Update : Food Stamps Quarterly Reporting/Prospective Budgeting (QR/PB) Q & A #1

Transcription

1 Santa Clara County Social Services Agency page 1 Date: 07/02/04 References: ACL #03-18 & 04-19, ACINs #I-54-03, I-84-03, I-09-04, I & I Cross-References: FS Updates #04-11 & Clerical: Handbook Revision: Distribution: No Yes Food Stamp Update Distribution List Update : Food Stamps Quarterly Reporting/Prospective Budgeting (QR/PB) Q & A #1 Background The California Department of Social Services (CDSS) has provided information to answer questions from various counties regarding Quarterly Reporting/Prospective Budgeting (QR/PB). Also Staff Development has been submitting questions that staff asked at the QR/PB training sessions that needed to be answered by Program. Clarifications Clarifications of Quarterly Reporting/Prospective Budgeting are as follows: Cycles The following questions and answers pertain to Cycle issues: Adding a New Program Q. If an existing Non-Assistance (NA) FS household (HH) applies for CalWORKs, does the report quarter stay the same or does it change to correspond with the new program? A. The CalWORKs program would adjust to the existing NA FS QR cycle. The FS program cannot shorten its certification period solely on the basis of conforming to another reporting cycle. Inter-County Transfers Q. For an Intercounty Transfer (ICT) is a new quarter started based on Santa Clara County s cycle methodology or are the quarters that were set up in the sending county used? A. A new quarter is started based on Santa Clara County s cycle methodology.

2 page 2 Update : Food Stamps Reminder: If the county grants FS prior to the CalWORKs case, the FS application approval date would drive the QR cycle. QR 7 The following questions and answers pertain to the QR 7 process: Completeness Criteria for QR 7 Q. If a household reports a change in circumstances mid-quarter and the appropriate case action has been taken prior to the first day of the Submit Month, is the QR 7 report considered complete if the household fails to report that information on the QR 7? A. No. The QR 7 is considered INCOMPLETE and a Y NOA must be sent. The household must report any change in circumstance that has occurred since the household submitted its last QR 7 report on the current QR 7. [22.3.6] Exception: If the household reports an increase in shelter costs mid-quarter, which results in increased benefits, the shelter increase does not have to be reported on the QR 7. 20% Earned Income Disregard Q. Should the 20% earned income disregard be allowed when good cause for late reporting exists? A. Yes. When good cause exists for late QR 7 reporting, the 20% earned income disregard is allowed. [33.8.6] When calculating an over-issuance (O/I), where good cause does not exist, the 20% earned income disregard is NOT allowed on that portion of earned income which the HH failed to report. Shelter Cost Changes Q. Does the client need to report a decrease in shelter costs on the QR 7 even when the HH has not moved? If the decrease was reported voluntarily during the quarter, is the QR 7 incomplete if the HH fails to report it again on the next QR 7? A. No to both questions. The client is only required to report shelter cost changes at recertification or when the HH moves. The QR 7 would not be considered incomplete if the recipient fails to report the change on the next QR 7. [22.3.6] Financial Eligibility The following questions pertain to financial eligibility issues:

3 Update : Food Stamps page 3 Conversion Factor Q. Is the multiplier/conversion factor used when determining financial eligibility even if using the conversion factor makes the client ineligible? A HH of 1 receives UIB of $230 weekly and is paid bi-weekly. $230 x 2 x = $ However, in the month of application the HH only anticipates receiving 2 bi-weekly checks. $230 x 2 x 2 = $920. The FSP gross income limit for a family of 1 is $960. A. Yes. The conversion factor MUST be used to determine the average monthly income, and the average monthly income is used to determine if the HH passes the gross income test. Joint CW/FS Application - CW Ineligible for 1st Month of QR Payment Quarter Q. What actions are required for a joint CalWORKs/FS application, where the household is ineligible for CalWORKs for the first month of the quarter but eligible for FS? Calworks/FS joint application in May. Calworks income ineligible for May, eligible for June. A. If the CW case is financially ineligible for the first month but eligible for the second month, pend the CW application and approve the first of the second month. The quarter will be established based on the approval date for FS so the quarter will be May, June, July. The CalWORKs budget for this situation will be based on the averaged income for June and July. Set up NAFS for May based on the May, June, July averaged income. Close the NAFS case at the end of May and establish the PA benefits as of June. PA benefits are calculated using the averaged income and actual CW grant for June and July. Budgeting Issues The following Questions & Answers pertain to budgeting issues: PA Grant - Joint CW/FS Application Q. Is the statement If you applied for cash aid, and it has not yet been approved, your Food Stamp benefits may be lowered or stopped without another notice if your cash aid is approved, on the notice still applicable? A. Yes, this language still applies. This action is taken ONLY during the application process when a joint CalWORKs and FS application is taken and Public Assistance (PA) eligibility is pending. If CalWORKs is granted after FS has been paid, the new CalWORKs income must be used to compute Food Stamp benefits for the remaining months of the current quarter even if this would result in a mid-quarter decrease in benefits. [17.3.4]

