Category: Temporary Home

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

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  COVID-19 ECONOMIC IMPACT PAYMENTS RESULTING FROM THE CONSOLIDATED APPROPRIATIONS ACT, 2021 FOR ALL INCOME MAINTENANCE (IM) PROGRAMS

MANUAL REVISION #

0205.005.30.10  

0210.015.35.40

0805.015.10  

1025.015.01.02

1110.020.30  

1115.015.90

DISCUSSION:

Economic Impact Payments (EIP), also known as Stimulus Payments, were approved as part of the Consolidated Appropriations Act, 2021 (CAA) which was signed into law on December 27, 2020.  The CAA contains changes that affect the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance (TA) Program, Child Care Subsidy (CC), and MO HealthNet (MHN) Programs.

Economic Impact Payments

U.S citizens and resident aliens will receive the EIP up to $600 for each individual and each qualifying child if:

• they are not a dependent of another taxpayer and
• have a work eligible Social Security number with Adjusted Gross Income (AGI) up to:
  • $75,000 for individuals
  • $112,500 for head of household filers and
  • $150,000 for married couples filing joint returns

Reduced Payments: The amount of the reduced payment will be based upon the tax filers AGI.  The EIP will be reduced by 5% of the amount by which their AGI exceeds the applicable threshold shown above up to certain maximums for each tax filing status.

Eligible retirees and recipients of Social Security, Railroad Retirement, Disability or Veterans’ benefits as well as taxpayers who do not make enough money to normally have to file a tax return will receive a payment. This also includes those who have no income, as well as those whose income comes entirely from certain benefit programs, such as Supplemental Security Income benefits.

Retirees who receive either Social Security Retirement or Railroad Retirement benefits will also receive payments automatically.

MO HealthNet Non-MAGI Programs, Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance (TA), and Child Care Subsidy (CC)

• Payments are excluded as income.
• Payments are excluded as a resource for the first 12 months from receipt.

NOTE: EIP payments reported in the month received will be entered as a resource. DO NOT enter as income in FAMIS. Any money left from the EIP 12 months after receipt will be counted as a resource.

Family MO HealthNet (MAGI) Programs

• Payments are excluded as income.

NOTE: Make a comment on the case of the amount received. The payment is not to be entered as income on the case.

• Example of note comment: Ms. Smith reported she received $600.00 from the EIP on 1/4/2021.

FAMIS Entries

If the EIP is reported as income in the month received, enter it as a resource on the SELFRES (FMWB) screen. DO NOT ENTER AS INCOME ON SELINC (FMX2). The excluded amount should always equal the total EIP when entering for the same month it was received along with any other excluded balances for that month. Use Code CV in the Excl Rsn field for the Economic Impact Payment or CB if multiple exclusion reasons exist. Please use the Verification Matrix for acceptable verification codes.

If the balance of the EIP is reported the month after receipt exclude any remaining balance of the EIP in the accounts as CV following normal procedures in entering liquid resources.

Though the EIP amount authorized by the CAA is different, please refer to IM-35 COVID-19 ECONOMIC IMPACT PAYMENTS RESULTING FROM THE CORONAVIRUS AID, RELIEF, AND ECONOMIC SECURITY (CARES) ACT FOR THE MO HEALTHNET, FOOD STAMP, TEMPORARY ASSISTANCE AND CHILD CARE SUBSIDY PROGRAMS for guidance to capture the EIP income as an excluded resource.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/nw/mm/hp/ers

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  COVID-19:  UNEMPLOYMENT COMPENSATION UPDATES RESULTING FROM THE CONSOLIDATED APPROPRIATIONS ACT, 2021

DISCUSSION:

Memo IM-37, dated April 29, 2020, introduced 3 new types of Unemployment Compensation funds that were created on March 27, 2020, as a result 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 December 27, 2020, the Consolidated Appropriations Act, 2021 (CAA) was signed into law.  The CAA enacts changes to the provisions of unemployment funds introduced by the CARES Act:

• FPUC-A $300 weekly federal supplement is added to regular unemployment funds starting after December 26, 2020 and ending March 14, 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 unemployment benefits for eligible individuals who are self-employed, seeking part-time employment, or who would not otherwise qualify for Unemployment Compensation. PUA funds are extended through March 14, 2021 and allow certain individuals to continue receiving benefits through April 5, 2021.  These funds count for all programs.
• PEUC funds provide an additional 13 weeks of unemployment benefits to individuals who have exhausted benefits under regular Unemployment Compensation. PEUC funds are extended through March 14, 2021 and allow certain individuals to continue receiving benefits through April 5, 2021.  These funds count for all programs.

