State of Wisconsin
Department of Health Services

Release 24-03
December 18, 2024

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2.2.1 Certification Periods (Renewals)

7 CFR 273.14(a); 7 CFR 273.10(f)

The certification period for FoodShare eligibility for most food units is 12 months. Food units where all members are homeless and food units that include a migrant or seasonal farm worker have a six-month certification period. Food units where all adult members are EBD and have no earned income may have a 36-month certification period.

The food unit must answer questions about their current household information in the last month of the certification period to be recertified and continue receiving FoodShare benefits. This is called a renewal. The food unit may need to verify some of the current household information they provide. At renewal, most food units must complete an interview (see SECTION 2.1.3 INTERVIEWS).

Note When a food unit moves into a Transitional FoodShare (TFS) certification period, their regular certification period will end early. The TFS certification period will begin the following month and will end five months later (see Section 5.1.1 Transitional FoodShare Benefits (TFS)). The food unit must complete a renewal in the last month of the certification period to continue to receive regular FoodShare benefits.

FoodShare assistance groups with zero FoodShare benefits in their initial benefit month (pro-rated benefits) and a FoodShare allotment greater than zero in the second month, will be certified for six, 12, or 36 months (depending on their household composition) beginning with the application month. If FoodShare eligibility is denied in the month of application for any other reason, and eligibility begins the following month, the six, 12, or 36-month certification period begins in the month following the application month. If the benefit calculation is zero for the first two months, the case will be denied.

Example 1 Barry applied for FoodShare in August after he lost his job. In the FoodShare benefit determination for August and September, Barry received zero for August due to pro-rated benefits and $98 in September. His certification period starts in August.

 

Example 2 Barry's VQT sanction ends August 8. He reapplies and re-requests FoodShare on August 25. He is ineligible in August and eligible for $141 in September. Barry's 12-month certification period begins September 1.

 

Example 3 Barry applied for FoodShare November 29 after his unemployment compensation ended. Barry reports during the application that he is homeless. Barry received his full unemployment benefit in his final month, so he is not eligible for FoodShare in November because his income was over the gross income limit, but he is eligible in December. Barry’s six-month certification period begins December 1. 

2.2.1.1 Six Month Reviews

The certification period of the following food units is six months:

  1. Food units that include a migrant of seasonal farm worker, or

  2. Food units where all members are homeless (not including certain EBD no earnings food units).

Note

Once a six-month certification period has been established the renewal may remain due in month six even if the homeless food unit secures housing or the migrant worker leaves the food unit prior to the renewal month, depending on when the change is reported (see Section 6.1.3.7 Change Impact Matrix).

2.2.1.2 36-Month Certification Period

Certain EBD food units with no earned income can receive 36-month certification periods. These food units will not need to complete SMRFs and may not need to complete an interview at renewal.

Food units must meet the following criteria to receive a 36-month certification period:

Note If the food unit meets the criteria to receive a 6-month certification period (see Section 2.2.1.1 Six Month Reviews), they will not receive a 36 month certification period. 

Food units that can receive a 36-month certification period should receive expedited service, if eligible (see SECTION 2.1.4 EXPEDITED SERVICE AT APPLICATION).

All food units with 36-month certification periods are simplified reporters (see SECTION 6.1.1 CHANGE REPORTING FOR ALL FOOD UNITS (SIMPLIFIED)).

All food units that meet the criteria to have a 36-month certification period are sent annual outreach letters at months 11 and 23. This letter includes a case summary detailing current FoodShare information on their case. The food unit has no required action to take at that time, besides existing simplified reporting requirements. Updating current case information can ensure the assistance group is receiving the correct benefit amounts to which they are entitled.  

Example 1 Ethel has a 36-month certification period. In the 11th month of her certification period, she receives her annual outreach letter, including a summary of the current information on her case. Ethel reviews her case summary and notices she is not receiving a deduction for a new, ongoing prescription medication she started two months ago. Ethel has no required changes to report at this time. Even though it is not required, Ethel calls her agency to report her new medical expense. She provides verification of the expense. She provides verification of the expense. Her monthly FoodShare benefit increases due to the new medical expense deduction.   

Food units with 36-month certification periods cannot shorten their certification period. The renewal for a 36-month certification period will not continuously align with another program's renewal or application. No other program has 36-month certification periods.

