We have received a number of questions regarding the new change reporting requirement for earned income food stamp households certified for six months.  The purpose of this memorandum is to share those questions and answers to help clarify the new change reporting requirement policy.
Issue: If the Temporary Assistance grant changes, do we adjust the food stamps?
Response: Yes, adjust the food stamp benefit to include changes in the Temporary Assistance grant and the corresponding changes that caused the change  in the Temporary Assistance grant.
Issue: Do we take action to remove children from the food stamp household if they are placed in alternative care?
Response: If payment for the alternative care placement is made by Title IV-E funds, act on changes to the food stamp household that also impact the Title IV-E payment.  This would include removing the child/ren from the Food Stamp household when the Title IV-E case is approved.
Issue: Do we take action to close the food stamp case if the client dies or goes to jail?
Response: If all household members have died, close the case.  If law enforcement reports the incarceration of an individual, take necessary action to remove the individual from the household.  If a Death Match is received, take action to remove the individual from the household.  These reports are considered verified upon receipt.  Information received through an Incarceration Report is questionable and cannot be considered verified upon receipt.  Evaluate the information at the next recertification.
Issue: Do we take action if the household sends in an IM-145 change report form reporting that someone moved out of the household, but we do not know if they went to another food stamp household?
Response: If removing the person from the household results in a reduction in benefits to the household, do not remove them until the next application or the individual makes application in another household.  If removing the individual increases benefits to the household, take action on the change.
Issue: If a child in a food stamp household reports that s/he has moved out of the household and into the household of the other parent, and that parent is not receiving food stamps; do we remove the child from the first parent's food stamp household?
Response: If removing the child from the household will increase benefits to the household, take action.  If not, do not remove the child from the household unless another household makes application for the child.
Issue: On combination cases (MC+/FS), are we supposed to verify income changes and act on the IM case and not the food stamp case?  Are the clients still required to report within 10 days as it says on the IM-UA?
Response: On combination MC+/FS cases, take whatever action is required for MC+.  Evaluate the effect on the food stamp case.  If the change increases benefits to the household, complete the budget adjustment.  If the change decreases the benefits, but the household's total gross income remains under 130% of poverty, take no action.  We have not changed reporting requirements for any of the IM programs.  It is very important that we explain the different program requirements at the interview so as to help the client avoid being confused.
Issue: Page 4 of memorandum IM-#76 says we are not to act on New  Hire Matches if they result in decreases in benefits.  It then goes on to say we still have to evaluate if the income has gone above 130% and that verification policy has not changed.  Does this mean we must still ask the client to provide verification of the income, and if they do not, are we to initiate action to close the case?
Response: The statement about evaluating income changes to determine if the income exceeds 130% is applicable to all income changes.  New Hire Matches do not contain enough information to determine the impact on the household's food stamp eligibility.  File the match in the case record and evaluate the information at the next certification or re-certification.
Issue: At reapplication it is discovered that the client had a change in the past six months that went above 130%, do we do a claim?
Response: We are obtaining clarification about how to complete claims for households subject to the earned income change reporting requirement.  Situations in which the household has failed to report when their income exceeds 130% do require a claim to be completed.  The actual process for determining the amount of overpayment may be changed.  Flag a case of this type and complete the claim when policy clarification is received.
Issue: What if the unreported change was a job quit?  How do we handle disqualification and applying the months of ineligibility?
Response:  If an earned income household reports a job quit during the certification, determine whether or not the individual had good cause or meets another work registration exemption.  If not, apply the appropriate sanction.  When a job quit is discovered at reapplication, and the individual does not have good cause or meet a work registration exemption, apply the penalty period beginning the day after the certification period ends.  (FS manual 1105.025.55.20 and 1105.025.055.25)
Issue: Are we supposed to attempt to teach clients to multiply gross income by 4.333 and 2.166?
Response: The client does not need to convert income for reporting purposes.  Actual income received in a month is sufficient as a benchmark for reporting purposes.  Explain during the interview that they need to add the pay checks received in the month to any other income the household has.  If the total is more than the amount you give them on the approval letter (130% of poverty maximum), they need to report the change to you.
Issue: If a food stamp household member moves out and a non-member reports the change, we are not to remove that person unless they have moved into another food stamp household.  But, can we then contact the household about this and then take action after discussing this with the client?  Will the client not think it is strange that this person has been removed from MC+ and can still get food stamps?
