SUBJECT:
FOOD STAMP POLICY PROHIBITION IN INCREASING FOOD STAMP BENEFITS AND TEMPORARY ASSISTANCE (TA) SANCTION FOR NON-COMPLIANCE WITH DIVISION OF WORKFORCE DEVELOPMENT (DWD)
FOOD STAMP MANUAL REVISION #:13
1105.025.30.25
1115.080.00
1115.082.00 (removed)
DISCUSSION:
Effective with the implementation of Temporary Assistance (TA) into FAMIS, when a TA participant fails to comply with the Division of Workforce Development, FAMIS sanctions the individual on the TA case. FAMIS also lifts the TA sanction when the individual complies with work activities. This memorandum discusses food stamp policy and procedures when a TA sanction for noncompliance with DWD is entered or ended, including a change in policy regarding when to enter the income source code RP (reduction - refusal to comply with program requirements).
Food Stamp Policy Change
Effective immediately, when a TA case is sanctioned for refusing to comply with a TA program requirement, the income source code RP (reduction - refusal to comply with program requirements) is only entered if:
- the individual is not sanctioned on the food stamp case; or
- the individual is sanctioned, but the sanction increases the food stamp benefits.
The income source code RP is used to prevent an increase in food stamp benefits when an EU fails to comply with required actions of means-tested programs (refer to policy at 1115.080.00).
Food Stamp Action Required When a Temporary Assistance Sanction Is Imposed for Non-compliance with DWD
Memorandum IM-#23, dated March 18, 2005, discusses the Temporary Assistance sanction process. When a TA sanction is entered in FAMIS due to non-compliance with DWD, the TA grant is reduced and an eligibility determination is completed for all programs in FAMIS. The decrease in the TA grant may cause the food stamp case to be increased or may cause a no change action. Overnight, the reminder “code received from DWD, determine if FS sanction required” is created. Within 10 days of receipt of the reminder, take the actions listed below.
- Determine whether or not a sanction should also be imposed for the Food Stamp Program. If the individual is exempt or excluded from food stamp work registration, other than exempt for Temporary Assistance case management (code 16), a food stamp sanction is not imposed. If the individual does not meet another exemption or exclusion, a food stamp sanction is imposed.
- If the individual is exempt or excluded for a reason other than TA (code 16), update the employment assessment code on the Employment Assessment (FMMS) screen with the exempt or excluded code. Complete an eligibility determination. No other action is required by the worker.
- If a food stamp sanction should also be imposed, type SANDISQ or FMAM on the command line and press enter. The Sanction/ Disqualification (FMAM) screen displays.
- On the Sanction/Disqualification (FMAM) screen, enter sanction type NFF (non-compliance with case management). Refer to the Entering a Sanction or Disqualification user guide for further instructions.
- Complete an eligibility determination (EDRES). If food stamp benefits remain the same or are decreased, authorize the action. Effective immediately, the higher TA grant is not budgeted (the RP income source code is not entered) if the sanction on the food stamp case causes the food stamp benefits to be decreased or remain the same.
- If the food stamp benefits are increased as a result of the food stamp sanction, or the individual is excluded or exempt, it is necessary to count the full TA grant rather than the reduced grant. Refer to Food Stamp Manual Section 1115.080.00. The sanction amount is to be based on the TA grant amount for which the household is currently eligible. FAMIS displays the reduced grant amount (after the 25% sanction) on the TA Budget Summary (FM4D) screen. Determine the 25% sanction amount and enter it as income source RP.
- Refer to Appendix L
of the Temporary Assistance/Case Management Manual to determine the 25% sanction amount. - In Appendix L , locate the reduced grant amount from TA Budget Summary (FM4D) screen in the third column (New Grant).
- Look at the first column (Old Grant).
- Subtract the amount in the third column (New Grant) from the amount in the first column (Old Grant).
- Enter this amount as the RP income source code, by typing SELINC or FMX2 on the command line and press enter. The Select Income (FMX2) screen displays. Prompt for the payee of the TA case. Press F14=ADDINC.
- The Income (FMX0) screen displays. Add type UI (unearned income) and source code RP and complete other required fields. Press F6=DETAILS to enter the budget.
- The Income Amount (FMX3) screen displays.
- Enter the amount by which the TA grant is being reduced and the first month in which the grant reduction is effective as the reduction (RP) amount (see steps above).
- Complete the eligibility determination after entering both the income and the sanction.
