Update : CalFresh Semi-Annual Reporting (SAR) Implementation

Transcription

1 Santa Clara County Social Services Agency page 1 Date: 08/02/13 (Revised 10/28/13) References: ACL #12-25, ACL #13-08, ACL #13-17, #13-26,#13-57, State PIs Cross-References: CalWORKs Update Clerical: Handbook Revision: Yes Yes Semi-Annual Reporting (SAR) Implementation Background Assembly Bill (AB) 6 requires the replacement of the current Quarterly Reporting /Prospective Budgeting (QR/PB) system with a Semi-Annual Reporting system for the CalFresh program. Changes The new SAR system applies to all CalFresh households with the exception of CalFresh Change Reporting (CR) households. These CR households will continue to follow existing CR rules and will not be required to submit semi-annual reports. What s New in SAR SAR is similar to QR/PB in most of its reporting requirements and budgeting methodology. The following are the changes under SAR: Households are required to submit one Semi-Annual Eligibility Report (SAR 7) once a year (in the sixth month of the first semi-annual period) followed by the annual recertification (RC) of eligibility. The RC will take the place of the second eligibility report. Reporting cycles change from quarterly to semi-annual. A cycle will be established based on Beginning Date of Aid (BDA) for new cases rather than the date of application. Semi-annual report form (SAR 7) will be sent to recipients at the end of the fifth month of the semi-annual reporting period. Recipients return the completed SAR 7 with any required verifications to the county by the 5th day of the sixth month of the semi-annual reporting period.

2 page 2 If a prior mid-period report was previously verified, it must be treated as reported and the SAR 7 should not be considered incomplete if the information is not re-reported on the SAR 7. AR/CO Change Reporting households become SAR. Counties must anticipate income and expenses over the length of the certification period and revise at mid-period when the household submits its SAR 7. At certification, if counties are averaging household income and expenses, they must do so over the length of the certification period and revise at mid-period when the household submits SAR 7. All households except change reporters and households with no gross income test (households with an elderly or disabled member) are required to report any change in income that is likely to render them ineligible for CalFresh benefits (i.e., 130 percent of the Federal Poverty Level [FPL]). Address change is not a mandatory mid-period report. Terminated income will no longer be averaged in the payment period; it will only be counted in the month received. Income that is starting or ending mid-period will no longer be averaged over every month of the Payment Period. Income anticipated during the certification period shall be counted as income only in the month it is expected to be received, unless the income is averaged. Benefits are frozen for the six months of the certification period, except under specified circumstances below. The county must act on changes that: Are required to be reported on the SAR 7/RRR; or Are considered verified upon receipt (VUR) and result in a mid-period increase or decrease in CalFresh benefits due to a change in household composition or income that is verified (NACF only); or Result in a decrease/discontinuance based on mandatory mid-period reports; or result in a decrease/discontinuance based on county-initiated action; or The household requests discontinuance.

3 page 3 Reporting Requirements The changes to the reporting requirements and action required under SAR are as follows: Semi-Annual Report (SAR 7) The SAR 7 replaces the current QR 7, and provides eligibility and income information that the county uses to determine ongoing eligibility and to calculate the allotment amount for the upcoming SAR Payment Period. The RC forms are also modified to request all of the same income and eligibility information that is requested on a SAR 7. This is a simplification from QR/PB so that recipients only have to fill out two eligibility reports a year. All CalFresh recipients who currently submit a QR 7 are required to complete and submit one SAR 7 a year, six months after their application, in addition to their annual RC forms. Completeness Criteria for the SAR 7 The completeness criteria for the SAR 7 remains unchanged from the QR 7 completeness criteria. For the CalFresh Program, the SAR 7 is considered complete if: The form is signed no earlier than the first day of the SAR Submit Month (only one of the parent s signatures is required for CalFresh in a two parent household); All questions and items are fully answered and information on the SAR 7 together with attached documentation provides sufficient information to allow for the determination of eligibility and benefit level; and Required verification is provided. Note: A SAR 7 is considered incomplete if the required mandatory verification is not received. If a SAR 7 is received without the required verification, the County must send a discontinuance notice to the recipient. If a prior mid-period report was previously verified, it must be treated as reported and the SAR 7 should not be considered incomplete if the information is not re-reported on the SAR 7. The information from the verified mid-period report is part of the case file and together with the information reported on the SAR 7 will be used to determine eligibility and the benefit amount. If a submitted SAR 7 does not contain information from a previous (voluntary) unverified report, an action must be taken to resolve the discrepancy between the two reports before changing benefits for

