M E M O R A N D U M

IM-52  03/23/00  REJECT OF TIMELY RECERT - FS MAN REV #10


SUBJECT:
REJECTION OF TIMELY RECERTIFICATIONS

   FOOD STAMP MANUAL REVISION #10 :

   1130.005.00, PAGE #1130-1
   1130.020.05, PAGE #1130-3
   1130.020.15, PAGE #1130-4
   1130.020.20, PAGE #1130-5
   1130.020.25, PAGE #1130-5
   1130.020.30, PAGE #1130-6

 
DISCUSSION:
Staff requested clarification of the policy regarding the rejection of timely food stamp recertifications.

Households who complete a timely reapplication for food stamp benefits have until the end of the current certification to provide the requested information.  If the household fails to provide requested verification by the last day of the certification, and has had ten days to provide the information, the application is rejected the next working day.

Example 1: Mr. A is certified through February 2000.  He completes a timely reapplication on February 14, 2000.  He has until Tuesday, February 29, 2000, to provide requested verification.  Mr. A does not provide the verification.  On Wednesday, March 1, 2000, the application is rejected.

Example 2: Mr. B is certified through April 2000.  He completes a timely reapplication on April 11, 2000.  He has until Sunday, April 30, 2000, to provide requested verification.  Mr. B does not provide the verification.  On Monday, May 1, 2000, the application is rejected.

Example 3: Ms. C is certified through June 2000.  She completes a timely reapplication on June 5, 2000.  She reports a new job on June 23, 2000.  Her caseworker requests the verification of her new employment on June 23, 2000.  Ms. C has until Monday, July 3, 2000, to provide the verification.  She does not provide the requested verification.  On Wednesday, July 5, 2000, the application is rejected.

The Food Stamp Manual sections 1130.020.20-1130.020.25 are revised to provide clarification of this policy.  The Food Stamp Manual sections 1130.000.00-1130.025.00 are revised to reflect EBT language.

The Food Stamp Program and Policy Unit is working with Data Processing to correct the due dates on the Weekly Application Control Report.  Programming is also necessary in the FSU5 system to not require delay codes.  Until the programming is complete, enter a client delay code.  Supervisors need to keep track of the number of timely reapplications that are rejected and are not counted as delayed for the worker.  Staff will be notified when these changes are made.

 
NECESSARY ACTION:
  • Review and discuss this memorandum with all appropriate staff.

  •  
  • File the revised manual section in the hard copy of the Food Stamp Manual.

  •  
  • Use a client delay rejection code when rejecting these applications until programming is complete that will not require a delay code.
  • REM
    Distribution #3

    [ Memorandum Table of Contents ]


     
    1130.000.00  CERTIFICATION PROCEDURES

    After investigating all eligibility factors, either:

     1. approve the application as soon as possible but not later than the date which allows for household participation by the 30th day after the application is filed except in those cases in which the household is eligible for expedited service (approval of the application includes the opportunity to participate);

     2. reject the application within 30 days after the date the application is filed; or

     3. if the household was not provided an opportunity to participate within 30 days of the day the application is filed, determine the cause of the delay and take appropriate action.


    1130.005.00    Opportunity to Participate DEFINED
    IM-#52  March 23, 2000

    Households determined eligible have an opportunity to participate as soon as possible, but not later than 30 days after the application is filed.  An opportunity to participate consists of providing households with a Benefit Security Card. 

     1. If the Benefit Security Card is mailed to the household, allow one working day for mail issuance processing and two mail days for delivery.  (Do not include Sunday or postal holidays as mail days.)

     2. Consider the household denied the opportunity to participate if the Benefit Security Card is mailed on the 29th or 30th day.


    1130.010.00    PRORATION

    Prorate a household's benefit level for the initial month of certification from the day of the month it applies for benefits.  Initial month is defined as the first month the household is certified for participation following any period the household was not certified for participation.  Different regulations regarding proration apply for new applications and for recertifications.

    1130.010.05     Proration for New Applications

    Prorate the initial month's benefits based on the date of application.

