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State of Wisconsin Release 09-02 June 26, 2009 |
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State of Wisconsin Release 09-02 June 26, 2009 |
1.2.2.4 Discrepancies in Verification
7 CFR Code of Federal Regulations 273.2(f)(4)
Local agencies must use documentary evidence as the primary source of verification for all information except residence and household composition.
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 or other source. Whenever documentary evidence cannot be obtained or is insufficient to make a firm determination of eligibility or benefit level, the ESS Economic Support Specialist may require collateral contacts or home visits. See the Suggested Verification Sources chart (1.2.6) 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 facsimile (FAX) or other electronic device, or though an authorized representative. Applicants must not be required to present verification in person at the FoodShare office. 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.
The local agency, generally, must rely on the applicant to provide the name of any collateral contact. The applicant may request assistance in designating a collateral contact. The local agency is not required to use the collateral contact designated by the applicant if the collateral contact cannot be expected to provide accurate third-party verification.
When the collateral contact designated by the applicant is unacceptable, the local agency must either designate another collateral contact, ask the applicant to designate another collateral contact or to 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 information being sought. ESS should avoid disclosing that an individual has applied for FS FoodShare , nor should they disclose any information supplied by the applicant or suggest that the applicant 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 is insufficient to make a firm determination of eligibility or benefit level, or cannot be obtained. Home visits must be scheduled in advance with the applicant. Home visits are to be used on a case-by-case basis where documentation is insufficient. Simply because a household fits an error-prone profile does not constitute a lack of verification.
7 CFR 273.2(f)(4)(iv)
When unverified information is received by the local agency from a source other than the food unit, the applicant 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 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 household fails to provide requested verification, the local agency must issue a notice notifying the applicant of the action that has been taken and providing the applicant 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 a food unit's circumstances from which the agency cannot readily determine the effect of the change on the food unit's case. The agency may receive such 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 food unit.
The request for contact notice advises the food unit that there has been unclear information 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 they fail to respond. The food unit 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 food unit. If the food unit does not respond to the request for contact, the agency must issue a notice of closure for loss of contact and close the FoodShare case. If the food unit does respond but refuses to provide sufficient information to clarify its circumstances, the agency must also issue an appropriate notice to close the FoodShare case.
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Example 1: If a FoodShare participant tells you they moved but you haven't received the requested verification, use the appropriate address VR fields. |
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Example 2: 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 worker should enter a “?” on the “Loss of Contact “ field and request verification of Mike’s new address. If Mike does not contact the agency within 10 days, the worker should enter the “Y” on “Loss of Contact” and close the FoodShare case. |
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Example 3: Mary’s neighbor reports to the 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 worker should enter a “?” in the Loss of Contact field and send the verification checklist requesting contact. If Mary does not contact the agency within 10 days, a “Y” should be entered and the FoodShare case closed due to loss of contact. |
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Example 4: Lydia’s landlord reports he believes either Lydia or her husband is working but doesn’t know where. The worker doesn’t know if Lydia or her husband is the one working or what the source of income is. The 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 case closed due to loss of contact.
If the landlord had reported that Lydia was now working at ABC Corporation, the worker would enter the appropriate information on Employment Page and use the “?” s on that screen to pend the case and request verification. |
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: 08-05
Release Date: 12/15/08
Effective Date: 12/15/08