MEMORANDUM

2010 Memorandums

IM-#36      04/22/10

DEPARTMENT OF SOCIAL SERVICES
FAMILY SUPPORT DIVISION
P.O. BOX 2320
JEFFERSON CITY, MISSOURI
TO:
ALL COUNTY OFFICES
FROM:
ALYSON CAMPBELL, DIRECTOR
SUBJECT:
SIMPLIFIED REPORTING RULES FOR ALL FOOD STAMP ELIGIBILITY UNITS
FOOD STAMP MANUAL REVISION # 12
SECTION 1102.015.10
SECTION 1102.025.00
SECTION 1105.005.00
SECTION 1105.010.10.07
SECTION 1105.010.10.30
SECTION 1105.010.20.20
SECTION 1105.010.20.25
SECTION 1105.035.10
SECTION 1115.020.03
SECTION 1115.020.05.20
SECTION 1115.035.02
SECTION 1115.035.25.20
SECTION 1120.005.10
SECTION 1120.035.00
SECTION 1125.035.00
SECTION 1130.030.00
SECTION 1130.030.05 (OBSOLETE)
SECTION 1130.030.10
SECTION 1130.030.15 (OBSOLETE)
SECTION 1130.099.00
SECTION 1135.035.05.10
SECTION 1140.000.00
SECTION 1140.005.00
SECTION 1140.005.05
SECTION 1140.005.10
SECTION 1140.005.18
SECTION 1140.005.20
SECTION 1140.005.20.05
SECTION 1140.005.20.10
SECTION 1140.005.20.15
SECTION 1140.005.20.20
SECTION 1140.005.20.25
SECTION 1140.005.20.30
SECTION 1140.005.20.35
SECTION 1140.005.20.40
SECTION 1140.010.00 (OBSOLETE)
SECTION 1140.010.05 (OBSOLETE)
SECTION 1140.010.10 (OBSOLETE)
SECTION 1140.015.00
SECTION 1140.020.00
SECTION 1140.20.15
SECTION 1140.020.30
SECTION 1140.025.05
SECTION 1140.040.00
SECTION 1142.035.10
SECTION 1145.020.00
SECTION 1145.030.00

DISCUSSION:

Effective May 1, 2010, all Food Stamp EUs are subject to simplified reporting requirements. Changes are made to certification periods and the mid-certification review policy. Income Maintenance Memorandum IM-#31, dated April 7, 2010, introduced this change, the initial notice to EUs, and the poster to help explain the change.

This memorandum discusses the following:

Implementation

A poster is created to display in county offices announcing the change in reporting requirements. Print and place the poster in the county office where recipients of Food Stamp benefits can see it.

On April 15, 2010, all EUs not currently subject to simplified reporting will be sent an FA-601 CLAIMANT INFORMATION NOTICE, which is entitled "Important Notice to All Food Stamp Recipients". The notice states the reporting requirements that begin on May 1, 2010, and that they are not required to report any changes except:

The IM-4FS/SR Simplified Reporting for the Food Stamp Program brochure is being revised to include simplified reporting rules for all EUs. Provide a copy of the poster and/or the revised IM-4 FS/SR to any EU asking about reporting requirements. This brochure must be given to the EU at every application or recertification. Discuss the new change reporting requirements and the mid-certification review process at each application. Staff must advise EUs that reporting requirements are only changed for the Food Stamp Program.

Share the poster with community partners to announce the change in reporting requirements for Food Stamp EUs.

Prior to implementation all EUs which are not currently subject to simplified reporting rules are converted. On May 1, 2010, the simplified reporting field on the Eligibility Unit Summary (FM0J) screen displays "Y" and all Food Stamp EUs become subject to simplified reporting rules.

Certification Periods and Mid-Certification Review Periods

Effective May 1, 2010, the following certification periods and mid-certification review (MCR) periods are set by FAMIS at new approval or recertification.

  Beginning May 1, 2010
  Certification Period Mid- Cert Review Period
All Adult Members Elderly or Disabled with No Earned Income 24 months 12 months
All other Food Stamp EUs 12 months 6 months

EUs with All Adult Members Elderly or Disabled with No Earned Income are only required to be reviewed every 12 months. The EUs can be certified for 12 months instead of 24 months only if it can be documented their situation is unstable. Record the reason for the 12 month certification in FAMIS. In this circumstance there is no MCR because the review is only required every 12 months, and the case is recertified at 12 months. An anticipated change known at certification is not justification of a 12-month certification period because this is a change that can be acted upon following simplified reporting rules.

