State of Wisconsin Department of Health Services

Release 24-02 August 22, 2024

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6.1.3 Timely Action on Reported Changes During the Certification Period

Changes can be reported timely or untimely. Agency workers must act promptly on all reported changes. If verification is requested, a minimum of 20 days must be allowed for the member to provide the verification.

6.1.3.1 Processing Reported Changes

7 CFR 273.12(c)(1) waiver

Following the report of a change, request verification from the member as soon as possible (see Section 1.2.1 Verification Introduction). To prevent “failure to act” agency QCQuality Control errors, agency workers must act on reported changes within 10 days. As a best practice a worker should process the change as soon as possible and not wait until the 10th day.  

Example 1

On June 19, Barry reported having a new job that started on June 9. The IM worker must request verification and allow Barry 20 days to provide it. If verification is requested on June 19, it will be due July 9. The IM worker will have time to process the verification and issue proper notice to Barry by adverse action in July. If the IM worker fails to act on the change by not requesting verification until June 30, Barry would have until July 20 to provide the verification, which is after adverse action. In this case, it is possible that August benefits would be in error due to IM worker failure to act promptly on the reported change.

Lack of verification is a common cause of case closure. A new application for FoodShare is not always required under specific circumstances when FoodShare closes due to lack of verification during the certification period. Allow FoodShare to reopen without a new application when closing for lack of verification after a change is reported or discovered during the certification period, as long as the requested verification is submitted in the calendar month following case closure. Benefits are prorated from the date the required action was taken.

Example 2

Julie is certified for FoodShare from March through February. Julie calls and reports a new job on April 5. Julie’s IM agency requests verification of Julie’s employment, due April 25. Julie fails to provide verification by the due date and FoodShare closes effective May 30. Julie provides the required verification on June 8. Julie’s FoodShare case reopens without requiring a new FoodShare application and prorates benefits from June 8 forward. Julie’s certification period remains the same March through February.

FoodShare may also close for reasons other than lack of verification. Allow FoodShare to reopen when a change in circumstances causes the FoodShare assistance group to regain eligibility during the month following the month of case closure, as long as the food unit takes the required action.

FoodShare members may choose to reapply for benefits in the month following closure even when not required. Completing a new application establishes a new filing date, allowing the member up to 30 days to provide needed verification. IM workers should explain the difference between completing a new application and providing needed information to members when possible.

Example 3

Pam’s FoodShare closes effective September 30 due to a pay increase at her job. Pam contacts the IM agency on October 8 to reapply for FoodShare. Pam reports a decrease in income due to a reduction in work hours. The IM agency informs Pam of the option to reapply for FoodShare or to provide verification reflective of the current circumstances to reopen FoodShare effective the date the verification is provided, as long as Pam meets program criteria. Pam chooses to provide verification and submits it on October 12. Pam’s FoodShare reopens with prorated benefits from October 12 forward.

 

Example 4

Joan’s FoodShare closes effective October 31 as a result of a newly added roommate’s earned income. Joan contacts the IM agency on November 19 because the roommate moved out and Joan wants to reapply for FoodShare. The IM agency provides Joan the option of reapplying for FoodShare or reopening her FoodShare effective November 19. Joan chooses to reopen FoodShare without a new application. The IM agency removes the roommate from the case and re-determines a prospective estimate of Joan’s income and expenses. FoodShare benefits are issued from November 19 forward.

6.1.3.2 Changes “Verified on Receipt”

7 CFR 273.2(f)(9)

Some examples of changes considered to be "verified on receipt" are:

1. Data exchange (see Process Help, Section 44.1 Data Exchange General Information) information that does not require further contact with the member (Social Security, Wisconsin Child Support Enforcement (KIDS; only child support income and expenses are verified), and Unemployment),
2. Changes reported by a member that do not require further verification, and
3. Changes for which adequate verification has already been submitted.

6.1.3.3 Changes That Cause an Increase in Benefits, Including Person Adds and Loss of Income

7 CFRCode of Federal Regulations 273.12(c)(1)

FNS Memo 12/18/14

All reported changes that cause an increase in the FoodShare benefit including person additions, increases in expenses, etc., will be effective the first of the month following the report month if required verifications are received within 20 days of the request for verification.

If needed verifications are not received within 20 days, and the FoodShare case is not closed for at least one day, make the change effective the first of the month following the month verifications are received.

