MEMORANDUM
2004 Memorandums
IM-31      04/01/04
SUBJECT:
PENDING FOOD STAMP APPLICATIONS FOR SANCTIONED INDIVIDUALS
DISCUSSION:
The purpose of this memorandum is to discuss:
  • ending the direct job placement sanctions;
  • programming changes for pending applications of EUs containing a member who is sanctioned due to noncompliance with METP; and
  • ending sanction code RTT and WRC and redefining NFF.
These changes are effective April 5, 2004.

Ending Direct Job Placement Sanctions

At next contact or next application, review any sanction entered for an EU member.  If the sanction is for direct job placement (DJP), end the sanction for the EU member and complete an eligibility determination.  Do not allow a DJP sanction to continue.  Converted sanctions do not have all the required fields completed.  Review the case record and add the violation date and start date before attempting to end the sanction.  Do not delete the sanction unless it is determined the individual was sanctioned in error.  Refer to the Updating/Ending a Sanction or Disqualification user guide for instructions on ending the sanction.

Programming Changes for Pending Applications

Memorandum IM-#135, dated 10/14/2003, discusses policy regarding pending applications when an EU member is sanctioned due to noncompliance with METP.  Programming is changed so that an application pends if one or more EU members applying for food stamp benefits is sanctioned due to non-compliance with METP to allow the person to take the required action to end the sanction.  The application pends if an EU member has one of the following METP non compliance sanctions:

  • METP non compliance (MTP)--A MTP sanction is system set when non-compliance information is received on the daily file received from the DWD.
  • Voluntary job quit (VJQ)--A VJQ sanction is created by the worker when it is determined an EU member has voluntary quit a job and does not have good cause or does not meet another work registration exemption.
  • Work registration sanction (SWR)--A SWR sanction is created by the worker when an EU member refuses to be registered for work.
  • Work effort reduction (WER) sanction--A WER sanction is created by the worker when it is determined an EU member voluntarily and without good cause reduced the number of hours of work per week to less than 30 hours per week.
NOTE: When the sanction is a DJP sanction, end the sanction and do not allow the application to pend.

Pending the application allows the EU member(s) to comply with the work registration requirement by completing the activity required to end the sanction.  It is no longer necessary to leave the application in the controlled flow to allow the sanctioned individual to comply.

When the sanctioned EU member complies, take the following action:

  • Type FMAM on the command line and press enter.  The Sanction/Disqualification screen appears.
  • Enter the EU member’s DCN and press enter again.
  • Type a “U” in the C field in front of the sanction to be ended.
  • Tab to the compliance date field and enter the date the EU member complied.  Press enter.  (The system enters the end date.)
  • The message “successfully updated” appears.  Refer to the Updating/Ending a Sanction or Disqualification user guide for more information.
  • Complete an eligibility determination resolution (EDRES).
Pending the Application

The pending action to end the disqualification is treated as outstanding verification and pends the application.  The Outstanding Verification (FM3M) screen shows "COMPLIANCE" in the description field, and "with DWD" along with the name of the sanctioned EU member in the source field.  To generate the FA-325 Request for Information form:

  • Press F23=FA325.
  • Press F9=FLOWFWD to flow to the Document Queue (FMVM) screen.  The FA-325 form is editable and ready to print.
  • Enter an “s” in the com field to select the FA-325 and press F17=EDITDOC to edit the form.  The Select Field Edit (FMVT) screen appears.
  • Type "s" in the sel field on the FA325_TXT_FLD_ line.  The Field Edit (FMVX) screen appears.
  • Type "U" on the command line.  Type text on the line on the Field Edit screen indicating how the EU member can end the sanction.  Press enter and then press F21=RETURN.  If you wish to add a second line of text, select the next FA325_TXT_FLD_ line and repeat the above process.
  • When all the desired text has been entered, press F21=RETURN to return to the Document Queue (FMVM) screen.
  • Type "p" on the Com line and press F23=PRINT to print the form.
Instructions for editing the FA325 can also be found in the Editing and Adding Text user guide.

The FA325 will show "compliance" in the proof of field and the following messages in the source field based on the type of sanction:

  • MTP--with DWD and the sanctioned individual’s name,
  • VJQ--working 30 hrs or more per wk and the sanctioned individual’s name,
  • SWR--with DWD and the sanctioned individual’s name, and
  • WER--working 30 hrs or more per wk and the sanctioned individual’s name.
Please note that not all METP sanctioned individuals can comply by going to DWD.  For example, an individual who refused to register for work and has a SWR sanction must be referred to DWD to be considered registered for work to end the sanction.  Consider the person registered when they agree to be referred to DWD.  End the sanction as outlined above and change the individual’s status from MNC to MAN and the Good Cause code from N to Y on the Employment Assessment (FMMS) screen.  Refer to specific policy for each type of sanction.