Certification periods of active Food Stamp EUs are not changed until the next recertification after May 1, 2010.

EXAMPLE: A non-elderly/disabled EU with earned income is certified six months, April 2010 through September 2010. This EU must recertify in September 2010, and if eligible is certified for 12 months, October 2010 through September 2011.

Mid-Certification Review Report Form

Effective May 1, 2010, Mid-Certification Reviews (MCR) are completed using the Food Stamp FA-545 Mid-Certification Review Report form. FAMIS no longer completes the MCR for categorically eligible households. The MCR cannot be completed by a telephone contact.

The FA-545 Food Stamp Mid-Certification Review Report form is completed by the EU. The FA-545 MCR Report may be returned by mail and no in-person or telephone contact is required.

The FA-545 MCR Report asks the EU to report the following:

Any other changes reported on the FA-545 MCR Report, or any cumulative actions previously disregarded are acted upon when completing the MCR.

Mid-Certification Review (MCR) Process

The Food Stamp Mid-Certification Review process follows the review process for other programs in FAMIS.

An FA-545 Food Stamp Mid-Certification Review Report form is generated by FAMIS on the 5th day of the month prior to the MCR month. The FA-545 MCR Report is due back from the EU the last day of the month prior to the MCR month.

EXAMPLE: Ms. Jones' Food Stamp certification is July 2010 - June 2011. The MCR month is December 2010. FAMIS sends the EU an FA-545 MCR Report on November 5, 2010. The FA-545 MCR Report is due back from the EU before November 30, 2010.

The alert "Mid-Certification Review Required." is generated at the time the FA-545 MCR Report is mailed to the EU. The alert continues to display until the review action is taken in FAMIS.

Mid-Certification Reviews may be initiated by the eligibility specialist when FAMIS cannot generate the FA-545 MCR Report because of timing. To create a review, go to the TA/MA/FS Review History (FM57) screen in FAMIS, prompt for Food Stamp program and press F14=ADDREIN. The message, "REIN Created, Notice Scheduled for Printing" displays at the bottom of the screen.

NOTE: Reviews created by the eligibility specialist on-line can be deleted on the same day the review is created as long as no factors have been reviewed. Enter "D" on the command line and press enter to delete. After the date of creation has passed the review must be completed and cannot be deleted.

Cases that are in closed status on the 5th of the month, and are cancel closed in the month prior to the MCR month require the eligibility specialist to initiate the MCR process. The same mid-certification review procedures apply.

EXAMPLE: Ms. Jones' Food Stamp certification is June 2010 - May 2011. The MCR month is November 2010. The EU is closed on October 2, but is cancel closed on October 7. Because the case was in closed status, the FA-545 MCR Report is not sent on the 5th of October. The ES should generate the FA-545 MCR Report when the case is cancel closed. The FA-545 MCR Report is due back from the EU before October 31, 2010.

The first FA-545s generated by FAMIS will be May 5, 2010, for the MCR month of June. For May 2010 MCRs, staff may either follow current process or may generate an FA-545 on the TA/MA/FS Review History (FM57) screen and track the review in FAMIS.

FA-545 MCR Report Form Received

When the completed FA-545 MCR Report is received go to the TA/MA/FS Review History (FM57) screen in FAMIS.

The status of the review will be PEN (Pending) or CMP (Complete). When all factors have been reviewed and the status is CMP, complete an eligibility determination (EDRES). All current changes entered and cumulative changes are authorized. Do not disregard this action. This is an action that must be taken.

NOTE: FAMIS does not give the option to disregard an MCR action. Therefore, it is important to complete the actions as soon as possible. If another change is reported while the MCR is pending, this change also becomes a part of the MCR and the action will be taken.

The FA-545 MCR Report is considered returned even if the information provided is incomplete or unclear. Missing or incomplete information is requested on the FA-325, Request for Information form. Allow the EU ten (10) days to respond to the FA-325.

Refer to the Completing a Temporary Assistance/MoHealth Net/ Food Stamp Review in FAMIS user guide for assistance in completing the review.