4 page 4 the upcoming semi-annual period. If the discrepancy cannot be resolved, the SAR 7 may be treated as incomplete. [Refer to Chapter 25 for detailed rules regarding SAR 7 completeness criteria]. Verifications When required verifications are not available, an affidavit may be sufficient except verification of U.S. citizenship or non-citizen status. The request for verification must state that the county can assist with obtaining the necessary verification, including payment of fees. After the county has determined that the households has made a good faith effort to obtain the evidence of eligibility but the third party fails or refuses to prove the evidence, and that if other information is not available, an affidavit can be accepted as the only available source of verification. Good Cause Considering that the initial six months of SAR implementation may be difficult and confusing for recipients, counties are strongly urged to apply the good cause provision liberally during the initial six months of implementation for recipients who do not meet their reporting requirements. Eligibility staff can do this by taking into account and documenting in the case record any problems that the recipient may be experiencing in understanding the new SAR reporting rules. It is important that counties should take into account a recipient s ability to understand reporting rules when good cause is being considered. Restoration of Benefits For all CalFresh recipients who have been discontinued for failure to submit a SAR 7, pro-rated benefits will be restored effective the date the completed SAR 7 is received by the county, at any time in the month following the discontinuance, without a new application or interview, and without the need to prove good cause. Mandatory Recipient Mid-period Reports Under SAR, households are required to report specific changes to the county within 10 calendar days of the date the change becomes known to the household. Households may report these mid-period changes verbally, in person, by telephone, or in writing. The EW MUST document the substance of the report, as well as the date of the report in the case record. Income Reporting Threshold (IRT) All CalFresh recipients who are subject to SAR must report when their income exceeds 130% of the FPL for household size in mid-period. This is the amount likely make a household ineligible for CalFresh.

5 page 5 Some mid-period changes are required to be reported in the CalWORKs program that are NOT required to be reported in the CalFresh program. However, when there is a combined CalWORKs/CalFresh case, if the household reports a change that is required to be reported for CalWORKs, the EW MUST also act on the information to determine CalFresh eligibility/benefit amount. If the change reported for CalWORKs results in discontinuance of CalWORKs benefits, CalFresh must be discontinued at the same time as the CalWORKs at the end of the month after a 10-day notice can be provided. Transitional CalFresh (TCF) benefits must be issued effective the following month, if otherwise eligible. When a household reports their income may be over the CalFresh IRT (130% FPL), the county must ask if the income is expected to continue. If... Then... The income is only expected to last for one month and will not continue at that level, If the household expects the increased income to continue, No action is required. Send out a No Change NOA. Send out the Notice of Information/Verification Needed (CF 377.6) to request verification of income. Note: CF does not meet the requirements of timely notice; therefore, it cannot be used to discontinue the benefits. If... Then... If the requested verification is not received by the due date, If the requested verification is received by the due date, and documentation verifies that the household is over the IRT, If the household returns the verification form stating they are earning an amount less than the household s IRT, and the information is not VUR, If the household returns the form with verification of earnings under the household IRT that is considered VUR, The worker must send a timely discontinuance notice for lack of receipt of the requested information needed to accurately determine eligibility or benefit level. The county must send a timely discontinuance notice. Send out a No Change NOA and document in case record for the SAR 7 or RC forms. Send out a timely notice and then adjust the household amount.

6 page 6 On April 15, a SAR household reports that their income has increased over the IRT. The household expects to continue to receive this income each month. The household was required to report this information. The worker sends a CF requesting proof of the income. The requested verification is not received by the due date and the worker sends a 10 day notice of discontinuance for lack of receipt of the requested information needed to accurately determine eligibility or benefit level. ABAWD For NACF only, if an able-bodied adult without dependents (ABAWD) work hours drop below 20 hours per week or 80 hours per month outside of the household s initial certification/recertification and SAR 7 reporting month. Voluntary Mid-Period Reporting A recipient may voluntarily report changes in income and other circumstances that may increase benefits any time during the semi-annual period. These reports may be made in writing, online, verbally, or in person to the county. For household composition and income changes in both PACF and (NACF) cases, the EW must act on changes considered VUR to increase/reduce or terminate benefits at any point during the certification period. Examples of changes that when reported, might increase or decrease benefits include, but are not limited to the following: When the household s income changes and is verified; When someone moves into or out of the home; When allowable CalFresh deductions increase. [Refer to Verified Upon Receipt (VUR), page -7 of this Update for more information]. To increase the allotment based on voluntary reports, the county must act when the change was reported, not when the change actually occurred. The effective date of the increase in benefits is determined differently for increases due to decreased income than for increases due to adding household members and are as follows: Increases in benefits due to decreased income are effective the first of the month in which the change occurs or is reported, whichever is later. Increases due to the addition of new household members are effective the first of the month following the report of the change.

