identify, budget, and verify gross income and deductions from UCB for Missouri unemployment recipients.

1. Review the COMP WEEK column of the IMES. Total all payments made per the CHECK AMT column for each specific COMP WEEK date to determine a gross payment amount. In the red box below, the total payment made for the COMP WEEK 12/30 is $620.00 ($558 + $62=$620).

2. Enter $300 as FPUC funds.

3. Deduct the $300 FPUC amount from the gross amount. The remaining amount should be the WEEKLY AMT. Enter the WEEKLY AMT as regular UCB, PUA, or PEUC funds.
   For MAGI determinations, the self-attested amount may be different than the amount shown on IMES. Starting with the self-attested amount, deduct the first $300 and enter it as FPUC funds, which are excluded.  The remaining amount is the self-attested regular UCB, PUA, or PEUC funds.
   NOTE:  Refer to 2020 Hot Tip, Identifying Pandemic Unemployment Types on IMES for more.  

4. For FAMIS determinations, evaluate the REC column of the IMES for child support payments (CHSP). If child support payments are deducted, budget the payments on the Court Ordered Expense (SUPEXP/FMXL) screen in FAMIS using normal budgeting procedures. 

5. Review the budget screens in the eligibility system before authorization. Regular UCB is included income for all programs.

Refer participants with questions about UCB to the Missouri Department of Labor and Industrial Relations interactive site at uinteract.labor.mo.gov.  Participants can use this site to file claims for UCB, view income verification, request documentation, and report changes in circumstances.

Subsequent updates to UCB will be released in additional memos.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/ers

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  CONTESTING THE WORK NUMBER INFORMATION

DISCUSSION:

If the participant believes that the information provided by The Work Number is incorrect, for example an incorrect employer is listed, they can contact Equifax directly:

Telephone: 1-866-349-5191
Mail: Equifax Information Services LLC
P.O. Box 740256
Atlanta, GA 30374-0256

Example:  Mr. B contacts the FSD Customer Service Center to report that the gross earnings reported by The Work Number for his most recent pay periods are incorrect.  Staff suggests to Mr. B that he contact his employer to confirm the accuracy of this information.

Example:  Mr. M contacts the FSD Customer Service Center to report that he has never worked for the company that is reported by The Work Number.  Staff suggests to Mr. M that he contact Equifax to report this information as inaccurate.  If staff determine that this does appear to be an error on The Work Number report, this income must not be included in the eligibility determination. 

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/rr/kg/am/cs/sb

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  THE WORK NUMBER MANUAL NOTICE REQUIREMENT FOR NEGATIVE ACTIONS

FORM REVISION #

IM-50E

DISCUSSION:

The Fair Credit Reporting Act (FCRA) requires the Family Support Division to notify participants when a negative action is the result of information reported by a consumer reporting agency such as The Work Number.

System work is currently being completed in FAMIS and MEDES to add required FCRA language to adverse action notices and action notices when a negative action is taken due to information provided by a specific FCRA source.

FCRA wording has been added to adverse action and action notices related to rejections and closings in FAMIS.  Additional information is available in Email Memo IM-11 Phase 1:  FAMIS Verification Codes and Fair Credit Reporting Act (FCRA) Notification Added to FAMIS Notices, dated 3/22/2021

For all other negative actions that are a result of information provided by The Work Number, staff must mail an IM-50E when the adverse action and action notices are sent.

Memorandums will be released as each phase of the system work is complete.  

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/rr/kg/am/cs/sb

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  THE WORK NUMBER FAIR CREDIT REPORTING ACT REQUIREMENTS

DISCUSSION:

The information provided by The Work Number is subject to FCRA requirements.  Refer to manual section 0110.060.05 Electronic Verification System Legal Basis for more information. 

Policy regarding proper authorization to review FCRA sources is available in the Electronic Verification System portion of the General Information manual.

A guide outlining when an IM-6EVS is required is in development.   

Eligibility unit members who are not applying for or receiving benefits must sign an Authorization for Verification (IM-6EVS) form before FSD can access their employment verification in The Work Number portal. 

