Food Stamp Program regulations finalized in November offered states this change reporting option.  This change reporting option for earned income households is intended to support households who are working to become self-sufficient by making the program more accessible and eliminating the need for frequent office visits as required by shorter certification periods. 

Households Subject to the New Change Reporting Requirement

Households considered earned-income households and who are subject to this change reporting requirement when certified for six months include:

households with earned income except:

• migrant/seasonal farm worker households and

 
• households whose only earned income is excluded, such as that of a minor or a student,

 
• households with a combination of earned and unearned income, 

• earned income households who change to unearned income during the current certification period,

• combination earned/unearned income households who change to unearned income only during the certification period, and

• unearned income households who begin receiving earned income during the certification period.

All households not identified as earned income households and earned income households not certified for six months have the following change reporting requirements:

• changes in gross monthly income of more than $25, except changes in IM grant,

• changes in any source of income, 

• all changes in household composition, 

• changes in residence and the resulting change in shelter costs,

• the acquisition of a licensed vehicle, 

• when resources reach or exceed a total of $2000 or $3000, if elderly, or

• changes in the legal obligation to pay child support.

At initial application or recertification, determine if the household is an earned income household or other type of household. 

During the application interview, explain the change-reporting requirement that appears to be applicable to the household.

• Give the IM-3 to households who are not subject to the earned income household reporting requirements and earned income households making application for food stamps in combination with another program.  When giving the IM-3 to an earned income household making an in-combination application, mark through:

 
• the words "FOR FOOD STAMPS, REPORT A NEW SOURCE OF INCOME WITHIN 10 DAYS OF THE DATE YOU START WORKING" in  paragraph one,

 
• the words "AND/OR FOOD STAMP PROGRAMS" in the heading "CHANGES THAT MUST BE REPORTED.", and

 
• Food Stamp assets to be reported.

• Give the IM-4 to all households.  It provides households with an explanation of how food stamp benefits are used.

• Discuss with earned income households what is considered income and that they must report when the total income before deductions for the household exceeds 130% of poverty.  For example, explain to the household that Temporary  Assistance, child support, and any other source of unearned income is considered along with earnings when comparing their income to the 130% of poverty standard.  If the household begins receiving or receives an increase in any type of unearned income, they should add it to their gross earnings when determining whether or not the change should be reported.

• A categorically eligible earned income household whose income exceeds 130% of poverty when approved, does not have a change reporting requirement when suspended.  If the household's income goes below 130%, advise the household of their income reporting requirement.

If the change reported while the application is pending changes the household's change-reporting requirement from earned-income reporting to the reporting requirement for all other households, send the household an IM-3. 

Certification Procedures

Certify earned income households for six months unless they are only eligible for the month of application and/or the following month.  Upon approval, notify earned income households of the need to report when their gross income exceeds 130% of poverty. 

Households with zero net income other than those meeting the earned income household definition continue to be certified for three months.

Assign households not subject to three month or six month certification procedures a certification period of 1 to 24 months depending on the household's circumstances.  This policy is not changed.

Necessary Action on Changes

Earned income households with a six-month certification are only required to report when the household's gross monthly income exceeds 130% of poverty. A household may report changes which are not required to be reported or information may be received from other sources.  Process the different types of changes as follows:

• Household's Gross Monthly Income Exceeds 130% of Poverty


Process any change reported that causes an earned income household's gross monthly income to exceed 130% of poverty.  Follow appropriate notification procedures (IM-80 or IM-149) when closing the case.
 

• Changes in Income Maintenance (IM) Grants


All changes that impact determination of the IM cash assistance grant (Temporary Assistance, SAB, etc.) must be acted on including changes to the grant amount for the in-combination food stamp household.  This does not apply to any of the other IM programs.  If a change occurs for a food stamp household member who is not included in the IM cash assistance, determine whether or not it is appropriate to act on the change.

• Changes Not Required to be Reported 


Take action on any reported or known change that increases the household's food stamp benefits.  An example of such a change could be a household member losing income. 

Do not take action on changes that decrease benefits to the household except for those that fall into the category of verified upon receipt.  Information is considered verified upon receipt if:
 

• it is not questionable and 

• the change is reported by or we receive it directly from the source of the information. 
Information considered verified upon receipt includes: 
 
• SDX, from the Social Security Administration,

 
• Bendex, from the Social Security Administration,

 
• SAVE, from the Immigration and Naturalization Service,

 
• IMES--Unemployment Compensation benefits from the Division of Employment Security 

 
• a household member being disqualified,

 
• a household member subject to the work requirement who uses all non-work months prior to the end of the certification period,

 
• changes reported by the household in household composition and deductible expenses such as shelter costs and childcare (changes that require further verification are not considered verified upon receipt),

 
• actions taken by other programs that affect food stamp deductible expenses such as a decrease in the Child Care co-payment which would result in a decreased child care expense.