7 page 7 The recipient should provide verification of the change within the 10 day period listed on the request for verification. If verification is not received within 10 days, the county must send a no-change NOA to the household which states that no action to increase benefits was taken because verification was not received. If verification is provided after 10 days, the date the verification is provided shall be considered the date of the voluntary report. Request for Discontinuance of Benefits A recipient may voluntarily request mid-period that: The entire household be discontinued; or Any individual member of the household who is no longer in the home be discontinued. If the household is requesting discontinuance of the household or an individual, discontinuance action MUST be taken mid-period as follows: If the household or the individual s request is made verbally, a 10-day Notice of Action (NOA) is required before discontinuing or decreasing benefits. If the request is made in writing, discontinue or decrease benefits at the end of the month with adequate notice. A 10-day NOA is NOT required. Verified Upon Receipt (VUR) Verified upon receipt (VUR) means that the information provided is not questionable, the provider is the primary source of the information, and no further information is needed to take action. Changes in benefits (increased or decreased) as a result of a voluntary report, that are considered VUR, must take place the first of the month following the month in which the change is reported. Changes that cannot be verified by client statement alone are: Income; Medical costs for a deduction Legal obligations to pay child support and the amount paid. Examples of information from the primary source considered VUR include: BENDEX and SDX from the Social Security Administration SAVE from the United States Citizenship and Immigration Services Unemployment compensation from the state unemployment agency

8 page 8 Worker s compensation from the state agency. Examples of internal agency information that is considered VUR include: State agency determination of an IPV Actions taken by other programs within the county agency that affect CalFresh income and expenses Information from a state, county or local work agency that a client failed to comply with work requirements. If secondary information is requested for verification in order to act on a change in another program, such as Medi-Cal, then by definition it is not VUR. Counties can hold the results of IEVS match until the SAR 7 or RC if the information is not considered VUR. Information not considered VUR includes, but is not limited to: Quarterly wage match data New hire match, Unearned income matches form Internal Revenue Service, and Wage data from the Social Security Administration. Household Composition Changes A voluntary report of household composition change by the head of household or responsible adult household member is considered VUR, and must be acted on. For reports of household composition change by another source, the county must contact the household to verify eligibility. A mom calls and reports one of her children has left the home. If the household is CalFresh only, act on the change and reduce the household size and send out a timely notice of action (NOA). If the household is a PACF case, since CalWORKs does not act, federal regulations allow CalFresh not to act in mid-period. Send out a No Change NOA and document in case record for the SAR 7 report. Same situation as above, but the report of the child leaving the home comes from a neighbor, a third party. This is not VUR since it was not reported by a primary source (i.e, the head of household). No action is taken until verified with the household.

9 page 9 Income under 130% of FPL When a voluntary mid-period report of income less than the IRT is not verified, the EW must document the report of the change in the case record to be reviewed at the time of the next SAR 7 or recertification and send a No Change NOA. A household is in January through December certification period. On March 15, mom reports she is eligible for Social Security and the first payment of $300 will be received April 3. This information is not VUR because the county needs further information in order to verify the change. If additional verification is not received, no action is taken. Send out a No Change NOA and note in case record for the next SAR 7 or RC. If a household provides undisputed verification that requires no further inquiry and is VUR, then the county must act to reduce benefits. Same scenario as above. On April 7, mom reports she is eligible for Social Security and sends in a copy of the first payment of $300 that was received April 3. This information is considered verified because the county needs no further information in order to verify the change. The EW narrates the information in the case record, sends a 10-day notice to reduce benefits and takes action to change for the May allotment. When the information is received by the primary source of the information and no further information is needed to take action, it is considered VUR. A household is in January through December certification period. On March 15, the county receives an SDX report that indicates a SAR household has been determined eligible for $300 in Social Security benefits and the first regular payment will be April 3. This information is considered VUR because it was reported by the party that is responsible for the income. The EW narrates the information in the case record, sends a 10-day notice to reduce benefits and takes action for the April benefits. County Initiated Mid-Period Actions In addition to making mid-period adjustments to benefits as a result of mandatory and voluntary recipient reports, the county must also act on certain changes in eligibility status at the end of the month in which a timely and adequate notice can be provided, even if it results in a