4 page 4 PA Grant - Continuing FS Case Update : Food Stamps Q. If a family is currently receiving Non-assistance Food Stamps (FS) and they apply for and are granted cash aid in the middle of a quarter, how should the new CalWORKs grant be budgeted when determining ongoing FS benefits? A. When a CalWORKs grant changes or a new CalWORKs grant is approved, these changes are known to county information, and the worker would take action to calculate a new FS budget using the CalWORKs grant as income. If the CalWORKs grant change would increase FS benefits, the current month s FS Benefits would be supplemented. If the CalWORKs grant change would result in a decrease in FS benefits mid-quarter, the EW will NOT take action to decrease benefits. When the next QR 7 is received, the EW will recalculate FS benefits based on the information in the QR 7 and the CalWORKs grant at that time. [17.3.4] UIB Q. Under QR/PB rules, can we reasonably anticipate Unemployment Insurance Benefits (UIB) if the recipient has not yet received his/her first check? A. Yes. Under QR/PB rules income that is reasonably anticipated to be received during the QR Payment Quarter must be used in computing the Food Stamp budget. Income is considered to be reasonably anticipated if the worker determines that: The income has been or will be approved or authorized within the upcoming quarter, or the household is otherwise reasonably certain that the income will be received within the quarter; AND The amount of the income is known. Therefore, if UIB meets the definition of reasonably anticipated income it is to be used in the budget, even if the client has not yet received his/her first UIB check. [17.3.3] Note: The policy for the treatment of UIB is different for CHANGE REPORTING households. [Section ] Student Income Q. How is student income received less often than monthly treated under QR/PB rules? A. The rules for the treatment of student income received less often than monthly have not changed under QR/PB rules. Student income received less often than monthly must be averaged over the period the income is intended to cover. The averaged amount is used for any month in the quarter covered by the student income and is then averaged over the quarter.

5 Update : Food Stamps page 5 School year is 09/04 thru 06/05 - net countable student income after allowing student expenses is $3000. $3000 divided by 10 months = $300 per month countable income for 09/04 through 06/05. [23.8.2] (QR Payment quarter is 05/05, 06/05 & 07/05) To determine average income for the quarter ($300 for 05/05 + $300 for 06/05 + $0 for 07/05 = $600 for the quarter divided by 3 months = $200 per month student income to be used in the FS Budget. Shelter Costs Q. Are rent & utility changes considered one change or are they treated as separate changes in recomputing the budget mid-quarter. A. Shelter cost changes are considered one change that includes both rent and utility costs. Quarter: June, July & August. Shelter costs being budgeted are $200 rent and $227 full SUA. The HH reports moving in July and that the new rent amount is $400 which includes all utilities. In determining whether benefits will increase for the current month, the FS budget would be recomputed using $400 rent and no SUA. Expenses Q. When a recipient reports a mid-quarter change in expenses for a FUTURE month, how is the recomputation done? QR/PB rules state mid-quarter changes in income & expenses are averaged over the current and remaining months of the QR Payment Quarter but the change isn t occurring until a future month. A. CDSS has modified its policy. Changes in expenses are acted upon beginning with the month of report OR the month of the change, whichever is LATER. [17.3.9] Quarter is May, June & July. Recipient calls on May 28th to report she has to pay $50 weekly for child care as of June 7th. She expects to pay $200 in June and $250 in July. Although the report was received in May, the change doesn t occur until June, so no action can be effective until June. The June ($200) and July ($250) child care expenses would be averaged and the average ($225) used to determine benefits for June & July. May s benefits would remain unchanged.