IMES is updated to include all three types of Unemployment.

Verification of Unemployment Compensation Income

Use IMES to identify, budget, and verify gross income and deductions from Unemployment Compensation 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. Review the WEEKLY AMT field to determine the regular weekly amount.
   
3. Enter the WEEKLY AMT as regular unemployment, PUA, or PEUC funds.

NOTE:  Refer to 2020 Hot Tip, Identifying Pandemic Unemployment Types on IMES for more.  

The remaining amount, should be the $300 FPUC funds.  Enter this amount as FPUC.

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 Unemployment Compensation/Insurance is included income for all programs.

Refer participants with questions about Unemployment Compensation 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 Unemployment Compensation, view income verification, request documentation, and report changes in circumstances.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/ers/hrp/mm/sb/nw

FROM:   KIM EVANS, DIRECTOR

SUBJECT:  INTRODUCTION OF THE IM-7A ALTERNATIVE ACCOUNT VERIFICATION FORM
FORM REVISION # IM-7A

DISCUSSION:  The purpose of this memo is to introduce the Alternative Account Verification Form, IM-7A. The IM-7A was created in an effort to provide an additional verification option to verify financial accounts. Use this form in the event a participant can display banking, direct benefit, or other account information on his/her device while in a Family Support Division (FSD) office.

EXAMPLE: Mary has completed an interview for her SNAP/MHABD case in her local office and the interviewer requested a bank statement.  Mary has access to her account information on her phone and while in the office, a staff member views the information on the phone and helps her complete the IM-7A form.  Her bank balance is $4000, but she notes on the form that she recently received a tax refund for $3000.  Mary and the staff member sign the form.

EXAMPLE:  FSD requested bank statements from Sue, who is hospitalized.  Her spouse, John, cannot find any statements.  He visits a local office and states he can view her accounts on their tablet.  A staff member completes the IM-7A form for each account with information viewed on the tablet.  The staff member adds a note to the forms to describe the account balances from the prior quarter months.  John views the entries and he and the staff member sign the form.

The following conditions apply when completing this form:

• The participant must be in an FSD office.

NOTE: Do not request or require a participant come into the office to present account information on an electronic device. Standard verification procedures still apply.

• If the participant completes the gray areas of the form, a staff member must also view the account information on the participant’s device.
• If a staff member completes the form for the participant, the participant must agree with the entries made on the form.
• The participant and the staff member must sign at the bottom of the form.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.
• Begin using the IM-7A immediately

KE/ers/ja/hrp

FROM:  KIM EVANS, DIRECTOR

SUBJECT:  MANUAL UPDATE AND IIVE CLARIFICATION FOR ALL INCOME MAINTENANCE (IM) PROGRAMS

MANUAL REVISION #

0110.025.10

DISCUSSION:

The purpose of this memorandum is to clarify when to utilize IIVE information and to inform staff of an update to the General Information Manual.   Section 0110.025.10 Unearned Income provides clarification that IIVE should be viewed and scanned to the Enterprise Content Management (ECM) system for each eligibility unit (EU) member/household member at the time of the interview or at the time the case is worked if no interview is held.

IIVE is a tool that can be used to verify a participant’s Social Security and/or SSI benefits and any changes to these benefits.  It is only necessary to view and scan the IIVE to the ECM once during the application, recertification, mid-certification (MCR) or annual review/renewal process. 

NOTE:  When scanning the IIVE to the ECM, all pages of the IIVE must be included.

When IIVE has been scanned to the ECM during the application process and subsequent views show no changes, record a comment in the eligibility system regarding IIVE.

NOTE:  For questions regarding when to view and scan IMES to the ECM, refer to memo 2020 IM Memorandum #67 posted May 26, 2020, Manual Update and IMES Clarification for All Income Maintenance (IM) Programs.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

KE/kg/nw/ks/ph