|PENDING FOOD STAMP APPLICATIONS FOR SANCTIONED INDIVIDUALS|
The purpose of this memorandum
is to discuss:
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:
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:
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:
The FA325 will show "compliance" in the proof of field and the following messages in the source field based on the type of sanction:
The application cannot be authorized until the sanction is ended and any other verification is provided or the application has pended
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.
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:
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.
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.
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:
If the controlled flow is not complete, FAMIS can take no action. Complete the controlled flow and authorize the action.
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.
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.