MEMORANDUM

DISCUSSION:

The purpose of this memorandum is to inform staff of changes to the sanction policy surrounding Temporary Assistance (TA) work requirements due to the Strengthening Missouri Families Act (Senate Bill 24, 2015).

Beginning August 28, 2015 the sanction applied to the TA benefit for non-compliance with work requirements increases from a twenty-five percent reduction (25% or NWR sanction code) to a fifty percent (50% or WR5 sanction code) reduction. If the TA participant does not comply after the 50% sanction has been in effect for ten weeks, a full family sanction (100% or WRF sanction code) will be imposed and the TA case will close.  

Initial Non-Compliance with Work Activities

When a Missouri Work Assistance (MWA) case manager determines a participant is not meeting the TA work requirements, the case manager will schedule a face-to-face meeting with the participant to explain participation requirements and the sanction policy should non-compliance occur. The participant has six (6) weeks to comply with work requirements for one week following the date of this meeting, regardless of whether they attend the meeting.

If the participant does not comply during this six (6) week period, an alert is sent to impose the WR5 sanction, which automatically reduces the TA benefit fifty percent (50%). FAMIS completes this action without FSD staff intervention.

The household will receive the reduced grant for up to ten (10) weeks if they remain eligible for TA on all other factors during that time. When the TA benefit has been reduced by 50%, the participant is required to complete four (4) consecutive weeks of participation in work activities for a minimum average of thirty (30) hours per week before the sanction can be ended.

The ten week period provides the individual additional time to comply with work requirements. When the participant has completed four consecutive weeks of work activities for an average of thirty hours per week, the case manager will send an alert to end the sanction. FAMIS completes this action without FSD staff intervention.

Failure to complete four consecutive weeks of participation for the minimum average of thirty hours per week by the end of the ten (10) week period will result in a full-family sanction and the TA case closing. FAMIS completes this action without FSD staff intervention.

Participants Already Sanctioned for Non-Compliance with Work Activities

Participants who already have a sanction imposed due to non-compliance with work requirements will continue to have their TA benefit reduced by 25%. The MWA case manager will schedule a face-to-face meeting with the participant to explain the participation requirements and changes in the sanction policy regarding non-compliance with work requirements.

If the participant attends this meeting with the case manager, the case manager will send an alert to end the current sanction. FAMIS completes this action without FSD staff intervention.

EXAMPLE: Joe is currently sanctioned for non-compliance with work requirements. His grant amount is $175.00. Joe receives a letter and is scheduled for a required face-to-face meeting with his MWA case manager. Joe goes to his meeting. The case manager sends an alert to end the current 25% sanction. Joe must participate in work activities for at least one week during the six week period, or the case manager will send an alert to sanction Joe’s TA benefit 50%.

If the participant does not attend this meeting with the case manager, the current 25% sanction remains imposed. Following the scheduled date of the meeting, these participants have six weeks to comply for at least one week with the work requirements.

• If the sanctioned participant complies during the six week period, the case manager will send an alert to end the 25% sanction. FAMIS completes this action without FSD staff intervention.
• If the participant fails to comply with work requirements during the six week period, an alert will be sent to FAMIS to reduce the TA benefit 50%. FAMIS completes this action without FSD staff intervention.

EXAMPLE: Sue has a two person household and is currently sanctioned for non-compliance with work requirements. Her grant amount is $175.00. Sue receives a letter and is scheduled for a face-to-face meeting with her MWA case manager. Sue does NOT attend her meeting and does NOT participate in work and training activity for at least one week during the six week period. FAMIS will automatically change the current 25% sanction to the 50% sanction of her TA benefit based on the full TA benefit amount. Sue’s TA grant amount is now $117.00 ($234.00 reduced by 50%).

The household will receive the reduced grant for up to ten (10) additional weeks if they remain eligible for TA on all other factors. When the TA benefit has been reduced by 50%, the participant is required to complete four (4) consecutive weeks of participation in work activities for a minimum average of thirty (30) hours per week before the sanction can be ended.

The ten week period provides the individual additional time to comply with work requirements. When the participant has completed four consecutive weeks of work activities for an average of thirty hours per week, the MWA case manager will send an alert to lift the sanction. FAMIS completes this action without FSD staff intervention.

Failure to complete four (4) consecutive weeks of participation at the minimum average of thirty (30) hours per week by the end of the ten (10) week period will result in the imposition of a full-family sanction and the TA case closing. FAMIS completes this action without FSD staff intervention.

TA Applicants with a Full Family Sanction Imposed

When an individual re-applies for TA after the case was closed due to a full family sanction, they must meet all eligibility factors for TA and complete a work activity for a minimum average of thirty hours for at least one week prior to approval of the TA case.

Review the work requirements with the applicant. If they now meet an exemption or exclusion, update the TA Work Requirement (COMPACT/FM8B) screen and Work Requirement Indicator code. End the full family sanction (WRF) on the Sanction/Disqualification (SANDISQ/FMAM) screen and enter the appropriate code for the end reason. No information or alerts are needed from the MWA case manager if the applicant now meets an exemption or exclusion.

When the application is registered in FAMIS, a referral to MWA will occur overnight. The case manager will schedule a meeting with the individual that currently has a full family sanction imposed. FSD staff are not able to approve the TA application until the full-family sanction is ended or the eligibility specialist determines the individual meets an exemption or exclusion to TA work requirements.

When the individual has completed thirty hours for at least one week, the MWA case manager will send an alert to FAMIS ending the full-family sanction. This will allow the TA eligibility determination to process if no other eligibility factors are pending.

As a reminder to staff, when a TA cash grant is sanctioned staff must follow Food Stamp policy referenced in 1115.080.00 Prohibition In Increasing Food Stamp Benefits. A daily report of the alerts created which implement and lift sanctions for non-compliance with TA work requirements will be sent to the TA Processing Center.

When a TA participant contacts FSD staff to comply with TA work requirements while the adverse action is pending, advise the individual of the proposed sanction and cite the reason for the action on the Adverse Action Notice (FA-510). To comply with work requirements, refer the individual to their MWA case manager.  To find the MWA office nearest the participant, go to Missouri Work Assistance Program. Follow normal procedures if the individual requests a hearing.

NECESSARY ACTION:

• Review this memorandum with appropriate staff.

JG/am