6 page 6 Correction of Errors Update : Food Stamps Q. When an individual applies for aid and reports $500 income for the future month and the worker enters it incorrectly as $300, can the benefits be changed for the future month or must they remain the same for the remainder of the quarter and an administrative over-issuance be computed for the entire quarter? A. Yes. Correction of administrative and client reporting errors is a mid-quarter county-initiated action under QR. If the EW makes an error in the budget calculation for FS, action must be taken immediately to correct the error with timely and adequate notice. Also, if the reverse was to take place, that is, the EW erroneously enters $500 when the recipient reported $300 income, immediate action must be taken to supplement the HH and increase the future benefits. Supplemental FS Benefits Q. If a recipient reports a decrease in income late in the month and the worker can t take action until on or after the 1st of the following month, must the supplemental FS benefits be issued or can they be used to offset an existing over-issuance (O/I)? A. Supplements resulting from decreased income reported mid-quarter cannot be used to offset an existing over issuance. Supplements resulting from voluntary reports of decreased income or addition of a new HH member are not considered lost benefits and cannot be used to offset an O/I, even if the supplement is not issued until in the following month. A supplement is required to be paid for the month in which the change occurred and was reported. Adding a Person Mid-Quarter Q. When a person with income is reported in the home mid-quarter, how is the budget recomputed to determine whether benefits will increase or decrease? A. The pending HH member s income is averaged for the remaining months of the quarter. The existing HH s monthly income when adding a new person to the grant is NOT recalculated. The new benefit amount is based on the existing HH s averaged income and the added person s new monthly averaged income. [17.3.9] Combining Two FS HHs Q. How do we combine two FS HHs who are on different cycles? A. When the first HH reports the change on their QR 7, the cases are to be combined as of the first of the upcoming QR Payment Quarter. This is considered a request for aid which is a county-initiated change. This allows the county to discontinue one of the households, if necessary mid-quarter, in order to combine the cases.

7 Update : Food Stamps page 7 19 year old on FS moves in with her mother on July 3rd. She reports this on July 6th. Her quarter is July, August & September. Since the HH composition change occurred mid-quarter, a No Change NOA must be sent reminding her to report this change on her next QR 7. Mother is also on FS and her quarter is June, July & August. When the mother turns in her July QR 7 in August, reporting her daughter moved into the home in July, the daughter would be added to the mother s case as of the first of the upcoming QR Payment Quarter (i.e., as of September 1, 2004). Since an application has been made for the 19-year old in another case, a county-initiated action is required under QR/PB rules to discontinue the daughter s FS case effective August 31, Decreased Income of one of the FS HH members Q. When there are two or more persons with income in the household and one member experiences a decrease in income, how is the budget recomputed to determine whether benefits will increase or decrease? A. When a HH consists of two or more members with income, and one of them experiences a decrease in income, that person s income is recalculated. The income of a person(s) who did not experience a decrease in income is NOT recalculated. The new benefits are based on the new averaged income of the person who experienced the change and the existing averaged income of the person(s) who did not experience a change. [17.3.9] Decrease in one Source of Income Q. If a household member has two or more sources of income and experiences a decrease in one of them, how is the budget recomputed to determine whether benefits will increase or decrease? A. When a HH member has receives income from two or more sources of income, and voluntarily reports a decrease of income from one of the sources, only that income source that experienced the decrease will be recalculated. The new benefits are based on the existing averaged income from the source of income that did not change and the newly averaged income from the source of income that did change.[17.3.9] Mid-Quarter Change The following questions and answers pertain to Mid-Quarter Changes: Definition Q. When exactly does the mid-quarter start?