Response: If the household does not report a household member has moved out and that individual is not applying for food stamps in another household, do not contact the household regarding the change for the Food Stamp Program.  This is not a change that the household is required to report for food stamps.  Note the information in the case record and evaluate the information at the next application or re-application.
Issue: A head of household's 20-year-old daughter moves into the household.  The daughter has income of her own.  The effect of adding the daughter and her income is to decrease the household's benefits.  What action should be taken?
Response: Even though the daughter is a mandatory household member, the worker should not act on the change, since the change is not verified upon receipt and causes a decrease in allotment.
Issue: What if the daughter was receiving food stamps on her own at the time she moved into her parents' household?  Would she continue to receive food stamp benefits?  She is also an earned income change reporting household.  She was not required to report this move.
Response: If the daughter is a mandatory household member or she purchases and prepares meals with her parents, this is a situation where an individual is in more than one food stamp household.  We cannot allow duplicate participation.  The daughter's case must be closed.  Evaluate the effect of adding the daughter to her parents' case.  If adding her would result in a decrease in benefits, do not add her to the case.  Record the action taken in the case record and evaluate the information at the next application or reapplication.
Issue: What if the daughter's only income was SSI?  Now she's in the "other" group.  Now she's required to report change in residence and household composition.  NOW what do we do?  If we add her to her parent's case, their benefits will decrease.  If we don't act on her case, it would seem that hers would be in error, because we're required to act on the change.
Response: If the daughter's only income is SSI, she is required to report when she moves.  Again, we would close her case and add her to her parent's case.  When adding her to her parent's case, we would look at whether or not the benefits to the household increase or decrease.  If the benefits decrease, take no further action.  The case record should show that she was added to the case, but there is no system entry because the benefits would decrease.
Issue: One of the counties has a case that has earned income and a child with SSI so you mark the budget "y" for disabled individual.  They don't have to meet the gross maximum income test and their gross income is $1629.06.  What do we put on the letter as the level for that size household is $1533?  The household is not suspended, they receive stamps.
Response: Elderly/disabled households are treated the same as categorically eligible households.  When the household's gross monthly income exceeds 130% of poverty, they have no reporting requirement.  If the household's gross monthly income does not exceed 130% of poverty, they should be told to report when it does exceed 130% of poverty.
Issue: Memorandum IM-#76, page 7 under the heading "Changes in Type of Household During Certification," discusses shortening the certification period and states it will be done automatically.  Does this mean state office will shorten the certification, or the worker does without an IM-80?
Response: The system shortens the certification period after the worker sends an IM-80, if necessary, and takes action to add the earned income.
Issue: Is it correct that the worker notifies the claimant of their new reporting requirement at certification?
Response: Yes, the worker should include this information on the Action Taken on Your Food Stamp Case (IM-112) notice.
Issue: If you go to FPAR and do a case print, will the Earned Income Household indicator appear on the printout?
Response: No, it only shows on FCAS.
Issue: Will the system allow a six month certification period for a household with self-employment income and overhead expenses causing the net income to be zero?  No earned income will be shown on the FSU5 and there will be zero net income?
Response: In situations where the household is self-employed and the overhead expenses cause the household's net income to be zero, workers should enter a code 4 (self-employment) in field 31 and 0000  00 in field 32 of the individual update screen of FSU5.  The system looks for earned income codes in that field and will allow the case to be certified for one, two, or six months.
Issue: Is an IM-12, client reporting change in employment and sending pay stubs, an employer calling to tell us the client's employment situation, etc. considered verified upon receipt?
Response: If an IM-12 is received from the employer, someone had to send it to them to complete.  The IM-12 is verification of income not a report of income.  How this information was reported is what determines if it is considered "verified upon receipt".  The same goes for the client reporting and sending pay stubs.  The client is not the source.  Therefore, it is not considered "verified upon receipt".  When an employer reports directly to DFS that an earned income household received an increase in pay and provides verification of the new rate of pay, it is verified upon receipt.  If additional information is required to determine the impact on the case, it is not verified upon receipt.
Issue: If a client reports that he lost his previous job three weeks ago and just started another, do you look at the new job or do you take him to zero income on the first change, and not look at the second/current situation.  Many times a client does report multiple changes at once.
Response: 1) We would look at the month of report and if the client is due supplemental benefits based on actual income (due to some zero pay periods), we would issue benefits in accordance with the significant change policy.