If a food unit with a 36-month certification period becomes eligible for Transitional FoodShare (TFS), their certification period will be shortened in accordance with TFS policy (see SECTION 5.1.1 TRANSITIONAL FOODSHARE BENEFITS).

Interview

The first time a food unit receives a 36-month certification period at their initial application, they are required to complete an interview. At renewal, these food units may not be required to complete an interview. If there is pending verification or questionable information on the case at renewal, or if the food unit no longer meets the eligibility criteria to have a 36-month certification period, an interview is required. Food units will receive a letter with instructions on how to complete their required interview. If the required interview is not completed, the case will lose their FoodShare eligibility.

Food units can always request a renewal interview even if it is not required. The food unit is responsible for contacting their agency to complete an optional interview. No food unit will be determined ineligible for failing to complete an optional interview. An optional interview must be completed within the renewal month.

Never deny an application or renewal without first attempting to schedule an interview. 

Losing 36-Month Certification Period Eligibility

If a food unit stops meeting the eligibility criteria to have a 36-month certification period, their certification period will not be shortened. If the food unit is still eligible to receive FoodShare benefits, they will retain the remaining months in their 36-month certification period and their renewal date will not change. However, these food unit will need to complete SMRFs every six months until their next renewal and complete an interview at their next renewal. 

A food unit could stop meeting the 36-month certification period eligibility criteria but maintain eligibility for FoodShare benefits in the following ways:

Example 2 Ci and his 17-year-old son Alang apply for FoodShare together. Ci is disabled and does not have any earned income. Alang is not disabled and has a part time job. Even though Alang has earned income, the food unit receives a 36-month certification period because Alang is not an adult. Eight months into their certification period, Alang turns 18. The food unit no longer meets the 36-month certification period eligibility criteria because Alang is now a non-disabled adult with earned income. The food unit will be required to complete SMRFs at months 12, 18, 24, and 30 and will be required to complete an interview at their next renewal. If the food unit circumstances have not changed at their next renewal, the food unit will receive a 12-month certification period. 

When a food unit loses their eligibility criteria to have a 36-month certification period, they will be notified of the requirement to complete SMRFs and their next SMRFs due date, if applicable. These food units will not receive Annual Outreach letters since they are required to complete SMRFs. If the food unit stops meeting the eligibility criteria past month 30 in their certification period, they will not be required to complete SMRFs because their next required eligibility action is the renewal. 

Once a food unit loses their 36-month certification period eligibility criteria, they are required to complete SMRFs and complete an interview at renewal even if they regain 36-month certification period eligibility criteria.

Example 3 Jan, Darrel, and Theresa have a 36-month certification period. Jan and Darrel are elderly, Theresa has a disability, and no one in the food unit has earned income. Sixteen months into their certification period, Darrel reports his granddaughter Nataleigh moved in. Nataleigh is 19. Since she does not have a disability and is not elderly, the food unit no longer meets 36-month certification period eligibility criteria. The food unit is required to complete SMRFs at months 18, 24, and 30 and complete an interview at renewal. Seven months after losing eligibility criteria, month 23, Darrel reports Nataleigh moved out. While the food unit meets the 36-month certification period eligibility criteria at this time, they are still required to complete SMRFs at months 24 and 30 and complete an interview at renewal. If the food unit still meets the eligibility criteria at their next renewal, they will receive a 36-month certification period.

Food units that stop meeting the 36-month certification period eligibility criteria and are ineligible for FoodShare will stop receiving FoodShare benefits. 

Conversion

Existing FoodShare food units that meet the eligibility criteria at project implementation will have their certification periods extended between two and 24 months. These food units will receive a one-time conversion letter. The letter will tell them of the change to their certification period, their new renewal date, reporting requirements, and responsibilities. No food unit will receive a certification period longer than 36 months or shorter than 12 months. At their next renewal, if the food unit still meets eligibility criteria, they will receive a 36-month certification period. Post implementation, all applicants that meet eligibility criteria will receive a 36-month certification period.

2.2.1.3 Shortening a Certification Period

7 CFR 273.10(f)(4) Waiver approval

Agencies may not end a certification period earlier than the assigned termination date, unless the agency receives information that the food unit has become ineligible, or the food unit does not cooperate in clarifying its circumstances. Loss of W-2 or a change in employment is not sufficient in and of itself to meet the criteria necessary for shortening certification periods.