To determine if an IM-6EVS is required consider the following: 

• Requesting benefits: Do not request a signed IM-6EVS.  The request for benefits on the application provides the necessary authorization to consult FCRA sources.

• Not requesting benefits: If the individual is a mandatory member of the eligibility unit a signed IM-6EVS is needed..

NOTE:  Refer to each program policy for mandatory members

As discussed in manual section 0110.060.15 Fair Credit Reporting Act Authorization, the IM-6EVS is valid until benefits are denied or terminated, or FSD receives a written and signed revocation.

Questions:

Questions should be sent through normal supervisory channels. Policy questions can be submitted by managers to the policy unit email addresses:

          MHABD and Family MHN: COLE.MHNPOLICY@dss.mo.gov

          SNAP: COLE.FSPOLICY@dss.mo.gov

          TA and CC: FSD.COLETAPOLICY@dss.mo.gov

For case specific policy clearances, utilize the Request for Interpretation of Policy (IM-14) process.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/rr/kg/am/cs/sb

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  THE WORK NUMBER BY EQUIFAX PORTAL          

DISCUSSION:

The Family Support Division (FSD) is adding The Work Number portal to the Electronic Verification System (EVS).  The Work Number provides earned income verification.   

• When the Work Number provides a response for an employer a cost is incurred. Only utilize The Work Number portal for all programs at the time of:
  • Initial application—when earned income is reported
  • Recertification—when earned income is reported.
    • Reminder: Manual section 1102.020.00 Verification Required at Recertification states that at the time of SNAP recertification, verification is not required if the source of income has not changed and amount of income has not changed by more than $50
  • Annual renewal—when earned income is reported

• Exhaust all other electronic resources, such as IMES, prior to requesting information from The Work Number.
• Staff must only access The Work Number one time per application period and not more than once in a 30 day time period.

EXAMPLE:  Mrs. Z submits a Supplemental Nutrition Assistance Program (SNAP) application on 2/1/2021 and a Child Care (CC) application on 2/15/2021.  The Work Number printout from the SNAP application is valid at the time of the CC application.  If Mrs. Z reports a change in earnings on the CC application, do not consult The Work Number portal a second time in the 30 day time period.  Request verification of the change in earnings from the participant.      

• Employment verification provided by The Work Number can also be used for other eligibility factors such as:
  • work months for Able Bodied Adults without Dependents (ABAWD) determinations or
  • hours worked for eligible student status for the SNAP program.

• If the participant submits adequate verification of their earnings with their application, do not request a report from The Work Number.
• If information reported by The Work Number does not match the participant’s statements, call the participant to resolve the discrepancy. If a collateral contact with the employer is necessary, staff can make a three-way call with the employer to verify the information.  If the collateral contact is unsuccessful, a Request for Information Notice (FA-325 for cases processed in FAMIS or IM-31a for cases processed in MEDES) is needed for the additional verification and documentation.

Do NOT utilize The Work Number in the following situations:

• SNAP Mid Certification Review
• Add a person or add a category requests, even if earned income is reported by the participant
• Reports of a change in circumstance
• Earned income is listed on IMES, but is not reported by the participant on the application/review form or during the interview
  • NOTE: Comments/notes in the eligibility system must reflect the review of this data and document any discussions held with the participant. 

Questions:

Questions should be sent through normal supervisory channels. Policy questions can be submitted by managers to the policy unit email addresses:

MHABD and Family MHN: COLE.MHNPOLICY@dss.mo.gov

          SNAP: COLE.FSPOLICY@dss.mo.gov

          TA and CC: FSD.COLETAPOLICY@dss.mo.gov

For case specific policy clearances, utilize the Request for Interpretation of Policy (IM-14) process.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/rr/kg/am/cs/sb

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  FAMILY SUPPORT DIVISION (FSD) CUSTOMER SERVICE HOURS CHANGE       

DISCUSSION:

The FSD Customer Service Centers will be closed on Saturday, April 3, 2021.   All centers will reopen on Monday, April 5, 2021 and will return to their normal hours of operation.  Effective April 5, 2021, hours of operation will be Monday through Friday 6:00 am to 6:00 pm.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/vm