FA-545 MCR Report Form Not Received

If the FA-545 MCR Report is not returned or a date returned is not entered by the last day of the month before the MCR month, FAMIS takes action to close the case. An FA-510, Adverse Action Notice, is sent on the first working day of the MCR month with the reason "Failed to return the review form."

If the Food Stamp MCR is pending and a review form for another IM program is returned, but the FA-545 Food Stamp MCR Report form is not returned, the review form for the other program is considered a returned MCR form for the Food Stamp Program.

FA-545 MCR Report Form Received After the EU is Closed

When the EU is closed for failure to return the FA-545 MCR Report, cancel close the EU if the form is received before the end of the MCR month. Benefits are not prorated.

EXAMPLE: EU with earned income certified June 2010 through May 2011. The FA-545 MCR Report is mailed October 5, 2010. The FA-545 MCR Report is not received by October 31. The FA-510 Adverse Action Notice is sent November 1, 2010, and case closed. The FA-545 MCR Report is received November 24, 2010. Cancel close this EU. FAMIS issues a full month’s benefit for November.

Use cancel close procedures when reopening the case.

If the FA-545 MCR Report is not received before the end of the MCR month, the EU must reapply for Food Stamp Benefits.

For additional information refer to Food Stamp Manual section 1140.040.00 MID-CERTIFICATION REVIEWS.

FA-545 MCR Completed Through Other Case Actions

A Food Stamp add-a-person application completes all of the factors required for an MCR when completed during the time frame the MCR are generated and due back. FAMIS completes the MCR when the action is authorized and assigns the EU a new review date when applicable.

EXAMPLE: Ms. Jones' Food Stamp certification is July 2010 - June 2011. The MCR month is December 2010. The FA-545 MCR Report is generated on November 5, 2010. The FA-545 MCR Report is due back from the EU before November 30, 2010. On November 15, 2010, the EU reports a new member and the add-a-person application is authorized on November 16, 2010. This completes the MCR.

A Food Stamp recertification completes all of the factors required for an MCR.

EXAMPLE: Ms. Jones' Food Stamp certification is June 2010 - May 2012. In October 2011 income is added to a current member. The certification does not change, but an MCR is due six months later, April 2012, which is just one month before the certification ends. (Changing the MCR is discussed in the next section.) The FA-545 MCR Report is generated March 5, 2012. The EU comes to the office to discuss the MCR. Since it is less than 60 days from the end of the certification, the eligibility specialist has the EU complete an application for Food Stamp benefits, completes the interview for the recertification, and authorizes the action. Completing the recertification also completes the MCR.

The MCR form is not to be used in place of the FA-331 Appointment Letter/Request for Contact or the IM-31RFC. When an EU’s circumstances are in question or information is received that requires additional clarification, send an FA-331 or IM-31 to request contact from the EU.

Shortening Certification (SHCP) and Changing the Mid-Certification Review Period (CHMC)

Changes to an EU can cause FAMIS to shorten the certification period and/or change the MCR month.

For EUs certified for 24 months, FAMIS shortens the certification period to12 months from the date of the change and shortens the mid- certification review period to 6 months from the date of the change if there are 12 months remaining in the certification period when:

EXAMPLE: Ms. Smith’s Food Stamp case is certified for March 2010 - February 2012. In October 2010, an EU member with earned income is added to the household. This EU is subject to simplified reporting rules, even though it was certified before May 1, 2010. The income causes a reduction in benefits so the action is disregarded because of simplified reporting rules for a change reported between reviews. (This change is acted upon at the next review as a cumulative change.)

The addition of a member with income causes the certification to change even though the benefit did not change. The last month of the certification is changed to October 2011. FAMIS changes the MCR month to April 2011 and notifies the EU. The FA-545 MCR Report is generated on March 5, 2011.

If there are less than 12 months remaining in the certification, the certification period is not changed. However, a new MCR date is set for the 6th month following the action if there are more than 6 months remaining in the certification period.

EXAMPLE: Mr. Jones' Food Stamp case is certified for April 2010 - March 2012. In August 2011, an EU member with earned income is added to the household. This EU is subject to simplified reporting rules, even though it was certified before May 1, 2010. The income causes a reduction in benefits so the action is disregarded because of simplified reporting rules for a change reported between reviews. (This change is acted upon at the next review as a cumulative change.)