A certification period may be shortened only in the circumstances described below:

2.2.1.4 Completing a Renewal

 7 CFR 273.14(b)

There are several steps to completing a renewal for FoodShare cases:

  1. Notification must be sent to the food unit informing them that the certification period is ending and an interview (see Section 2.1.3 Interviews) must be conducted for most cases if benefits are to continue.
  2. If an interview must be conducted, the food unit will receive a letter.
  3. The food unit must be notified of verifications they need to provide to determine continued eligibility for the program. Certain information gathered at the interview must be verified (see Section 1.2.1 Verification Introduction).
  4. A new electronic, telephonic, or written signature must be collected.
  5. Benefit eligibility must be confirmed in CWWCARES Worker Web (see Section 2.1.7 Confirming the FoodShare Eligibility Determination in CARES) in order for the review or renewal to be considered complete.

2.2.1.5 Renewal Processing Time Frame

The 30-day processing time frame for a renewal is not the same as it is for applications. The 30-day renewal processing time frame refers to the renewal month. In other words, a renewal must be processed and confirmed by the last day of the renewal month, with two exceptions:

When there is an agency-caused delay, it must be documented in CWW the reason for the late renewal and set the FoodShare program request date for the first of the month so that benefits are not prorated.

The FoodShare case will close effective the last day of the renewal month at adverse action of the renewal month if renewal is not completed, including confirmation. The agency and the FoodShare food unit have until the end of the renewal month to complete the renewal.

FoodShare that closes at renewal may reopen without requiring a new application under specific conditions. Allow FoodShare to reopen at renewal if the action needed to resolve ineligibility is completed in the month following the end of the current certification period, as long as the interview was timely.

An interview must be completed within the renewal month of the current certification period to be considered timely. If the food unit fails to complete a timely interview, FoodShare will close effective the last day of the renewal month at adverse action and a new FoodShare application is required.

Example 4

Holly completes a timely FoodShare renewal, including the interview, on July 9 but does not have verification of her wages from Marigold’s. Verification of her earned income is requested. Holly fails to provide verification and her case closes effective July 31.

On August 5, Holly provides verification of her wages. She regains eligibility as of August 5 and is issued prorated benefits from August 5 through August 31. Holly’s FoodShare new certification period remains unchanged.

If Holly had responded timely to the request for verification and submitted her verification in July, but the verifications were not processed  until August, benefits would have been issued back to August 1 due to agency delay.

 

Example 5 Tom's FoodShare renewal is due by June 30. He completes his required interview on June 27 and has verification due July 17. Tom provides the requested verification on July 15. Although Tom's case closed effective June 30 due to lack of completed renew/verification, his FoodShare case is reopened with a certification period beginning July 1 because he completed the interview in the renewal month and provided the requested verification by the due date. Benefits are not prorated, and he is not required to submit a new application.

 

Example 6

Ruby calls her IM worker on August 21 to schedule an in-person FoodShare renewal due by August 31, but the only appointment available is not until September 4. Ruby completes her renewal on September 4 but does not have verification of her wages from Sunny’s Craft House. Verification of earned income is requested with a verification due date of September 24. Ruby submits the necessary verification on September 20. Because Ruby submitted her verification timely (within 20 days) and because the agency was unable to complete the interview in August, Kim issues benefits to Ruby back to September 1.

Had Ruby submitted the necessary verification after September 24, but before September 30, benefits would be prorated back to the date verification was submitted.

 

Example 7 Tricia’s FoodShare assistance group has a FoodShare certification period ending June 30. Tricia completed a telephone interview on June 17 and the case pends for a signature. The signature page is not returned and FoodShare close June 30. Tricia returns the signature page on July 14. FoodShare reopens without requiring a new FoodShare application. Benefits are prorated from July 14, with a new certification period from July 14 to June 30.

2.2.1.6 Eligibility Reviews for Other Programs and Their Impact on the FoodShare Certification Period

7 CFR 273.10(f)(4) Waiver approval

Renewals completed for other assistance programs do not automatically count as a renewal for FoodShare and will not change the FoodShare certification period. A FoodShare certification period may be changed to align with that of another program only if the member has stated their consent to  complete a FoodShare renewal in order to align its FoodShare certification period with the certification period of another program. Consent can be given in ACCESS when completing an ACCESS renewal or verbally when completing a telephone or paper renewal. A 36-month certification period will never align with another programs’ certification period. 

This page last updated in Release Number: 24-03
Release Date: 12/18/2024
Effective Date: 12/18/2024


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