8 page 8 Update : Food Stamps A. With regard to reporting, the term mid-quarter means any change reported during the QR Payment Quarter outside of the QR 7 report process. PA Grant Supplement Q. If you change a CalWORKs grant due to a mid-quarter report and issue a CalWORKs supplement, what CalWORKs grant amount should be used to refigure the FS budget to see if a supplement is due for Food Stamps? A. The new CalWORKs grant, which includes the original CalWORKs grant amount plus the CalWORKs supplement, must be used when refiguring the FS benefits. [17.3.4] No Change to CalWORKs Q. If a voluntary report results in no change or decrease to CalWORKs, but the FS would increase because of the reported change, can the FS benefits be increased? A. Yes, the EW would act to increase FS benefits in this situation. SSI Q. Would the receipt of Supplemental Security Income/State Supplemental Program (SSI/SSP) require a mid-quarter action? If action cannot be taken during mid-quarter wouldn t it be considered duplicate aid to issue Food Stamp benefits and SSI/SSP at the same time? A. No. Under QR, benefits may only be decreased or discontinued during the quarter under limited circumstances. The receipt of SSI/SSP is NOT one of them. A Food Stamp household member cannot be discontinued mid-quarter due to the receipt of SSI/SSP. This individual is discontinued at the end of the quarter. If the person begins receiving SSI/SSP in a Submit Month, that individual is discontinued at the end of the current quarter, IF timely notice can be given, or at the end of the upcoming QR Payment Quarter IF timely notice cannot be given. Quarter: July, August & September. A FS recipient begins receiving SSI/SSP benefits in September and reports this on their August QR 7 submitted on September 10th. The EW would discontinuance this individual at the end of the current quarter (i.e., September 30th) with a 10-day NOA. Quarter: July, August & September. A Food Stamp recipient begins receiving SSI/SSP benefits in September (submit month). She voluntarily reports this to her EW on September 24th. Since it is too late to send a 10-day NOA to discontinue her at the end of the current quarter, a No Change NOA must be sent. This individual will be discontinued at the end of the upcoming QR Payment Quarter when the HH submits its

9 Update : Food Stamps page 9 November QR 7 in December. Since the HH was not required to report the receipt of SSI/SSP until on the November QR 7, no overissuance has occurred. It is NOT considered duplicate aid if a person receives Food Stamp benefits at the same time as he/she receives SSI/SSP. Out of State Q. If an individual member of a FS HH notifies us that he/she has moved out of state, must we remove the individual mid-quarter even if it means that the benefits for the remainder of the FS HH will decrease? A. Yes. If the individual changes residence to another state, the individual would be discontinued. A mid-quarter decrease is required in this situation because the individual has moved out of state and is no longer a California resident and would not be eligible for benefits in California. Death of FS HH member Q. If a household member dies during the quarter, what action must be taken? A. If mid-quarter information becomes known to the county that a HH member is deceased, the report MUST be treated as a request for discontinuance. If the report is verbal, the decrease/discontinuance is taken at the end of the month in which timely and adequate notice can be given. If the report is in writing, the decrease/discontinuance is taken at the end of the month with adequate notice. This represents an exception to mid-quarter decreases that involve discontinuance of an individual HH member mid-quarter. The death of a recipient must be reported on the QR 7. However, if a HH does not report the death of a recipient until the QR 7, no overissuance shall be assessed for failure to report the death mid-quarter. [21.3.1] Proration of Expenses Q. When a person is added to a FS HH, when is the proration of expenses changed? A. The proration of expenses is done in the month the person is added to the household. The HH consists of an SSI mother, one child, and one unborn. The reporting cycle is July, August and September. Income is pooled with SSI mom. The $600 rent is prorated by 2 = $300 rent currently being used in the FS budget. The child s birth is reported in July and the newborn is added to the FS HH as of August. The rent deduction changes from 1/2 to 2/3 when the newborn is added to the HH in August. The rent deduction for August will be $400 (2/3 of $600).

