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State of Wisconsin |
HISTORY |
The policy on this page is from a previous version of the handbook.
1.2.2.4 Discrepancies in Verification
7 CFR 273.2(f)(4)
Local agencies must use documentary evidence as the primary source of verification for all information except Wisconsin residence (1.2.3.5) and household composition (1.2.3.7).
Although documentary evidence must be the primary source of verification, acceptable verification must not be limited to any single type of document and may be obtained from the applicant/member or other source. Whenever documentary evidence cannot be obtained or is insufficient to make a firm determination of eligibility or benefit level, the IM worker may require collateral contacts or home visits. See 1.2.6 for the Suggested Verification Sources Chart for more details.
7 CFR 273.2(f)(4)(i)
Documentary evidence consists of written confirmation of a household's circumstances. Examples of documentary evidence include wage stubs, rent receipts, and utility bills.
Applicants may provide documentary evidence to verify information in person, through the mail, by fax, or other electronic device, or through an authorized representative. Applicants must not be required to present verification in person at the local agency. The local agency must accept any reasonable documentary evidence provided and must be primarily concerned with how adequately the verification proves the statements in the application.
7 CFR 273.2(f)(4)(ii)
Collateral contacts consist of oral confirmations of circumstances by persons other than food unit members. A collateral contact may be made either in person or over the telephone.
Note: Authorized representatives completing an application or renewal cannot serve as collateral contacts.
The local agency, generally, must rely on the applicant/member to provide the name of any collateral contact. The applicant/member may request assistance in designating a collateral contact. The local agency is not required to use the collateral contact designated by the applicant/member if the collateral contact cannot be expected to provide accurate third-party verification.
When the collateral contact designated by the applicant/member is unacceptable, the local agency must designate another collateral contact, ask the applicant/member to designate another collateral contact, provide an alternative form of verification, or substitute a home visit. The local agency is responsible for obtaining verification from designated collateral contacts.
When talking with collateral contacts, local agency staff should disclose only the information that is absolutely necessary to get the sought-after information. IM workers should avoid disclosing that an individual has applied for FoodShare, disclosing any information supplied by the applicant/member, or suggesting that the applicant/member is suspected of any wrongdoing.
Clearly document the collateral contact information.
7 CFR 273.2(f)(4)(iii)
Home visits may be used as verification only when documentary evidence cannot be obtained or is insufficient to make a firm determination of eligibility or benefit level. Home visits must be scheduled in advance with the applicant/member. Home visits are to be used on a case-by-case basis where documentation is insufficient. An error-prone profile does not constitute a lack of verification warranting a home visit.
7 CFR 273.2(f)(4)(iv)
When unverified information is received by the local agency from an external source, the applicant/member must be given a reasonable opportunity to resolve the discrepancy prior to a determination of eligibility or benefits. If the unverified information is received through an Income Eligibility Verification System (IEVS) data exchange regarding unreported sources of income or assets, the local agency may contact the source directly for verification.
When verification is received or if the applicant/member fails to provide requested verification, the local agency must issue a notice notifying the applicant/member of the action that has been taken and provide the applicant/member with an opportunity to request a fair hearing prior to an adverse action.
Document clearly in case comments the reason for verification requests due to questionable information or discrepancies.
7 CFR 273.12(c)(3)
The agency may receive unclear information about changes in an applicant’s or food unit member's circumstances from which the agency cannot readily determine the effect of the change on the food unit's FoodShare case. The agency may receive unclear information from a third party or from the food unit itself. If there is not enough information reported to request specific verification, issue a request for contact notice to the applicant/member.
The agency may also receive information from CWW that the case meets an automated Error Prone Profile (EPP) that the IM worker needs to resolve. In this case, a request for contact notice may also be appropriate.
The request for contact notice advises the applicant/member of unclear information that has been reported and the need to contact the agency within 10 days. If there are other items that need to be verified, the notice will list those specific items. The notice will also state the consequences if the applicant/member fails to respond. The applicant/member has 10 days to respond either by telephone or by other correspondence to clarify its circumstances. The burden of clarifying an issue is placed on the applicant/member. If the applicant/member does not respond to the request for contact, the agency must issue a notice of denial or termination for loss of contact and close the FoodShare assistance group or deny the FoodShare application. If the applicant/member does respond but refuses to provide sufficient information to clarify its circumstances, the agency must also issue an appropriate notice to close the FoodShare assistance group or deny the FoodShare application.
Note: IM workers should add a case comment stating the reason for loss of contact
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Example 1: A notice of decision was sent to Mike at adverse action. The notice was returned to the agency by the Post Office as “undeliverable” with no forwarding address. The IM worker should enter a “?” on the “Loss of Contact “ field and request verification of Mike’s Wisconsin residency. If Mike does not contact the agency within 10 days, the IM worker should enter the “Y” on “Loss of Contact” and close the FoodShare assistance group. |
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Example 2: Mary’s neighbor reports to the IM agency that a man has moved in with Mary and her children. The neighbor doesn’t know the man’s name or if he is related to Mary or her children. The IM worker should enter a “?” in the Loss of Contact field and send the verification checklist requesting contact. If Mary does not contact the IM agency within 10 days, a “Y” should be entered and the FoodShare assistance group closed due to loss of contact. |
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Example 3: Lydia’s landlord reports that he believes either Lydia or her husband is working but doesn’t know where. The IM worker doesn’t know if Lydia or her husband is the one working or what the source of income is. The IM worker should enter the “?” on the “Loss of Contact “ field and send the verification checklist requesting contact. If Lydia does not contact the agency within 10 days, a “Y” should be entered and the FoodShare assistance group closed due to loss of contact.
If the landlord had reported that Lydia was now working at ABC Corporation, the IM worker would enter the appropriate information on the employment page and use the “?” on that page to pend the FoodShare assistance group and request verification. |
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Example 4: During a renewal, an “expenses exceed income” EPP is produced. At the interview, the IM worker is expected to ask questions of the member’s circumstances. The member may have just lost a job and may be living off his or her savings. The member’s circumstance may also appear questionable and require further investigation. A referral to Front End Verification or a fraud investigation may be appropriate. |
7 CFR 273.2(f)(6)
Case files must include documentation to support eligibility, ineligibility, and benefit level determinations. Documentation must be in sufficient detail to permit a reviewer to determine the reasonableness and accuracy of the determination.
This page last updated in Release Number: 16-01
Release Date: 05/31/2016
Effective Date: 05/31/2016
Notice: The content within this manual is the sole responsibility of the State of Wisconsin's Department of Health Services (DHS). This site will link to sites outside of DHS where appropriate. DHS is in no way responsible for the content of sites outside of DHS.
Publication Number: P-16001