Temporary Suspension of SNAP Work Requirement Policy Due to COVID-19 Starting April 2020

Helping Families. Supporting Communities. Empowering Individuals.

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03/26/2020

Policy Memo

Summary

  • This policy memo is to inform staff in Cook County and DuPage County of the temporary suspension of the Supplemental Nutrition Assistance Program (SNAP) Work Requirement policy in Illinois effective 04/01/2020.  This action is the result of H.R. 6201, Families First Coronavirus Response Act, Title III - Section 2301, which temporarily suspends the work and training requirements for SNAP during the COVID-19 crisis.  This temporary suspension begins 04/01/2020, and continues until the public health emergency declaration by the Secretary of Health and Human Services based on the outbreak of COVID-19 is lifted. Staff will be notified when to resume the SNAP Work Requirement. 
  • In addition to the suspension of the SNAP Work Requirement policy effective 04/01/2020 under H.R. 6201, Illinois is issuing policy to permit SNAP recipients subject to time-limited benefits in DuPage County the ability to claim Good Cause for the month of March, if they are unable to comply with the SNAP Work Requirement due to the COVID-19 crisis. 
  • Certain guidelines and restrictions enforced on Illinois' residents, businesses and other outside entities to help protect the health and safety of residents may place limitations on a nonexempt customer's ability to fulfill their work requirement obligation.  Good Cause includes situations beyond the customer's control, such as, but not limited to illness or work conditions that pose an unreasonable degree of risk to the person's health and safety or to the safety of others. Nonexempt SNAP recipients residing in DuPage County may claim Good Cause for March 2020.
  • The SNAP Work Requirement policy began in DuPage County January 01, 2018. Some DuPage County recipients have received their 3 months of time-limited benefits and are not currently active for SNAP due to not regaining eligibility. These individuals are eligible to reapply for benefits again starting 04/01/2020 under the exception being granted by FNS due to the COVID-19 crisis. The requirement to regain eligibility is being waived. The customer may complete an application for SNAP effective 04/01/2020. The regaining eligibility question in IES will be disabled to allow the individual to qualify for SNAP.
  • The 12 percent exemptions will still be applied to the month of March for nonexempt customers living in Cook County who would have lost eligibility for April due to not meeting the work requirement.
  • Implementation of the SNAP Work Requirement in the 90 additional Illinois counties is on hold until further notice.

Temporary Suspension of SNAP Work Requirement

  • As a result of H.R. 6201, Families First Coronavirus Response Act, Title III- Section 2301, the work and training requirements for SNAP has been temporarily suspended due to the COVID-19 crisis effective 04/01/2020. To insure the health and safety of all Illinois residents, the SNAP Work Requirement policy is temporarily suspended in Cook County and DuPage County effective 04/01/2020. Nonexempt SNAP recipients residing in Cook County and DuPage County are no longer required to comply with SNAP Work Requirement policy. Staff are not to enforce this policy on any SNAP recipient until further notice.

Regaining Eligibility DuPage County

  • The SNAP Work Requirement began in DuPage County January 01, 2018. Some DuPage County recipients have received their 3 months of time-limited benefits and are not currently active due to not regaining eligibility. These individuals are eligible to reapply for benefits again starting 04/01/2020 under the exception being granted by FNS due to the COVID-19 crisis. The requirement to regain eligibility is being waived. The customer may complete an application for SNAP effective 04/01/2020. The regaining eligibility question in IES will be disabled to allow the individual to qualify for SNAP.
  • Implementation of the SNAP work requirement in the 90 additional Illinois counties is on hold until further notice.

SNAP Work Requirement - March Time-Limited Benefits.

  • In addition to H.R 6201, the Illinois Department of Human Services (IDHS) is issuing policy that permits SNAP customers who are subject to time-limited benefits in DuPage County the ability to claim Good Cause for the month of March, if they are unable to comply with the SNAP Work Requirement policy due to the COVID-19 crisis. Allow a customer Good Cause, if they state they are unable to comply with the SNAP Work Requirement policy due to COVID-19. The HSC must do an override of the ABAWD time-limited Clock so that it does not count as a ticked (unmet) month for March.
  • Good Cause includes situations beyond the customer's control, such as, but not limited to, illness or work conditions that pose an unreasonable degree of risk to the person's health and safety or to the safety of others. Verification is not needed and may be difficult for the customer to obtain. Document the reason in Case Comments.
  • The 12 percent exemptions will still be systematically applied to the month of March for nonexempt customers living in Cook County who would have lost eligibility for April due to not meeting the work requirement for 3 months. The 12 percent exemption is not determined by FCRC staff.

SNAP Work Provisions

SNAP customers who must comply with the Work Provisions may also be impacted by the COVID-19 crisis and may claim Good Cause. In some instances, employers may have closed their business or reduced the work hours of employees in order to comply with certain guidelines enforced in Illinois due to COVID-19. SNAP recipients who are subject to the Work Provisions requirements should not be sanctioned, if their hours are reduced to comply with these guidelines.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services