UPSTATE AND NYC MESSAGE   

DSS-4357EL                                                                 
WGIUPD                  GENERAL INFORMATION SYSTEM               		04/02/01  
                   DIVISION:  Temporary Assistance
 
GIS 01 TA/DC010                                                           

TO:		Commissioners; IM Directors; FS Directors; Staff Development       
     		Coordinators                                                         
FROM:  	Patricia A. Stevens, Deputy Commissioner                          
       		Division of Temporary Assistance                                  
SUBJECT:  Adoption of a New Six-Month Reporting Policy for Food Stamp    
          		Cases with Earned Income                                        
                                                                           
EFFECTIVE DATE:  See Dates in Text Below        
CONTACT PERSON:  Dale Van Buren @ 1-800-343-8859, extension 4-9327 

	This is to inform social services districts that the New York State Office of Temporary and Disability Assistance (OTDA) has chosen a newly available Federal option for food stamp recipients to report changes concerning their household.  This new option limits the reporting requirements during the certification period for households with earned income that are assigned six-month or longer certification periods.  Specifically, these households are only required to report increases in their gross monthly income resulting in the household exceeding 130 percent of the monthly poverty income guideline for their household size during the six-month period.

	The OTDA decided to take this option after considering the increasely high level of earned income errors that exist under the current quarterly reporting system.  If this situation continued unabated, during the current federal fiscal year (FFY) the attributed error rate could result in a substantial administrative disallowance.

	In New York State earned income cases are currently on a quarterly reporting system for food stamps and have a six-month certification period.  The new six-month reporting policy is authorized by 7 CFR 273.12(a)(1)(vii).  The food stamp quarterly reporting system will be obsolete by July 1, 2001.

	For cases with earned income, districts must not act on changes that would result in a decrease in food stamp benefits unless:

1.	The household has voluntarily requested that its case be closed in writing or in the presence of an eligible worker; or
2.	The district has information about the household's circumstances considered verified upon receipt; or
3.	There has been a change in the household's TA grant.

TA/FS Cases Effective April 1, 2001:

	While Temporary Assistance reporting rules already require reporting any income changes as they occur, we are implementing six-month reporting rules for food stamps for this population effective April 1, 2001.  This means that the current TA reporting rules for reporting changes within ten days and reporting on a quarterly basis as well, will continue for TA cases.  However, should a TA/FS household fail to report a change as required by TA rules, and delays reporting that change until the next recertification, that change would not be considered an overpayment of food stamp benefits.  Consequently, income changes or all other changes (excluding ABAWD requirements) experienced during the certification period that result in the household remaining under 130% of the poverty level are not subject to FS quality control errors.

	The case circumstances as verified by the district at the most recent certification interview are sufficient for continuing recurring benefits.  However, the household may voluntarily report changes that occur during the certification period.  Or, the household may report changes to meet TA reporting requirements.  In those instances, the TA worker would act on the reported change to adjust the TA grant.  The TA/FS worker must consider these changes that are reported and take appropriate action to adjust benefits if the change is verified upon receipt and it results in a decrease or an increase in food stamp benefits.

	If any TA case is discontinued for failure to comply with TA quarterly reporting rules, the food stamp portion of the case must be continued for the original length of the certification period (unless they become ineligible for other reasons).  Food Stamp certification periods may not be shortened for failure to comply with the TA quarterly report requirement.

Non Temporary Assistance Case

	The new six-month reporting policy for Non-Temporary Assistance (NTA) Cases will be implemented July 1, 2001.  A mass conversion letter will be sent in June and further information regarding this conversion will be made available in a future INF.  The last quarterly report generated for NTA/FS cases will be sent at the end of May and must be processed in June.

Prospective Budgeting of the income remains the same:

	At recertification, the worker will use the same four most recent weeks (before the interview date) of income to prospectively calculate the benefits.  FSSB XIII-A-6 through A-9 outlines the "best estimate process" in PROJECTING AVERAGE MONTHLY EARNINGS.  Examples of significant changes are shown in this FSSB Section and still apply.

District Requirements to Close Cases:  The district must close a six-month reporting case with adequate notice when the household:

•	reports in writing, or reports in person to an eligibility worker, an income that exceeds 130% of the monthly income guidelines for their household size or the household requests, in writing or in-person, that the case be closed; or
•	is on a certification period greater than six-months (due to the transition to the six month reporting system or is a Monroe Co. case) and they fail to verify income at the end of the 6th month; or
•	no longer resides in the state, or all household members are dead.

TA Implications

	There is no change in TA policy for quarterly reporting at this time.  The policy outlined in 93 ADM-9 continues to remain in effect for TA cases that are subject to quarterly reporting.  This office is currently whether changes will be made in the future for TA cases that are subject to quarterly reporting and will advise districts at that time.

Abled Bodied Adults Without Dependents (ABAWD) Participating:

	While ABAWDs are able to participate in six-month reporting, they must report to the district when their work hours fall below 80 per month.

Additional Reporting Rule Change Adopted to raise the $100 reporting threshold for unearned income effective April 1, 2001:

	For food stamp households subject to change reporting (within ten days for the those households with only unearned income outside of the new six-month reporting rules), the required threshold to report income changes is increased from $25 to $100.  This change is effective for all food stamp cases on April 1, 2001.  This change is consistent with the $100 earned income waiver made effective in April 2000.