- Refer to Appendix L
NOTE: Some of the amounts in the third column of Appendix L
EXAMPLE: Ms. A. receives TA and food stamps for herself and her two-year old daughter. She was referred to DWD for case management. Ms. A. did not enroll with DWD and they are now recommending a sanction be imposed on her TA case. Based on the notification received from DWD in the nightly batch, FAMIS sanctioned the case and reduced the TA grant to $175. The caseworker receives the reminder, “code received from DWD, determine if FS sanction required”. Ms. A. is exempt from work registration due to the age of her daughter, so she is not sanctioned. Her work registration/employment assessment code is changed to 01. The caseworker refers to Appendix L
EXAMPLE: Ms. B receives TA and food stamps for herself and her 14 year old daughter. She was referred to DWD for case management, but she did not comply. DWD is recommending a sanction be imposed on her TA case. Based on the notification received from DWD in the nightly batch, FAMIS sanctioned the case and reduced the TA grant to $175. The caseworker receives the reminder, “code received from DWD, determine if FS sanction required”. Ms. A. is not exempt or excluded from work registration for another reason, so the caseworker enters a food stamp sanction and the benefits are decreased. The RP income source code is not entered because the benefits were decreased due to the sanction.
Food Stamp Action Required When FAMIS Lifts Temporary Assistance Sanction
When a TA sanction type NWR (non-cooperation with work req) is ended by FAMIS an eligibility determination is run on the food stamp case. The increase in the TA grant may cause the food stamp benefits to decrease. If the benefits decrease, an Adverse Action Notice (FA-510) is sent to the food stamp EU regarding the change in benefits. Overnight, a reminder “TA Sanction ended. Check FS sanction” is sent to the worker. Within 10 days of receipt of the reminder, take the actions listed below.
- Review the Sanction/Disqualification (FMAM) screen to determine if there is an existing food stamp sanction due to TA non-compliance. If there is an NFF sanction, end the food stamp sanction using the date of compliance received from DWD as the date of compliance for food stamps. Refer to Ending a Sanction/Disqualification user guide for instructions.
- Review the income for the EU and if income source code RP appears, end the income on the Income (FMX0) screen using the month the sanction ends as the end month.
- Complete an eligibility determination (EDRES) to change the role of the sanctioned individual to IN and reinstate food stamp benefits for the sanctioned EU member.
- If an Adverse Action Notice (FA-510) was generated and sent to the EU due to the increase in TA grant and the adverse action period is not yet expired, a conflict of actions is created. Resolve the conflict of actions rather than allowing FAMIS to resolve the actions, in order to ensure the EU receives the correct allotment. Access the Action Resolution screen (FM50 or ACTRES) to resolve the actions. The worker must void the pending adverse action. Refer to the user guide Changing an Adverse Action Status for instructions. After voiding the adverse action, the worker must access the Eligibility Determination Resolution screen (FM3Y or EDRES) to run a new eligibility determination.
Fails to Comply With Work Activity While Being Case Managed By FSD
When an individual is being case managed by FSD and fails to comply with the work activities, the worker enters the NWR sanction for the Temporary Assistance case. Complete the following steps:
FAMIS generates an Adverse Action Notice (FA-510) to the individual.
Food Stamp Policy is the same whether the failure to comply with TA work activities is with DWD or FSD. The reminders are not sent to the worker, since the worker is entering or ending the TA sanction. Follow the policy and procedures in the Food Stamp Action Required When a Temporary Assistance Sanction Is Imposed for Non-compliance with DWD section above, except that the worker takes the actions the same day the TA NWR sanction is entered. Follow policy and procedures in the Food Stamp Action Required When FAMIS lifts Temporary Assistance Sanction section above when the sanction is ended, except that the worker takes the actions the same day the TA NWR sanction is ended. A conflict of actions will not be created when the sanction is ended by the FSD worker on the TA case and the food stamp actions are completed on the same day.
Intranet Update
The Food Stamp Manual section 1115.080.00 PROHIBITION IN INCREASING FOOD STAMP BENEFITS is renamed and revised to include this policy change, formatting changes, and to remove SSI from this section. The Food Stamp Manual section 1105.025.30.25 is revised to include this policy change. Two procedure guides Prohibition in Increasing Food Stamp Benefits and Ending Food Stamp Noncompliance with a Program Requirement are added to the Intranet to assist staff with the correct procedures.
The Food Stamp Manual section 1115.082.00 HOUSEHOLD MEMBER COMMITTED FRAUD IN A MEANS-TESTED ASSISTANCE PROGRAM is removed, as the policy does not apply in Missouri.
Two flow charts, Food Stamp Sanctioning Process for TA Sanctioned Individuals - DWD Case Management and Food Stamp Sanctioning Process for TA Sanctioned Individual - FSD Case Management, were developed to show the food stamp process when a TA case is sanctioned for noncompliance with case management. To access the flow charts:
- on the Food Stamp Intranet Site, click Food Stamps;
- click Tools/Guides; and
- click FS Sanction Process FSD/TA Noncompliance or FS Sanction Process DWD/TA Noncompliance.
NECESSARY ACTION:
- Review this memorandum with appropriate staff.