10 page 10 Subsequent Mid-Quarter Change Update : Food Stamps Q. If a new member is not added to the household (HH) mid-quarter because it would decrease benefits, if a change in that person s circumstances happens later in the quarter, can we re-evaluate then? A. Yes. All mid-quarter changes are treated separately and sequentially. The current payment quarter is June, July and August. The HH consists of mom and child. Mom reports that dad who is earning $900 per month moved into the home on June 5th. Adding Dad as of July 1st would reduce benefits to the HH so no action is taken. However, dad is laid off from his job on July 9th. Mom reports dad s job loss on July 12th. The change in circumstances caused by the job loss is a new report and a reevaluation must be done. Dad would be added to the HH effective August 1st, as this will result in a Food Stamp benefit increase. [ & 21.4] Duplicate Report of Information Q. If a recipient reports a change mid-quarter which has already been taken into consideration in computing the QR Payment Quarter budget, what action should be taken? A. If the information has already been taken into consideration in setting up the QR Payment Quarter, a recomputation for the quarter CANNOT be done. [17.3.9] On the March QR7, received in April, the HH reports that the mom s job will end on June 15th. She anticipates receiving $1000 in May, $500 in June and $0 in July. This information is used to set up the budget for the May-July QR Payment Quarter (i.e total income for quarter $1500 divided by 3 = $500 per month used in the FS budget). In June, the mom calls and reports the job ended and she received her final check for $500 and anticipates $0 income in July. A recomputation can NOT be done since there is NO change from what was reported initially on the QR 7, and used in computing the QR Payment Quarter FS budget. Multiple Mid-Quarter Changes Q. How does the county treat multiple mid-quarter changes when they are all reported at the same time? A. Each change must be evaluated separately and according to the sequence of occurrence, keeping in mind the timing of when benefits can be increased based on decreased income and new household members in the QR/PB system.

11 Update : Food Stamps page 11 The rules for increasing benefits based on decreased income require benefits be increased (supplemented) in the month of the report. The rules for adding new persons to the HH require that benefits be increased to reflect the add-on no earlier than the first of the month following the report of the change. When there is both a change in income for an existing household member and an addition of a new person reported at the same time, then: If the new person being added to the HH has income, the EW must first consider the add-on, taking into consideration the income that this individual brings to the HH without considering the change in income of the existing HH member. Once the EW determines whether to add the new person as of the next month or the next quarter, then the EW would recompute benefits based on the change in income of the existing HH member. HH consists of mom and her child. Mom is working part-time. QR Payment Quarter is August, September and October. Mom s second child enters the home on August 3th and mom loses her job on August 6th. Both changes are reported on August 9th. In the scenario above, the EW first must evaluate adding the child, taking into consideration any income the child has but without taking into consideration mom s decreased income. Once it is determined that the child will be added as of September, then the EW would recompute August budget based on mom s decreased income. The September FS benefits would be based on a HH of 3 with the decreased level of income resulting from the job loss. [21.4 & ] Note: For Quality Control purposes, it is critical in each of these types of situations for the EW to document the rationale/justification for the action taken. The documentation/narrative should include a discussion about the sequence of the changes, the action taken, and the reason for the action. Request for Information/ Verification Q. When a HH reports a change mid-quarter, and verification is required, must the request for verification be in writing? A. Yes. The EW must request verification in writing. The 71R speedletter must be sent to the household. Q. If the HH provides the verification timely (within 10 days) but in the following month, can the HH be supplemented for the month that the change was reported?

12 page 12 Update : Food Stamps A. Yes. If the HH timely provides verification (within 10 days of the request), even if the verification is provided in the following month, then the HH is entitled to benefits for the month in which the change was reported. Quarter: May, June & July HH reports on June 28th that the mother was laid off from her job on June 16th. A statement from the employer is submitted on July 2nd. Since the verification was received timely, the June FS budget must be recomputed to determine if the HH is entitled to a supplement for June. Q. If the HH fails to provide the verification within 10 days, what action must be taken? A. If the HH fails to provide the verification timely (within 10 days), the EW MUST send a No Change NOA to the HH. If the HH provides verification after the 10-day period, the date the verification is provided is considered the date of a new voluntary report. The month in which the verification was received and the remaining months of the quarter can be supplemented. Quarter: May, June & July HH reports on June 28th that the mother was laid off from her job on June 16th. On July 12th a No Change NOA is sent to the HH. The HH submits a statement from the employer on July 22nd. This is now considered a new mid-quarter report and the current month (July) can be supplement. [ & ] Failure to Provide Information - New Member Q. What action can be taken mid-quarter when the HH makes a voluntary mid-quarter report of a new HH member and fails to provide necessary information/verification to add the new person? When should the HH be discontinued for failing to provide information/verification? A. If the HH requests to add a new person, the HH must be given 10 days to provide the necessary information/verifications. If the HH fails to do so, a NO Change NOA must be sent to the HH indicating that their benefits will not increase. This would equate to denying the request to add the new person. If the HH later provides the information/verification, the date of receipt of the information/verification is considered a NEW mid-quarter report. The EW must wait until the end of the quarter in which the new HH member is required to be reported on the QR 7. If the HH does not report the new member on the QR 7, the EW must act to resolve the discrepancy and the HH must provide information/verification on the same time lines that are required if the new member was reported on the QR 7. [ & ]