    1130-1


    If a household is certified for one or two months during the last half of the month of application and the household is notified in writing of the date by which it must reapply to avoid an interruption in benefits, the specified period protects the household from the initial month proration of benefits.

    EXAMPLE:  A household is certified for two months and notified it must reapply by 5/6.  If it reapplies any time before the end of the day on 5/6, the household is given a full month's benefits for May, not a prorated issuance.  May is not considered an initial month for this household.

    EXCEPTION:  Migrant and seasonal farm worker households are entitled to a full allotment rather than a prorated allotment as long as the break in participation does not exceed 30 days.

    EXAMPLE:  A migrant household certified through March reapplied on 4/12.  The household receives a full allotment for April.

    NOTE:  For households jointly applying for SSI and FS prior to release from an institution, prorate benefits from the date of release from the institution.
     

    1130.010.10     Proration for Recertifications

    If the household submits an application for recertification prior to the expiration of its certification period and is found eligible for the first month following the end of the certification period, that month is not an initial month and do not prorate the allotment.

    EXAMPLE:  A household's certification period ends on 5/31, and the household submits its application for recertification on the same date.  In this case, even though the application for recertification may not actually be approved until mid-June, no gap exists between certification periods.  Therefore, June is not an initial month and the household allotment is not prorated.

    EXAMPLE:  A household's certification period ends on 3/31, but the household does not reapply until 4/3.  If the household is eligible, its April benefits are prorated for the period 4/3 through 4/30.
     

    1130.015.00    ANTICIPATED CHANGES AT TIME OF APPLICATION

    Because of anticipated changes, a household may be eligible for the month of application, but ineligible in the subsequent month.  The household is entitled to benefits for the month of application in a timely manner even if application processing results in benefits not being issued in the subsequent month.  Similarly, a household may be ineligible for the month of application, but eligible in the subsequent month due to anticipated changes in circumstances.  Even

    1130-2


    though denied for the month of application, the household does not have to reapply in the subsequent month.  Use the same application when denying benefits for the month of application and making an eligibility determination for subsequent months.
     

    1130.020.00    RECERTIFICATIONS

    Approve the recertification prior to the end of the household's current certification period when the household meets all eligibility requirements and completes the necessary processing steps.  This allows the household an opportunity to participate by its normal issuance cycle the first month of the new certification period.

    NOTE:  Process recertifications meeting expedited service criteria according to expedited service procedures.
     

    1130.020.05     Timely Recertifications
    IM-#52  March 23, 2000

    To be considered a timely application for recertification, the following conditions must be met.

     1. Households certified for one month or certified for two months in the second month of certification have 15 calendar days from the date of the Notice of Expiration prepared by the county.  (See Time Frames for Sending/Dating Expiration Notice)
           -OR-

     2. Households certified for two months in the first month of certification, or certified for three months or longer, must submit identifiable applications by the 15th day of the last month of the certification period.  These households receive a Notice of Expiration generated from State Office when the case is certified prior to the last month of certification on or before the third to last working day of the month.  (If this criteria is not met, see Time Frames for Sending/Dating Expiration Notice.)

      NOTE:  For households consisting of SSI applicants/ recipients applying for FS recertification at SSA, consider the application date timely if the appropriate filing deadline is met.  Consider an application filed when SSA receives a signed application.


    1130-3


    1130.020.10     Non-timely Recertifications
    IM-#1   January 15, 1999

    Process any application for recertification NOT submitted in a timely manner as an application for initial certification.  If the application is received within 30 calendar days after the certification period ends, do not verify income if the source has not changed and the amount has not changed by more than $25, unless the information is incomplete, inaccurate, inconsistent, or outdated.
     

    1130.020.15     Processing Recertifications
    IM-#52  March 23, 2000

    1. Necessary processing steps also include the timely provision of necessary verification.

     a. Allow the household ten days from the date of the request for information to supply the necessary verification.  Document the date the information is due.

     b. If verification is not provided by the ten-day deadline, the household loses its rights to uninterrupted benefits.

     c. If the household provides the verification requested, but the time to provide the verification expires too late to allow the household to participate timely, allow the household the opportunity to participate within five days after providing verification.