2) We would then look at the new income and determine if the projected amount puts the household over 130%:

a) If yes, take appropriate action to close the case.
b) If no, unless the income is considered verified on receipt or increases the allotment, take no action.  The amount previously budgeted before the client lost the first job remains in the system. Review the client's circumstances at the next certification.
Issue: In the TAKE 45, scenario 6 - Activity 2 regarding New Hire Matches.  Is this teaching point to indicate we do not take action at all on New Hire matches during the certification period EVEN if the employment could potentially put the family over 130% total family income.  If the income is over 130% and not followed up on will Quality Control recognize this as policy and not count it as an error?
Response: No action is taken on New Hire matches for households with earned income reporting requirements.  The New Hire matches do not contain enough information to determine the impact of the new change.  No error will be cited by Quality Control solely because action is not taken.  Quality Control will look to see if the sample  month income exceeded the 130% poverty standard.  If it does, they will check further to determine if the increase should be in the error determination.  If the income results in an error, this is a  client error because of failure to report.
Issue: It was my understanding that those cases approved prior to May 1,  would remain in the regular reporting requirements until the next certification even if they reported a change that would put them in the earned income reporting requirement during the certification period.  Staff is telling me that the system is changing the indicator and certifying for six months once the change in budget shows earnings.  Is this correct?
Response: Cases approved prior to May 1, are not to be under the new reporting requirements unless they report a change that makes them an earned income household.  The household becomes subject to the earned income reporting requirements if the certification can be extended or shortened to six months.  Refer to memorandum IM-#90.
Issue: In a single person food stamp household with earned income, a relative reports the person dies.  Do we take action to close?
Response: Close the case when the only household member or the entire household dies.
Issue: In a food stamp household with mom, dad, and children, if mom or dad dies and the change is either not reported or reported by a non-household member, do we take action to remove?
Response: If it is reported by a non-household member that a household member died and there are remaining household members, determine whether or not a death match has been received.  If so, take action to remove the individual or close the case, using adverse action procedures.  Information received on a death match is verified upon receipt.  Counties should be receiving death matches on deceased individuals and should be taking action to  stop benefits to those individuals.  If there is no death match and the household does not report the death of the household member, note the information in the case record and follow up on it at the next application or  reapplication.
Issue: When the system shortens a certification period because the case is changing from an "other" household to a "earned income reporting" household, the system is not notifying the household that their certification period has been shortened.  Should the worker send the worker-generated Notice of Expiration (NOE)?  Is there any problem with the fact that the original approval letter notified them of a longer certification period?
Response: When the system shortens a certification period because the case is changing to an earned income reporting household, the worker has initiated this action by completing an adjustment and entering information into FSU5.  The client must be notified of action taken on the case.  The worker should notify the household on the Notice of Adverse Action (IM-80) being sent to reduce benefits (if that is the case) and/or the Benefit Adjustment Notice (IM-149).  Do not send an NOE.  NOEs are sent to households in the month prior to the last month of certification which is not when certifications are being shortened for this policy.
Issue: An able-bodied adult without dependents (ABAWD) is living in the home with his spouse, who is employed.  In his third non-work month, he reports that he has gone to work.  The worker does not act on the change, because to do so would decrease benefits.  What does the worker do with the FTWR?  Will the system allow us to remove the subsequent non-work months without showing any earned income for the individual?  Is that the correct action to take?
Response: The worker needs to evaluate the non-work months shown in FTWR and remove those months in which the ABAWD is meeting the work requirement.  The worker would need to change the individual's work requirement code in field 50 and work registration code in FSU5.
Issue: A client is receiving Child Care and food stamps.  An increase in income is reported for child care, which causes an increase in the sliding fee.  Would this be treated the same as a change in an Income Maintenance grant (whatever happens to the grant, happens to the food stamps)?  If not, what do we do with the increased sliding fee?
Response: Actions taken by other programs within the agency that change the  amount of expense budgeted for food stamps are considered verified upon receipt.  Because the action adding income to the child care case results in a change in the sliding fee budgeted for food stamps, the same action would be taken on the food stamp case.  If however, the action on the child care case resulted in no change in the expense budgeted for food stamps, no action would be taken.
Issue: If we have a child care provider who receives food stamps, are the child care payments we send to her "verified upon receipt?"
Response:  Child care payments made to a provider who is also a food stamp participant would be verified upon receipt as the agency is the source of income.
  • Review this memorandum with all appropriate staff.
Distribution #6

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