The addition of a member with income would cause the certification to be shortened to 12 months even though the benefit did not change. However, there are only 7 months remaining in the certification period. The certification period is not changed, but FAMIS changes the next MCR month to February 2012. FAMIS generates the FA-545 MCR Report on January 5, 2012.

The certification period is only shortened if a new member is added which changes the status of the EU. A change in the status of an active Food Stamp EU member does not change the certification period. However, the mid-certification review period is changed from 12 months to every 6 months for the remaining certification period if:

EXAMPLE: Mr. Temple’s Food Stamp case is certified for April 2010 - March 2012. In June 2010, Mr. Temple gets a job and reports it. The income causes a reduction in benefits. The action is disregarded because of simplified reporting rules for a change reported between reviews. (This change is acted upon at the next review as a cumulative change.)

Because income is added to a current household member, the certification is not shortened. However, FAMIS changes the next MCR month to December 2010 and notifies the EU. FAMIS generates the FA-545 MCR Report on November 5, 2010. There will also be MCRs in June 2011, and December 2011 before the recertification in March 2012.

The action SHCP (Shorten Certification Period) is displayed on the Eligibility Unit Log (EULOG) screen when a certification period is shortened. The action CHMC (Change Mid-Certification Review) is displayed when mid-certification review period is changed. When the certification period or the mid-certification review period is changed, an FA-150 Claimant Action Notice is sent to the household including the new date.

Simplified Reporting Scenarios have been created and are available in Food Stamp Charts for reference.

Acting on Changes

All Food Stamp EUs are subject to simplified change reporting rules effective May 1, 2010. Elderly/Disabled EUs without earned income certified prior to May 1, 2010, continue to be subject to change reporting requirements until May1, 2010.

All cumulative changes are acted upon at MCR. All changes reported while the MCR is pending are acted upon as cumulative changes.

System Changes

The Simplified Reporting field on the Eligibility Unit Summary (FM0J) screen displays "Y" for all EUs after May 1, 2010. The Simplified Reporting field on the Action Authorization (FM3H) screen will show the correct history for the change reporting status at the time of the action to assist staff with case reviews and overpayment determinations.

FAMIS continues to set certification periods at approval and MCR periods.
FAMIS shortens certification periods and MCR periods if necessary.

A message has been added to the FA-150 Claimant Action Notice telling the EU the next review date.

Fair Hearing Request

If the EU requests a fair hearing for the Food Stamp Program fax the request to the Hearings Unit the same day. It is important to send all Agency evidence to the Hearings Unit as soon as possible. All available evidence should be sent to the Hearing Unit with the original request for hearing within 24 hours. Do not wait until a few days before the hearing to send the evidence.

For a request for fair hearing for failure to return the Mid Certification Review, evidence may include, but is not limited to these items:

For action resulting from failure to return information needed to complete the review, also include the FA-325 Request for Information.

For budget adjustments or closing, evidence includes, but is not limited to:

NOTE: If taking actions on cumulative changes, it is necessary to include notices and budgets from previous actions.

Provide a copy of the evidence to the EU asking for the hearing, and their legal representative and schedule a pre-hearing conference. If the EU designates an attorney or authorized representative for the hearing, send a copy of all notices and evidence for the hearing to the EU and the designated individual.

Please note that if verification of child support income was from a MACSS screen, the verification to support this should be requested from child support staff for the hearing. They can give you a print-out that contains the same information you viewed, that can be presented as evidence. If you cannot get this information, contact Food Stamp Program and Policy Unit for assistance. Do not go to hearing and state that the verification cannot be supplied because the screen cannot be printed, as the Agency has access to this information.

Food Stamp Manual, User Guides, and Brochure Changes

The Food Stamp Manual is revised to include this policy. The obsoleted sections of the manual are available on an attached document for reference in reviewing possible overpayments and eligibility prior to May 1, 2010, for EUs not subject to simplified reporting rules. The FAMIS user guide Completing a Temporary Assistance/Medical Assistance/ Food Stamp Review in FAMIS and the IM-4FS/SR Simplified Reporting for the Food Stamp Program brochure are being revised and will be available upon completion.

NECESSARY ACTION:

KSO/JM/CS

Attachment


2010 Memorandums