10 page 10 decrease or termination of benefits. The changes in eligibility status listed below are considered county-initiated and may occur at any time during the semi-annual period. They include, but are not limited to: Sanctions or financial penalties; Failure of a member of the household to comply with a Quality Control Review; Discontinuances due to the termination of a CalWORKs inter-county transfer; Benefits are applied for and approved for a household member in another household or for the household; Change from state funding California Food Assistance Program (CFAP) to federal SNAP which shall be seamless to the client; Cost of Living adjustments (COLAs) for the CalFresh, CalWORKs, General Assistance and for those COLAs administered by the Social Security Administration; Adjustments due to erroneous or incomplete recipient SAR 7 or mid-period reports of information or lack of action by the county on the SAR 7 or mid-period recipient reports; The three-month limit for an ABAWD ends or an ABAWD who is not exempt and doesn t reside in an area with an ABAWD waiver who has regained eligibility and subsequently stops meeting the work requirements; The county discovers Transitional CalFresh recipients have moved out-of-state and are receiving public benefits (TANF and/or SNAP) in another state; and A member of the household receives SSI/SSP benefits. Adding a sanctioned person back to the household the month following the expiration of the disqualification period without a request from the household, if the household is otherwise eligible. Move out of State If the county determines that the household is no longer or will not be residing in the state, CalFresh benefits must be terminated in mid-period at the end of the month in which an adequate notice can be sent. An OI may be established if the household was residing out of state and continued to receive benefits from California and the other state at the same period. Transitional CalFresh (TCF) If a household received public benefits (i.e., TANF grants or SNAP) benefits in another state while transitional benefits are received in CA, the TCF benefits must be discontinued. An OI must be established if TANF or SNAP benefits were concurrently issued in another state. However, if public benefits are not received out-of-state while TCF benefits are received in CA then the TCF benefits would continue for the full duration of the TCF benefit period.

11 page 11 Move out of County When at least one member of the CalFresh household also receives CalWORKs, the CalWORKs ICT process must be followed. When at least one member of the CalFresh household receives Medi-Cal, but no household member receives CalWORKs, the Medi-Cal ICT process must be followed. [Refer to ICT Chapter 36] Third Party Information/Known to the County Under certain circumstances, information will be known to the county or will be provided to the county through a third-party. Such information should be used by the county to: Calculate an OP/OI when the information received is considered a mandatory report and is obtained after benefits have been issued in the wrong amount (e.g., Income and Eligibility Verification Systems (IEVS) matches); and Take prospective action to change benefits mid-period or at the beginning of a semi-annual period if the county learns that the recipient failed to accurately report changes on a mandatory mid-period report or on the SAR 7 or RC forms. All third party information that is received by or known to the county must be acted upon in accordance with SAR rules. If a change is required to be reported by the recipient under SAR rules, the county must take action to verify the information and take action based on the information once it has been verified. If a change is not required to be reported, such as a change of income not over IRT that occurs mid-period, the county may use the third party information as ancillary information to ensure that the next semi-annual report submitted by the recipient is consistent with other information known to the county. If the information on the SAR 7 or RC forms is not consistent with what has already been reported or is being reported through a third party, the county must seek to resolve the discrepancy. If the county cannot resolve the discrepancy, the SAR 7 or RC forms may be considered incomplete. Recertification All existing regulation relevant to CalFresh RC will continue to apply in the SAR system. However, under SAR, counties must use the RC forms in place of the second SAR 7 to determine continuing eligibility and the next SAR Payment Period s benefit amount. Because RC will be used to determine the next SAR payment Period s benefit amounts, counties must schedule the RC early enough in the month to be able to establish the next SAR Payment Period s benefits.

12 page 12 Reminder: Counties must align CalWORKs RD and CalFresh RC with the SAR cycle assigned to each recipient and RD/RCs must take place in the sixth month (Submit Month) of the second semi-annual period. This ensures that recipients only have two mandatory eligibility reports a year. Eligibility and Benefit Calculations The following changes affect Eligibility Determinations and Benefit Calculations: Income Eligibility Determination For both PA and NA CalFresh households which are subject to SAR, counties must anticipate income and expenses over the length of the certification period and revise at mid-period when the household submits its periodic report form. The information on the SAR 7 or RC forms is used to determine continuing eligibly and future benefit amounts based on all eligibility factors. The SAR 7 or RC forms provides: A report of income received by the household in the SAR Data Month. Any changes affecting the household s eligibility since the submission of the last report, and Any changes in income and expenses the household anticipates will occur in the upcoming SAR Payment Period. Based on the information reported on the SAR 7 or RC forms, continuing eligibility is determined as it relates to income and household composition using prospective budgeting rules. The information verified from a voluntary or mandatory mid-period report that results in a mid-period benefit change is also used to determine continuing eligibility and future benefit amounts. Financial Eligibility Test For NACF households that do not have elderly or disabled household members, the county is required to determine the reasonably anticipated monthly income for the certification period and compare it to 130% of the FPL to determine if the household passes the 130% FPL gross income test and is financially eligible. For PACF cases, if the companion CalWORKs case is determined financially eligible, the CalFresh household is considered categorically eligible and no Gross income test is necessary for CalFresh purposes.