Issue the appropriate supplement by the 10th day of the month the increase in benefits is effective.

Note

A person can be a member of more than one food unit but only one assistance group in the same month except residents of shelters for victims of domestic violence (see Section 3.4.1 Dual Membership and Duplicate Benefits). Prior to adding a person from one FoodShare case to another, remove the person from the previous FoodShare case.

 

Example 5

If Mike (a baby) is born June 25, and the change is reported June 27, FoodShare benefits increase effective July 1. Since the case was reported after adverse action, a FoodShare supplement is issued for July. If Mike (a baby) is born June 25, and the change is reported July 1, FoodShare benefits will increase effective August 1. No FoodShare supplement is issued.

 

Example 6

Jule has an open FoodShare case with a certification period of February through January. Jule reports on March 25 that Eve, Jule's sister, moved in on March 15 and they purchase and prepare together. Jule’s IM worker requests verification of Eve’s eligibility information by April 14. Verification is not provided by April 4 and the FoodShare case closes effective April 30. Eve provides verification to the local agency on May 15. FoodShare reopened without a new application. Eve is added to the assistance group and benefits are redetermined and prorated for the month of May. In June, Jule and Eve will receive a full month of benefits. Jule’s FoodShare certification period remains the same, February through January.

 

Example 7

Lisa reports on March 5 that her husband left the home on February 27. Lisa's husband was working, and this change results in Lisa being eligible for more FoodShare benefits. The IM worker re-determines the prospective estimate of Lisa’s income for the next benefit month, April, and confirms benefits. Since the change was processed March 5, before adverse action, no supplement is needed.

 

Example 8

Carol reports on March 25 that rent is increasing by $500 for April. The IM worker finds the expense questionable, as Carol's current rent expense is $300 and the rent increase more than doubles the total rent expense. The case is pended on March 25 and verification is due April 15. Carol provided the verification on April 3. On April 5, the IM worker makes the change to increase Carol’s FoodShare benefit effective April 1 and issues a supplement for April. If Carol had reported the rent increase on April 2, or provided the verification after April 15, the FoodShare benefit increase would have been effective May 1.

6.1.3.4 Sanction Request

An IM worker should act on a sanction request immediately but has 10 days to process the request. However, the IM worker should try to enter the sanction before the next adverse action (see Section 6.3.1 Negative Notices) in CARESClient Assistance for Reemployment and Economic Support.

Example 9

The IM worker receives a sanction request for Jayne on June 12. The IM worker officially has 10 days to process the sanction. Adverse action is on June 18, the worker makes sure to act on the sanction before the 18th. However, if they do not, the case would not be in error unless the worker did not act on the sanction until after adverse action in July.

6.1.3.5 Person Add Following a Sanction (Re-request)

If an individual is requesting to be added to the FoodShare assistance group following:

• A disqualification for an IPVIntentional Program Violation,
• Failure to comply with other FoodShare program requirements, or
• Was an ineligible immigrant.

Eligibility for the previously excluded person will be effective the first of the month following the period of disqualification, or the first of the month following their request to be added back to the FoodShare assistance group, whichever is later.

Example 10

Margaret’s husband David is sanctioned from September 1 through August 31 due to an IPV. Margaret calls on August 25 and requests that David be added back to the FoodShare assistance group on September 1. Verification is complete. The IM worker adds David to the group effective September 1. If Margaret’s request for David to be added back to the group was made on or after September 1, he would be added to the group effective the first of the month following the request.

6.1.3.6 Changes That Cause a Decrease in Benefits

7 CFR 273.12(c)(2)(i)

For reported changes that result in a decrease in benefits, process the change to allow for adequate negative notice to be issued to the member. If verifications are not received within 20 days, and the FoodShare case is not closed for at least one day, make the change effective the first of the month following the month verifications are received.

Example 11

Lisa reports on June 3 that her husband moved back into the home on May 29. On June 3, Lisa’s IM worker adds Roy to the FoodShare case and requests verification of his income due June 23. Roy’s income will cause a decrease in FoodShare benefits. Lisa provides Roy’s verification on June 10. Notice of a decrease in benefits is issued at adverse action in June and benefits are decreased for July. If verification was not provided by the due date, the IM agency would take action to close the FoodShare case for lack of verification. Since the due date and agency action to close the case occurs after adverse action in June. FoodShare benefits would close July 31 for failure to verify income.