The application cannot be authorized until the sanction is ended and any other verification is provided or the application has pended

  • for 30 days, if an initial or non-timely application, or
  • until the end of the current certification, if the application is a timely reapplication.
When the sanctioned individual states s/he is not going to cooperate, the application pends until the timeframe listed above has passed.

If the sanction can be ended by going to DWD, send the EU member with an IM-311 Referral and Transmittal form to DWD to comply.  Indicate on the IM-311 that the member has applied for food stamps and must comply with DWD to end a sanction.  Also include the county office FAX number on the IM-311 so the DWD office can FAX the form back to the worker.

Once the EU member complies, DWD staff will note on the bottom of the IM-311 the individual has complied and FAX the form back to the worker.

The following actions may occur, depending on the EU’s circumstances.  Each action is described in the sections that follow.

EU Member Complies

End the sanction for the sanctioned EU member/s as outlined above.  If this is the member’s first sanction or it has been more than 3 months for the second sanction or more than 6 months for a third or any subsequent sanction, the EU member will be eligible to receive food stamp benefits back to the date of application, if otherwise eligible.

If the EU member complies during the first month of application, go to FMAM and enter the compliance date.  Refer to the Updating/Ending a Sanction or Disqualification user guide for instructions.  FAMIS sees that individual as being sanctioned through the end of the month in which they comply and determines them eligible for the following month, if they meet all other eligibility criteria.  Authorize the action.  Go to Select Worker Initiated Budget Calculation Area WIBCA (FMXH) and complete a budget to issue benefits for the month of application.  Refer to the WIBCA user guide for instructions.  Use the date of application as the prorate date to ensure correct benefits are issued.  Record the reason for completing the WIBCA on the Comments screen.  If the application pends into a second month and the EU member does not comply until the second month, complete a second WIBCA for the second month, if the EU is otherwise eligible, to issue benefits for the second month.  If the WIBCA is completed the same day as the reject and approval actions are authorized, the supervisor must authorize the payment for the first and second month.

If this is the member’s second or third sanction and the minimum sanction period has not yet been served, the EU member will continue to be sanctioned until the minimum time period is over.

A new sanction may be entered while in the controlled flow because an applying EU member does not wish to register for work, voluntarily quit a job, or voluntarily reduced the number of hours worked.  The new sanction will cause the application to pend for compliance.  For example, an EU member reports at the time of application a voluntary job quit or work effort reduction.  If the sanctioned individual goes to work or increases the number of hours worked prior to the 30th day, delete the sanction rather than ending it.  Go to the Job Quit/Work Reduction (FMMT) screen and select the question with the "Y" answer.  Press F6=DETAIL.  On the detail screen type U on the command line, tab to the (Y/N) field and change the Y to an N.  If the individual had good cause, leave the Y in the (Y/N) field, tab to the Good Cause field and type or prompt for the appropriate good cause code.  Complete an eligibility determination (EDRES).

When a sanctioned individual included on an active case complies, the individual becomes eligible for benefits the month following the month in which the individual complied.  Go to the Sanction/Disqualification (FMAM) screen and enter the compliance date.  Complete an eligibility determination (EDRES).  FAMIS correctly determines eligibility.  Do not complete a WIBCA to authorize benefits for the month in which the individual complies.

All EU Members Do Not Comply

The application pends until the last day of the certification period for timely reapplications or 30 days for non-timely reapplications and initial applications.  If a one person EU or all EU members do not comply with METP requirements the application is rejected following the timeframes listed below, as long as the EU was given at least 10 days to comply and/or provide requested verification and the controlled flow is complete:

  • Timely reapplications – the application is rejected the night of the last day of the certification, if the last day is a business day.  If the last day is a weekend or holiday, FAMIS rejects the application the night of the first business day following the end of the certification.
If the controlled flow is not complete or has an ISD on the last day of the certification, FAMIS can take no action.  Complete the controlled flow and authorize the action.
  • Non-timely reapplication and initial applications – the application is rejected the night of the 30th day, if the 30th day is a business day.  If the 30th day is a weekend or holiday, FAMIS rejects the application the night of the first business day following the 30th day.
If the controlled flow is not complete or has an ISD, FAMIS can take no action on the 30th day following the date of application.  Complete the controlled flow and authorize the action.
Follow policy in the Food Stamp Manual at 1130.000.00 Certification Procedures for worker initiated rejection if the application is in the controlled flow and the processing timeframe is expired.