13 page 13 A household s eligibility shall be determined for the month of application as of the date of the interview. If the household s eligibility has been determined, but the county has not yet authorized the issuance of benefits, and a non-mandatory change is reported prior to the authorization of benefits, the county shall treat the change like any other voluntary mid-period report unless, it is considered VUR. The determination of continued recipient financial eligibility for CalFresh occurs under the following two circumstances: When the county reviews a SAR 7 or the annual RC forms submitted by a recipient, the county must determine if the household will continue to be financially eligible in the upcoming SAR Payment Period based on income that the household reasonably anticipates to be received in the remainder of the certification period. When a household makes a mandatory mid-period report of income over their IRT, the county must determine if the household maintains continued financial eligibility for the current SAR Payment Period. If eligibility is maintained, their benefits must be recalculated for the remainder of the SAR Period based on the income over IRT. Prospective Budgeting Under SAR, income that the household reasonably anticipated it will receive in the certification period is used when calculating benefits for the upcoming SAR Payment Period. Income and household information from the SAR Data Month, as well as anticipated changes in income and expenses must be used when determining continuing eligibility and benefit levels. When income or expense is averaged, it must be averaged over the certification period and revise at mid-period when the household submits its periodic report form. At application, recipient reports receiving $100 in earnings every week and reasonably anticipates that this income will continue at the same amount for the upcoming certification period. The $100 weekly income is multiplied by the weekly multiplier of 4.33 to determine the monthly average income amount of $433. (If the household reports receiving $200 every two weeks, the $200 bi-weekly income is multiplied by the bi-weekly multiplier of to determine the monthly average income amount of $433.) This amount would be forecast over the entire certification period, and then recalculated for the remainder of the certification period if a change in income is reported on the SAR 7 or RC forms or a voluntary report (VUR only).

14 page 14 A household reports on his SAR 7 that four weekly paychecks were received in the following amounts: $115, $100, $125, and $95 and indicates on the SAR 7 that his income is not expected to change during the remainder of the certification period. The worker will add the four weeks of income together, divide by four and then multiply the resulting amount by 4.33 to arrive at the average monthly income amount for the remainder of the certification period (i.e.: $115 + $100 + $125 + $95 = $435 / 4 = $ x 4.33 = $470.89). (If five pay periods were reported in the Data Month on the SAR 7, the worker will add each week together, divide by five, and then multiply the resulting amount by 4.33.) Reasonably Anticipated Income Income is reasonably anticipated when the worker determines it is reasonably certain that the recipient will receive a specified amount of income during any month of the certification period. This definition applies to all types of income, earned or unearned. Under SAR, recipients will be required to provide information for the Data Month and any anticipated changes in the six months following the Submit Month. The income received in the Data Month will be considered reasonably anticipated and will be used in the budget calculation unless the recipient reports that they anticipate a change in the upcoming SAR Period. Income is considered to be reasonably anticipated if the county determines that: The income has been or will be approved or authorized within the upcoming SAR period, or the household is otherwise reasonably certain that the income will be received within the SAR period; The amount of the income is known and verified, or the household is otherwise reasonably certain of the amount of the income; and The start date of the income is known and verified, or the household is otherwise reasonably certain of the start date of the income. Reminder: If the amount of income or when the income will be received is uncertain, i.e. it cannot be reasonably anticipated, that portion of the household s income that is uncertain or cannot be reasonably anticipated will NOT be counted when determining income eligibility and benefit levels.

15 page 15 A recipient s income varies between $200 and $400 a month and the employer can t confirm the earnings or schedule, but the recipient states that earnings are usually at least $200. The county should list $200 as reasonably anticipated income. If the recipient s income varies dramatically (for example someone who is waiting for an on-call substitute position, who doesn t know whether there will be any work or any minimum hours) there is no income that can be reasonably anticipated and no income will be budgeted. EWs will be required to make a determination of what income is reasonably anticipated when: A household first applies for benefits; A recipient household reports new income on the SAR 7; A recipient household reports on the SAR 7 that income is expected to change; A recipient household has income that fluctuates; and A recipient makes a mid-period report of an income change. Conversion Factor Weekly or bi-weekly stable income received by a Change Reporting or SAR household is converted to a monthly amount by using a conversion factor of: 4.33 for weekly payments, and for bi-weekly payments. Stable Income Stable income is defined as income that is expected to remain at the same level throughout the certification period. If a recipient or applicant household has stable monthly income and does not expect any changes in the certification period, the income reported on the application, SAR 7, or RC forms must be used to determine the benefit amount for the next SAR Payment Period. If the stable income is received weekly or bi-weekly the income shall be converted into a monthly average as described above. Fluctuating Income Income is considered to be fluctuating when the amount of income and its payment frequency is different for each month of the certification period. This includes when the household has income for one or more months of the certification period and zero income for the remaining months of the certification period due to income starting or stopping. It also includes continuing income that changes from month to month. If the household receives weekly or bi-weekly paychecks, but their income fluctuates month to month and they cannot reasonably anticipate that their Data Month income will continue at the same