      EXAMPLE:  Ms. C's household was certified for FS through October.  She reapplied and was interviewed on 10/12.  On 10/22 she reported a new job.  The same day, the caseworker sent a letter giving ten days to provide verification of new income.  The participant provided the information 11/01.  The caseworker completes the reapplication and either issues Ms. C benefits or notifies her of rejection no later than 11/06.

    2. Complete recertifications for categorically eligible households timely even if the Temporary Assistance redetermination has not been made.
     a. Assume categorical eligibility for these households.  Do not evaluate those eligibility factors not investigated for categorically eligible households.

     b. If the household is later terminated from Temporary Assistance, investigate those factors not previously considered.

     c. If FS eligibility or the benefit level is affected by the


    1130-4


    Temporary Assistance termination, follow adverse action procedures. 
    1130.020.20     Recertification Denials
    IM-#52  March 23, 2000

    DFS may deny recertification applications the first working day after the end of the household's current certification period if the household fails to appear for a scheduled interview or fails to provide needed verification (as long as the deadline for providing missing verification has elapsed).

    Complete denials, including those for failure to complete the interview or provide missing verification timely, either the first working day after the end of the current certification or within 30 days after the date the application was filed as long as the household had adequate time for providing the missing verification.
     

    1130.020.25     Uninterrupted Benefits
    IM-#52  March 23, 2000

    1. A household is entitled to uninterrupted benefits if it timely files an application for recertification, is timely interviewed, and timely provides needed verification.

     Do not interrupt benefits for households making a timely reapplication and determined eligible.  Take action on timely reapplications within the following time standards.

     a. Notify households provided a notice of expiration at the time of certification, and that timely reapplied and completed the necessary processing steps, of eligibility or ineligibility within 30 days of the date the household received its last issuance.  Provide the household an opportunity to participate within 30 days of the date of its last issuance also.

     b. Notify households filing a reapplication by the 15th day of the last month of the current certification period of  approval no later than the end of the certification period.  Notify households of rejection the first working day after the end of the current certification period.

      Provide households determined eligible the opportunity to participate by the normal issuance cycle in the month following recertification on a timely reapplication.

      NOTE:  Households that make timely reapplications, but due to DFS error, are not recertified in time to ensure issuance in the normal issuance cycle in the following month, receive


    1130-5


    an immediate opportunity to participate within five working days upon eligibility determination.

    2. DFS failure to provide eligible households that filed timely reapplications with an opportunity to participate in accordance with the above provisions is considered an administrative error.  These households are eligible for restoration of lost benefits,

    1130-5a


    if as a result of such error, are unable to participate in the month following the expiration of the certification period.
     

    1130.020.30     Loss of Uninterrupted Benefits
    IM-#52  March 23, 2000

    The household loses its right to uninterrupted benefits for:

     1. failure to attend any interview scheduled on or after the deadline for timely filing of the application for recertification, or

     2. failure to submit all necessary verification within the established time frame.

    Although a household loses its right to uninterrupted benefits for such failures, do not deny the household at the time of the failure, unless the household refused to cooperate or the certification period has lapsed.

    If the household loses its right to uninterrupted benefits, but is otherwise eligible after correcting such failures, provide benefits within 30 days after the date the application was filed.

    EXAMPLE:  The household applied for recertification on 7/14.  The current certification period expires in July.  An interview was scheduled on 7/23.  The household came to the scheduled interview and additional verification was requested.  The household has ten days to provide the requested verification, or until 8/2.  The household cannot be denied prior to the end of its current certification period, as the deadline for providing verification extends past the current certification period.  The household is entitled to uninterrupted benefits issued to arrive when the household normally receives its benefits.
     

    1130.025.00    Delays in Processing

    If DFS does not determine a household's eligibility and provide an opportunity to participate within 30 days of the day the application is filed, take the following action.
     

    1130.025.05     Determine Cause of Delay

    First determine the cause of the delay using the following criteria.

     1. A delay is the fault of the household if the household failed to complete the application process even though the caseworker assisted the household.  Take the following action before a delay is considered the household's fault.
    1130-6