If no other outstanding verification was needed, the Reason field on the Action Authorization (FM3H) screen displays “ROL”.  Press F19=REASON and both ROL and the METP sanction type appears.

If other outstanding verification was requested but not provided, the Reason field on the Action Authorization (FM3H) screen displays VER – verification not provided.

When there is more than one EU member and not all EU members have an METP sanction, the FA-150 Action Notice advises the EU which EU member is rejected due to an METP sanction.  If there is other outstanding verification in addition to the METP sanction and the verification is not provided by the 30th day, the FA-150 shows the reason for rejection as "requested verification was not provided."

If the EU provides verification of compliance with METP within the timeframes outlined in the Food Stamp Manual Section 1130.027.00 EU Provides Requested Verification/Takes Required Action After Rejection, the application may be cancel rejected.

An EU Member Does Not Comply, But There Are Other EU Members

The application pends until the last day of the certification for timely reapplications or 30 days for non-timely reapplications and initial applications.  When there are other EU members, the controlled flow is completed, there is no other outstanding verification, and the remaining EU members are eligible for benefits, FAMIS takes action in the timeframes listed below:

  • Timely reapplications--the night of the last day of the certification, if the last day is a business day the sanctioned individual is rejected and the remainder of the EU is approved as long as the EU has had 10 days to provide requested verification.  If the EU has not had 10 days to provide the requested verification, the application pends until the day after the 10 day timeframe.  If the last day is a weekend or holiday, FAMIS rejects the sanctioned individual and approves the other EU members the night of the first business day following the end of the certification.
If the controlled flow is not complete, FAMIS can take no action.  Complete the controlled flow and authorize the action.
  • Non-timely reapplication and initial applications – the sanctioned individual is rejected the night of the 30th day and the remainder of the EU is approved, if the 30th day is a business day as long as the EU has had 10 days to provide the requested verification.  If the EU has not had 10 days to provide the requested verification, the application pends until the day after the 10 day timeframe.  If the 30th day is a weekend or holiday, FAMIS rejects the sanctioned individual and approves the remaining EU members the night of the first business day following the 30th day.
If the controlled flow is not complete, FAMIS can take no action.  Complete the controlled flow and authorize the action.
If no other outstanding verification was needed, the Action field on the Action Authorization (FM3H) screen displays RJPR for the sanctioned individual and reason “MTP” - non-compliance with MO Employment and Training.

If the sanctioned individual later complies, the individual becomes eligible for benefits the month following the month in which s/he complied.  Go to the Sanction/Disqualification (FMAM) screen and enter the compliance date.  Complete an eligibility determination (EDRES).  FAMIS correctly determines eligibility.

Do not complete a WIBCA to authorize benefits for the month in which the individual complied.

Expedited Application

If other EU members are entitled to expedited benefits, authorize the benefits without the sanctioned EU member.  The case is processed and approved, rejecting the sanctioned EU member.  If the EU member later complies by completing the required action, end the sanction as described above and run a new eligibility determination.  The EU member will be added back to the case the date of compliance unless it is their second or third sanction and they have not yet served the mandatory three or six month sanction.  Refer to the Updating/Ending a Sanction or Disqualification user guide for more information.

When the only EU member is sanctioned and is also expedited eligible, expedited benefits are not issued as the EU is not yet eligible for food stamp benefits.  The application is pended for thirty days or until the EU member complies.  If the EU member complies prior to the 30th day, they become eligible for benefits from the date of compliance.  If the EU member does not comply, the application is rejected.

Ending Sanction Code RTT and WRC and Redefining NFF

Due to the fact that we no longer process specific fail reasons when an individual fails to comply with DWD, sanction code reasons RTT (refused/employed training or treatment) and WRS (failure to register for employment) are removed.  They can no longer be entered as a sanction type.  All DWD sanctions are currently MTP sanctions and are not further defined as refusing to register for work or refusing employment or training.  Sanction type NFF is redefined to non-compliance with case management.


NECESSARY ACTION:
  • Review this memorandum with all appropriate staff.
  • Stop leaving applications in the controlled flow to allow an EU member to complete action to end an employment and training sanction.
JKW