16 page 16 amount, the conversion multipliers will not be used to convert the Data Month income into a monthly average. In this case, the county should accept the household s estimate of reasonably anticipated income or when that estimate is questionable, contact the household to determine what monthly income (if any) can be reasonably anticipated. A recipient reports that she will work the first three weeks of each month, and be paid $200 per week worked. In this case, since the recipient does not expect to be paid every week, the conversion multiplier would not be used. Instead, the monthly income of $600 is used to determine the benefit amount for the semi-annual period. Medical and Dependent Care Expenses For medical and dependent care expense deductions, the county will determine what the household reasonably anticipates over the certification period. Under SAR rules, a medical or dependent care expense must be determined for the certification period. If the expense is reported mid-period, it must be verified and used for the current and remaining months in the current certification period. As with income, the EW must carefully document the rationale for the determination of reasonably anticipated expenses for the CalFresh household. Contract/Self Employment For both PA and NA, households which, by contract or self-employment, derive their annual income in a period of time shorter than one year must have that income averaged over a 12 month period, provided the income from the contract is not received on an hourly or piecework basis. These households may include school employees, sharecroppers, farmers, and other self-employed households. However, these provisions do not apply to migrant or seasonal farm workers. A mom works at a school cafeteria from September to June. She makes $400 per month only for 10 months in a year. The total amount of income that the mom expects to receive for the entire year (i.e., $400x10=$4,000) must be averaged over a 12 months. Starting or Ending Income Mid-Period Income that is starting or ending mid-period will no longer be averaged over every month of the Payment Period. Income that the recipient anticipates will begin or end in one of the months of the upcoming SAR Payment Period will only be counted in the months that the income is reasonably anticipated to be received. This is a change from QR/PB

17 page 17 and will allow a household to receive the maximum benefit amount in the months in which this income is not received. This rule also apply to intake cases; income from the month of application will only be used to determine eligibility and benefit amount in the month in which it was received. Income that is beginning or ending will be treated differently depending on how certain the household is that the income will begin or end. If the household is certain that their income will be ending or new income will be starting in a certain month of the SAR Payment Period, this income will only be used to determine benefit amounts for the months in which it is reasonably anticipated to be received. In these situations, the county must calculate two different benefit levels for the semi-annual period: one benefit amount for the months in which the income will be received and one benefit amount for the months in which the income will not be received. A household of four is in the June through November SAR period. Mom submits the SAR 7 for October to the county timely on November 8. On the SAR 7, she reports that she will start a part-time job in December that will probably only last until the end of January, when the holiday shopping season has ended. She reports that she will get paid $800 in December and January. The county will calculate her benefits based on $800 monthly anticipated income for December and January and tell the recipient to report when her job has ended. However, if Mom has verification that the job is only for those two months, the county would put that verified information in the case record and act to increase her benefits based on no income beginning in February. A recipient reports on his SAR 7 that he made $800 in the Data Month. He is paid weekly and received four weekly paychecks of $200 each. He writes on his SAR 7 that he anticipates that his Data Month income will not remain the same and explains that he believes he will be laid off in the next month or two. The county will convert his weekly pay into a monthly average by multiplying the $200 weekly pay by 4.33 (i.e.: $200 x 4.33 = $866) and will tell the recipient to report when he gets laid off or his income goes down. (If the recipient had proof of a date his job would end, the county would only count his income in the months it will be received.)

18 page 18 A household of two is in the June through November SAR period. Mom reports on her October SAR 7, which was submitted to the county timely on November 8, that her current job will end December 15, and she will start her new job on January 2. Her monthly salary will increase from $500 to $800. Both jobs are paid twice a month (on the 15th and 30th). She expects to receive her last pay check from her old job in the amount of $250 on December 30 and doesn t expect to receive her first $400 paycheck from her new job until January 30. Her December benefits will be calculated based on her reasonably anticipated December income of $500, her January benefits will be calculated based on her reasonably anticipated January income of $400, and her February through May benefits will be calculated based on her $800 monthly anticipated income. Over-Issuances For the CalFresh program, over-issuances (O/Is) will be established as applicable based on: Household failure to report accurately and completely; County error; or Late SAR 7. Failure to Report If a recipient fails to report changes or information as required (mandatory mid-period reporting, SAR 7 reporting, the RC forms), the amount of the O/I is the difference between the benefits the recipient received and the benefits the recipient would have received under SAR rules if the recipient had reported timely and correctly. If the county recalculation results in an OP/OI, the date that the OP/OI begins is the first date that the change would have been made had a timely and correct action been taken based on a timely and accurate recipient report. If a recipient receives income under IRT that they did not reasonably anticipate at the time of their last mandatory report, this is NOT considered a failure to report and no OP/OI shall be assessed. A recipient works through a temporary employment agency. He reports on his SAR 7 that his job ended in the Data Month. He reports that he is on-call, but that he can t anticipate whether or not he will get another job or make any money in the upcoming six months. The county agrees that he can t reasonably anticipate any income, issues a supplement for the Submit Month and budgets no income for the upcoming SAR Payment Period, without any further contact with the recipient. The county later learns that the temp agency found him a new job that started in the Submit

