Treatment of Payments Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) for Cash, Medical, and SNAP

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05/13/2020

Policy Memo

Summary:

  • This policy memo provides guidance to staff on how to treat the Federal Economic Impact Payments (Stimulus payments) and the Federal Pandemic Unemployment Compensation (FPUC) benefits authorized under the Coronavirus Aid, Relief and Economic Security Act (CARES) for Cash, SNAP and Medical programs.
  • Under the guidance of Administration for Children and Families (ACF), Federal Center for Medicaid and Medicare Services (CMS), Food and Nutrition Services (FNS) and pursuant to 26 U.S.C. 6409, the Stimulus payments of $1,200 plus an additional $500 per child received under the CARES Act is exempt income in the month of receipt and exempt as a resource for 12 months from receipt.
  • The Stimulus payments are exempt as income and exempt as a resource for 12 months after it is received for medical cases and SNAP non-categorically eligible households.
  • Under the CARES Act, there are 3 different types of federally funded unemployment compensation benefits, however this policy memo addresses only FPUC. Information will be forthcoming on the other two types, Federal Pandemic Unemployment Assistance/Payments (PUA) and Federal Pandemic Emergency Unemployment Compensation (PEUC).
    • PUA expands benefits to include those individuals who are self-employed, individual contractors, have insufficient work history or otherwise not qualified for regular unemployment, etc.
    • PEUC extends benefits to individuals; and
    • FPUC Federal benefits increase regular unemployment benefits by $600 a week.
  • FPUC is exempt income for cash programs and medical programs.
  • FPUC under the CARES Act is non-exempt income for SNAP purposes.

Stimulus Payments received from CARES Act

Under the guidance of ACF, CMS, FNS and pursuant to 26 U.S.C. 6409, the Stimulus payments of $1,200 plus an additional $500 per child received under the CARES Act is exempt income in the month of receipt and exempt as a resource for 12 months from receipt for AABD, TANF and Refugee cash programs, non-MAGI medical programs, and SNAP (non-categorical).

  • Any part of the stimulus payment remaining after 12 months will be considered a non-exempt resource for non-MAGI medical programs after 12 months.
  • Any part of the stimulus payment remaining after 12 months will be considered a non-exempt resource for non-categorically eligible SNAP households after 12 months. A non-categorically eligible household includes:
    • SNAP households that contain elderly/disabled individuals with gross income that exceeds 200% FPL;
    • SNAP households that contain an individual disqualified for Intentional Program Violations (IPV); or
    • SNAP households that contain an individual sanctioned for failure to comply with work provisions.

Unemployment Compensation under the CARES Act

  • FPUC: Provides an additional $600 per week to individuals who are collecting regular state or unemployment compensation benefits. FPUC is not payable for any week of unemployment ending after 07/31/2020.


These payments should be treated as follows:

SNAP Program

FPUC under the CARES Act is considered non-exempt unearned income for the purposes of determining SNAP eligibility. It is to be treated consistent with non-pandemic unemployment benefits. Information on how to treat other types of Federal Pandemic Unemployment Benefits will be supplied when information becomes available.

Cash Programs

Only the FPUC portion of unemployment benefits is considered exempt unearned income for cash programs and should not be budgeted. If a customer reports receiving any of these benefits, workers should not take action to budget the benefits towards federal funded cash programs.

Medical Programs

  • Only the FPUC portion of unemployment benefits is exempt income for medical programs. Eligible individuals will receive an increase of $600 per week thru 07/31/2020. Caseworkers should review AWVS to verify the individual received the FPUC payment. These additional FPUC payments are exempt income for medical eligibility and are to be deducted from the total unemployment benefit payment prior to entering the unemployment income into IES as earned income. Enter a specific case comment noting the action.


Note: AWVS does not separate the FPUC from the previous amount the individual was receiving. See the example IES clearance below, the individual below received 1 week of FPUC payments, and the weekly amount is shown without the $600.

IES AWVS Clearance Example

Example from AWVS clearance record above:

  • A weekly benefit amount of $238 + dependent allowance of $90 = $328 total weekly benefit.
    • $328 X 2 (paid biweekly) = $656 (total biweekly payment)
  • On 04/07/2020, payment increased by $600 which included the FPUC payment.
  • Total monthly UIB benefits equals $1912($1256 + $656). The FPUC benefit of $600 needs to be subtracted. $1912-$600 = $1312. This is the total UIB benefits that should be entered in IES.

Case Comment: Deducted $600 FPUC UIB payment. FPUC increase is exempt for medical coverage.

NOTE: This example only shows one FPUC payment of $600. Each individual's AWVS clearance result will display differently depending on when the UIB benefits started.


IES

An IES ALERT! will be posted for proper entry of the federal unemployment benefits. FPUC is only budgeted for SNAP and not for Medical or Cash. A separate income record must be added in order for programs to budget correctly in IES. Two separate unearned income records need to be created; one for regular unemployment benefits and an additional record for supplemental FPUC. Add the FPUC unearned income with the verification type "Adoption Subsidy".

NOTE: If the edge is incorrectly denied due to the income type of "adoption subsidy", an override will need to be added to case to approve Medical edges.


[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Theresa Eagleson

Director, Healthcare and Family Services