13 Update : Food Stamps page 13 Other Issues The following questions and answers pertain to other QR/PB issues: Transitioning between Change Reporting and Quarterly Reporting Q. What is required to transition a FS case from Change Reporting to Quarterly Reporting or vice-versa. A. When a FS HH changes its reporting status from change reporting to quarterly reporting, the following steps must be taken: 1. Put the HH into a QR cycle based on the application or RC date, as appropriate. 2. Determine when the first QR 7 for the HH is due. 3. Ensure that the HH is properly informed about the QR/PB rules including mandatory reporting requirements, QR 7 due dates, Issue the HH a TEMP QR 1, QR 7A, and the appropriate QR Cycle card. When a QR/PB HH changes its status to change reporting from quarterly reporting, the following steps must be taken: 1. Remove the HH from the QR cycle and stop sending QR 7s; 2. Inform the HH of their new reporting requirements as a Change Reporting HH; Establish benefits based on last known income and any anticipated income. Third Party Information Q. Do we need to take any action prior to the QR 7 when we receive an anonymous report of information that a recipient could have VOLUNTARILY reported but didn t? A. No. If the anonymous tip is about information that is not required to be reported, the EW must note the information in the case file and wait for the next QR 7. If the information is not reported on the next QR 7, the EW must take appropriate action to resolve any inconsistency. No Change Notice of Action (NOA) Q. Is a No Change NOA required to be sent when a HH voluntarily reports a change in property mid-quarter? A. Yes. A No Change NOA must be sent if the HH has voluntarily reported new resources mid-quarter. The No Change NOA includes language reminding the recipient to report this information on the next QR 7 submitted. TFS Q. When CalWORKs is discontinued mid-quarter is the HH still eligible for Transitional Food Stamp (TFS) benefits?

14 page 14 Update : Food Stamps A. Yes, when CalWORKs is discontinued mid-quarter, a Food Stamp household is eligible for TFS from the first of the month following the CalWORKs discontinuance, if the HH is otherwise eligible for TFS. CalWORKs/FS AU/HH reports income over the Income Reporting Threshold (IRT). A determination is made that the AU/HH fails the income tests for CalWORKs and regular Food Stamps. CalWORKs and Food Stamps are discontinued at the end of the month. The first of the following month TFS benefits must be set up for the HH, if otherwise eligible. Implementation The information contained in this Update is effective upon receipt. Other Programs This information applies to the Food Stamp Program ONLY. KATHERINE BUCKOVETZ, DIRECTOR Department of Employment and Benefit Services Contact Person(s): Susan Maxwell, Food Stamp Program Coordinator, Idelle Villarreal, Program Coordinator,

15 Santa Clara County Social Services Agency page 1 Date: 07/02/04 Filing Instructions for Update : Food Stamps Quarterly Reporting/Prospective Budgeting (QR/PB) Q & A #1 Remove Replace with Chapter 17, pages (07/01/04) Chapter 17, pages (07/02/04) Chapter 21, pages 6-10 (07/01/04) Chapter 21, pages 6-10 (07/02/04) Chapter 22, pages 7-8 (07/01/04) Chapter 22, pages 7-8 (07/02/04) Chapter 33, pages (04/01/04) Chapter 33, pages (07/02/04)

16 page 2 Filing Instructions for Update : Food Stamps