19 page 19 Month. Unless he failed to report income over IRT or the county has evidence that the temp agency had confirmed the job offer with him in the Data Month, including start date and amount of income, there would be no OP/OI. Late/Incomplete SAR 7 Report Under SAR, an O/I MUST be established when a recipient submits a late SAR 7 which results in the household receiving more benefits than to which it was entitled because of the county s inability to decrease benefits due to the 10-day notice requirement. Incomplete SAR 7s may also result in an OP or OI. If the AU/HH voluntarily reported an unverified change mid-period but that change is not included on their next SAR 7, the county must attempt to resolve the discrepancy. If the county cannot resolve the discrepancy, it must consider the SAR 7 incomplete. If the discrepancy is resolved late in the submit month, and the county does not have time to issue a 10-day notice of decreased benefits, benefits must be released at the higher level and an OP/OI assessed. In the January through June semi-annual period, a recipient submits her SAR 7 late on June 28. After redetermining benefits based on information reported on the SAR 7, the county determines that the July through December benefits should be reduced due to income reported on the SAR 7. The SAR 7 was submitted too late in the month for the county to provide 10-day notice and decrease benefits for July. The county issues a 10-day notice of decreased benefits effective August 1, pays July benefits at the June level, and adjusts benefits to the correct amount for August through December. The county calculates an OP/OI for the month of July. The OP/OI amount is the difference between the July and August benefit amounts. County Error When the county fails to act correctly on a mandatory recipient report or VUR, an administrative O/I must be established. Verified mid-period reports are considered part of the case record and must be entered into the eligibility automation system at the time they were verified. (Failure to include information from verified mid-period reports would thus be an agency error OP, and no OI would be established, as the recipient timely and accurately reported). If a mid-period change (that has already been reported but was not verified) is not reported when the SAR 7 or RC forms are submitted, that is when the household would be considered to have failed to report and the county must act to resolve the discrepancy. If the discrepancy could not be resolved, and the change should have

20 page 20 been reported on the SAR 7, the form would be incomplete. In this case, the county was required to notify the AU/household of an incomplete SAR 7, and issue the appropriate warning and discontinuance NOAs. If the county failed to do this, any resulting OP/OI would be listed as agency error, with the OP/OI established for the amount the AU/household was not entitled to receive, beginning the SAR Payment Period after the incomplete SAR 7 or RD/RC forms were due. An AU/household reports on their SAR 7 submitted on March 5 (for the April through September semi-annual period) that Dad started a job on February 10. The income is expected to continue at the same level in the next SAR Payment Period. The income did not exceed the IRT. The county fails to use the newly reported income to determine benefits for the next SAR Payment Period of April through September. If the county had used the new income to compute the cash aid and CalFresh benefits, the family would have received a lower grant and allotment, so as soon as the county discovers their error they must establish an administrative error OP/OI for the amount the AU/household was not entitled to receive beginning on April 1. Income Exceeds IRT If a HH reports increase in income or new income that exceeds the IRT, which results in ineligibility, but it is too late to provide 10-day notice of adverse action, the county must release benefits for the next month at the previous level. As long as the change was reported timely, no OI shall be established. Additionally, there is no OI in CalFresh if a PACF case fails to report income over the first or second tiers of the IRT because reporting income over those levels is only required in the CalWORKs program. A recipient assigned to the January through June semi-annual period reports receiving income over the IRT within 10 days of receipt, on March 28. After ensuring that the income will continue at the same level, the county determines that the recipient is financially ineligible for both CalWORKs and CalFresh based on the new income amount and should be discontinued. The report was timely, but was received too late in the month for the county to discontinue the recipient effective March 31 due to 10-day noticing requirements. The county must issue a 10-day notice of discontinuance effective April 30. The cash grant for April is an OP. April CalFresh benefits are not considered to be an OI, because the recipient timely