Examples of reported changes that are not being directly reported by the source of the information and would not be acted on if they resulted in a decrease to the household's benefits are:

• New Hire matches,

 
• household report of new or increased income, 

 
• wage history shown on IMES,

 
• report of a change in household composition by someone outside the food stamp household.
Information that is reported or learned from another source must always be evaluated to determine whether the household's total gross income exceeds 130% of poverty.  The impact on the household's benefits must also be determined.  Verification policy is not changed.  However, if enough information is reported so that it is obvious the household  remains eligible and benefits will not increase, no additional verification is needed. Utilize information received to determine benefit amount at the next recertification.
 
• Household Member Moves In or Out 


Always take appropriate action to remove an individual from one food stamp household before adding him/her to a new food stamp household to prevent duplicate participation.  No matter how or by whom the change is reported an individual may not participate in more than one food stamp household at any given time.

If a household member reports another household member moves in or out, act on the change. This is a change that is considered verified upon receipt. 

If a non-household member reports a household member has moved in or out and is not requesting the individual be added to another food stamp household, do not act on the change.  For example a non-custodial parent reports a child has left the custodial parent's household and is now residing in the non-custodial parent's home.  The non-custodial parent is not a food stamp recipient and is not applying for food stamps.  Do not take action to remove the child from the custodial parent's assistance group
 

• Voluntary Closing


When an earned income household voluntarily requests their case be closed, close the case.
 

• Changes Reported on FS-1


When an earned income household reports an anticipated change at the time of application, take action on those changes. 

 Changes in Type of Household During Certification

When an earned income household or a combination earned and unearned income household reports a change in income during their certification period that changes their income status to an  unearned income household, they remain subject to the earned income reporting requirements until their next certification.

When an unearned income household reports a change in income changing their status to an earned or a combination earned and unearned income household during their certification:

• The new change reporting requirements for the household becomes effective the month following the month in which the action is completed:

• if six months remain in the current certification period beginning with the month the change adding the earned income is effective,

 
• if the current certification period can be extended to equal six months beginning with the month the change adding the earned income is effective, not to exceed twelve months (If the certification period can be extended, it will be done automatically.) or,

 
• when a certification that exceeds six months is shortened beginning with the month the change adding the earned income is effective so that the remainder of the certification does not exceed six months.  (This will be done automatically.)

• Notify the household of their new change reporting requirement on the benefit adjustment notice. 

• If the current certification cannot be extended an additional six months, reporting requirements do not change.  Reporting requirements for earned income households not certified six months apply.  Determine the correct reporting requirement at the next certification or recertification. 

The Notice of Eligibility, Denial or Pending Status (IM-112) is being revised to notify earned income households of the new  change-reporting requirement at certification and recertification.  Until the revised IM-112 is available, when approving an earned income household subject to the new change-reporting requirement, enter the following statement in Section A of the IM-112, "Your household must report when your total income prior to deductions becomes more than $ _____."  Enter the 130% income maximum for the household being certified.  Mark through  the change reporting section below the net food stamp income section.  Do not enter the above statement when approving all other households and do not mark out the change reporting section. 

The Benefit Adjustment Notice (IM-149) is also being revised.  Until the revised form is available, insert the following  statement on the form when the household reports a change and they become subject to the new earned income reporting requirements: "Your household must report when your total income prior to deductions becomes more than $ _____."  Enter the 130% income maximum for the household in the blank.  Mark through the change reporting section below the net food stamp income.  Do not enter the above statement and do not mark through the change reporting section when sending the form to all other households.

An "Earned Income Households Change Reporting Requirements" table is attached.  It provides the 130% of poverty standard for each size household.  Use this table to determine the 130% of poverty standard to insert on the IM-112 and the IM-149.  The chart is being printed on cardstock and will be sent to the county offices as soon as it is available. 

FSU5/FCAS

FSU5 has been changed to allow a six-month certification period for earned income households.  If an earned income household is only eligible for the month of application or the following month, the system will allow one or two months as the appropriate certification period.  FSU5 will also automatically update the last ATP date for those households whose certification period is extended or shortened due to adding earned income to an unearned income household. 

An indicator is being added to FCAS to indicate households subject to the earned income reporting requirements.  This field is being added so workers can check FCAS to determine the income reporting requirements for households prior to acting on reported changes.  It is designed to assist workers when a household no longer has earned income but, remains subject to the earned income reporting requirement.  Until the field is available in FCAS, workers must flag those cases.  FCAS will also show the new last ATP date for households whose certification period is extended or shortened when earned income is added to an unearned income case. 

Manual Revision

The manual is being revised to reflect the policy changes due to the new change reporting requirement and new certification procedures.  You will be advised when the update is complete.

• Review this memorandum with appropriate staff.

• As of May 1, 2001, begin certifying households with earned income for six months.  These households are only required to report changes in gross income in excess of 130% of poverty.