6.1.3.7 Change Impact Matrix

Use the Change Impact Matrix to determine how to respond to changes reported by food units.

Food Unit Type	Initial Certification Period	Initial SMRF Requirement	Change Reported	Date Change Acted On	Impact on Certification Period	SMRF Requirement after Change
Regular	12 months	Yes	Homelessness or Migrant in household	At any time during the certification period	No effect on the original certification period of 12 months	Yes
Homeless or Migrant	6 months	No	Reports securing housing or no longer migrant	Prior to adverse action in the fourth month	Certification period remains six months	No
				After adverse action in the fourth month	Certification period remains six months	No
EBDElderly, Blind, or Disabled household with earnings	12 months	Yes	Source of earnings ends	At any time	No effect	No
EBD without earnings	12 months	No	New source of earnings	Prior to adverse action in the fourth month	No effect	Yes
				After adverse action in the fourth month		No
TFS	5 months	No	Change in income, household comp, or other types of change	At any time	No effect	No
			Death of PP or when PP moves out of Wisconsin		TFS closes and member must re-apply	N/A

6.1.3.8 Processing ABAWD Changes

When an exemption is reported (and verified if deemed questionable), workers must apply the exemption on the first of the month in which the exemption began, regardless of when the exemption is reported.

The FoodShare Clock Page may need to be adjusted once an exemption is applied to the case (see SECTION 3.17.1.13 ADJUSTING FOODSHARE CLOCK PAGE).

6.1.3.9 Oral Explanation of Applicable Work Requirements

7 CFR § 273.7(c)(1)(ii) and (iii)

An oral explanation of work requirements must be provided when a FoodShare member(s) is newly determined subject to the FoodShare basic work rules (see Section 3.16.1 FoodShare Basic Work Rules and the FoodShare work requirement (see Section 3.17.1 FoodShare Work Requirements for ABAWDs) during the certification period. This can occur when a current and previously exempt FoodShare member(s) has a change in circumstances and is no longer exempt, or when a new household member is added and is subject to the basic work rules and work requirement. 

If the change is acted upon while the member is on the phone or in person at the agency, the oral explanation must be provided at that time. If the member is not immediately available, at least one contact attempt must be made to provide the oral explanation. The attempt to contact the member must be documented in case comments.

The following information must be provided to member(s) who are subject to the FoodShare basic work rules and FoodShare work requirement: 

• An explanation of each work rule and applicable work requirement.
• Information on exemptions from each applicable work rule and work requirement.
• An explanation of the process to report an exemption, including contact information to request an exemption.
• What is required to maintain eligibility under each work rule and applicable work requirement.
• Consequences for failure to comply with each work rule and applicable work requirement.
• An explanation of the process for requesting good cause, including examples of good cause circumstances and contact information to initiate a good cause request.
• Information on the FoodShare Employment and Training Program (FSET) and benefits of FSET participation if the food unit includes an individual subject to the FoodShare work requirement.
• Information on the status of the time limit of the FoodShare work requirement if the household lives in an area or on tribal lands where the time limit of the FoodShare work requirement is suspended

The appropriate sections of the "FoodShare Basic Work Rules and FoodShare Work Requirements Script for IM Workers" must be read to meet the above requirements. 

Example 12

Vanessa is a 40-year-old receiving FoodShare benefits. At application, Vanessa was receiving unemployment compensation and determined exempt from the FoodShare basic work rules and FoodShare work requirement. A few months later, Vanessa called the local IM agency and reported no longer receiving unemployment compensation. Vanessa had no other changes and no longer has a qualifying exemption from either work requirement. The appropriate sections of the oral explanation of work requirements for the FoodShare Basic Work Rules and FoodShare Work Requirements Script must be read to Vanessa while she is on the phone.

Example 13

Zac is 35 years old. Zac applied and was determined eligible for FoodShare benefits for himself and his 12-year-old son, Corbin. Zac is determined subject to FoodShare basic work rules. He is not subject to the FoodShare work requirement due to residing with a minor child. A few months later Zac reports Corbin is no longer living in his household via an online change report. Zac is now also subject to the FoodShare work requirement. An attempt to contact Zac by phone is made to provide the oral explanation of work requirements due to Zac becoming subject to a new work requirement. Zac does not answer the call. The attempt must be documented in the case record.

 

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Publication Number: P-16001