21 page 21 reported. Due to the April 30 discontinuance, Transitional CalFresh benefits would begin on May 1. NOTE: CalWORKs recipients may choose to waive the 10-day noticing requirement in order to avoid an OP. If the AU chooses to have their grant discontinued on March 31, Transitional CalFresh would begin on April 1. Same as above, but the continuing income over the IRT only results in a decrease to the grant amount and does not make the recipient ineligible for either CalWORKs or CalFresh. The county must issue a 10-day notice of decreased benefits effective April 30. An OP would be assessed in CalWORKs for April for the amount of the grant that was released at the higher amount. There would be no OI in CalFresh because the recipient timely reported. O/I Computation When determining whether an O/I should be established based on mid-period changes that are considered mandatory, the EW must determine if the recipient reported the change in a timely manner (i.e., within 10 calendar days). If the recipient reports a mandatory mid-quarter change timely, completely and accurately, an O/I shall NOT be established when the county is unable to issue the correct allotment due to the 10-day notice requirement. Note: Due to CalWORKs and CalFresh having different mid-period reporting requirements, there will be times when failure to report something (such as income over the CalWORKs IRT) will result in an OP in CalWORKs, but will not result in an OI in CalFresh. The AU/HH of three is in the January through June semi-annual period. Mom is convicted of a drug felony that results in ineligibility on April 25 and reports the conviction on April 26. The report is considered timely, because it was made within 10 days. The county is unable to decrease cash aid and CalFresh benefits for May to reflect discontinuance of the ineligible AU/household member, because there is insufficient time to provide 10-day notice. Benefits must be issued for May in the same amount that was issued in April, and the county must take action to decrease benefits effective June 1. The county must establish an OP for Mom s portion of the May grant; however, the county should not establish an OI for the May CalFresh allotment, because the recipient reported the change timely.

22 page 22 When recomputing benefits results in an OP/OI, the county must recreate case circumstances, including the determination of what income could be reasonably anticipated at that time (not based on actual income determined after the fact), using the correct county processing time frames based on what and when the recipient should have reported. In the semi-annual period designated as July through December, the county determines through an IEVS match (on October 15) that a household had income that exceeded their CalFresh IRT in the previous semi-annual period beginning on January 5. The household is still receiving the same level of income in the current SAR period but never reported the income mid-period or on their June SAR 7. The county determines that the household should have reported this change for CalFresh by January 15, and their CalFresh allotment should have been discontinued based on this increased income effective February 1. An OI would be established in CalFresh because the household was required to report this increase in income mid-period. If a county receives an IEVS match that shows a discrepancy between the actual and reported earnings of an AU/household, the county must determine if the AU/HH was mandated to report that income mid-period. An OP/OI would only be assessed if the income was over the IRT and the AU failed to make the mandatory report of income over the IRT within 10 days of receipt. Any mid-period income discrepancies will not result in an OP/OI unless the AU failed to meet their mandatory reporting requirements under SAR rules. Changes Not Required to be reported Changes reported voluntarily should not be considered when determining OPs/OIs. Unverified voluntary mid-period changes need only be reported on the SAR 7 or RD/RC forms that follows the change. A mother and child are aided as an AU/household of two based on absent parent deprivation (for CalWORKs) and are assigned to the January through June semi-annual period. On the RD/RC forms due in June, Mom correctly reports that no one had moved in or out of the home since the last SAR 7 was submitted. In July, Dad moves into the home and is full-time employed. Mom correctly reports that Dad moved into the home on the SAR 7 due in the following

23 page 23 December. Based on the SAR 7 submitted in December, the county determines no deprivation exists and discontinues CalWORKs effective the end of December. The county does not establish an OP for any months of the July through December period because the recipient was not required to report the addition to the home until the SAR 7 submitted in December. Deprivation was established based on the RD/RC forms due in June for the July through December period. Dad moving in had no effect on the eligibility for the July through December semi-annual period because eligibility for that period was correctly established based on the June RD/RC forms. Mom was not required to report the addition to the home until the following SAR 7 due in December. There would be no OI in CalFresh, since Dad moving in was not a mandatory mid-period report. His income would not be counted until the January through June payment period, following the mandatory report of Dad in the home. Implementation SAR is being implemented effective August 10, 2013 in Santa Clara County. Intake EWs are to use QR rules to set up CalFresh benefits for month(s) prior to August 10, After August 10, cases that are subject to SAR must use SAR rules. Continuing The EW is to use the information reported on the household s last QR 7 to reasonably anticipate income to determine benefits for the initial semi-annual reporting period. EWs are to apply SAR rules and budgeting after August using the July QR7 report received in August. AR/CO Cases Annual Reporting/Child Only (AR/CO) cases, which are currently Change Reporting cases for the CalFresh program, will transition to SAR effective October 1, Documentation Under SAR, documentation is ESSENTIAL. Documentation for SAR is required for, but is not limited to, the following information: How reasonably anticipated income was determined such as: Income the recipient states he/she expects to receive in future months,