MR #19.08: Important SNAP Policy Clarifications

05/09/19

Summary

• This manual release revises certain PM/WAG sections of the policy manual to comply with the final rule changes made to provisions of the Food, Conservation and Energy Act of 2008 that amends certain SNAP regulations affecting applicants and participants in the Supplemental Nutrition Assistance Program (SNAP). The dot points below identify the SNAP policy manual sections that are revised. The Family and Community Resource Center (FCRC) should apply these policy changes as eligibility determinations are being made for initial applications, redetermination (REDE), case changes and program adds, if applicable to the SNAP household.
• Adds policy to PM 02-04-00 requiring FCRCs to offer a copy of a SNAP household's completed application, regardless of the method by which the applicant submitted the application. SNAP households that choose to request a copy of their completed application may select the format of the copy (paper or electronic). The FCRC must provide the copy in the format the household requests. This includes an application completed for other program benefits that includes a request for SNAP. Until the Integrated Eligibility System (IES) is programmed, document in the Case Comments that the customer was offered a copy of their application and the format in which it was provided. Also indicate in the Case Comments when a customer declines the offer.
• A general clarification was added to PM 02-04-00 regarding Illinois' compliance in the use of the telephonic signature and the audio recording of the household's verbal agreement which includes a summary of the information to which the household agreed, when completing an application through the Application for Benefits Eligibility (ABE) Customer Call Center.
• Clarifies policy in PM 07-04-13 to exempt one burial plot per SNAP unit member and the value of one funeral agreement per SNAP unit member. This exemption includes all revocable or irrevocable prepaid burial contracts and contracts funded by a life insurance policy. Most SNAP households are categorically eligible, and their assets are not considered.
• Clarifies policy and procedures in PM 08-04-04-v and WAG 08-04-04-v, that FCRC staff must verify military combat pay before allowing it as an exclusion from the income of a SNAP household that applies for or participates in SNAP. This exclusion applies only to additional pay resulting from deployment or service to a combat zone and not to pay received prior to deployment.  
• Reiterates that the FCRC must provide a SNAP household in Mid-Point Reporting an opportunity to participate in the Supplemental Assistance Program no later than 10 days after the household's normal issuance date, if an eligible household returns a complete Mid-Point Report (Form 2890) within 10 days of the date of the Mid-Point Report Reminder - Action Required (Form 2891). See Manual Release MR #18.14: Revises Mid-Point Reporting Process - Reminder Notice Required, dated 07/31/18 and PM 19-07-07, WAG 19-07-07.
• Clarifies policy in PM 13-01-05-a , PM 13-01-06, to allow a SNAP household with an incapacitated member of any age, the option to deduct attendant care costs as either a dependent care deduction or a medical expense deduction. Previous policy stated to allow the expense only as a medical deduction. Document the customer's choice in the Case Comments.
• Adds policy stating transportation costs to and from dependent care facilities and activity fees associated with the care provided to the dependent may be allowed as a dependent care deduction.
• Adds a policy clarification to exempt as income and as a resource benefits paid by the Veteran Administration to the children (including adult children) of Vietnam veterans born with congenital Spina Bifida.
• FCRC staff are still required to act on all reported changes in general. A 267 VCL must be sent to the SNAP household requesting clarification and/or verification if unclear information is received from a third party or from the SNAP household itself from which the FCRC cannot readily determine the effect of the change on the SNAP case.
• There is a change in policy on how to treat unclear information received from a data crossmatch (excluding Prisoner Data Matches, Death Data Matches and information received on undeliverable mail/unreported address changes). Policy and procedure is added to PM 18-04-03 and WAG 18-04-03 requiring an FCRC to only pursue clarification and verification (if applicable) of a SNAP household's circumstances if unclear information is received from a data crossmatch that:

• If the unclear information is more than 60 days old, or it indicates that there was a change in household circumstances, but not a change the household was required to report, the FCRC will follow-up on the information at the next REDE of a Change Report household or at the next Mid-Point Report or REDE of a Mid-Point Reporting household, whichever is earlier.
• A desk aid (pdf) has been created to help staff determine when to follow-up on a data crossmatch.

Note: FCRC staff are still required to act on all Prisoner Data Crossmatches, Death Data Crossmatches and information received on undeliverable mail/unreported address changes.

1. Introduction
2. Provide a Copy of SNAP Application
3. Exempt Burial Needs of SNAP Member
4. Military Combat Pay Exclusion
5. Telephonic Signatures- Audio Recording of Verbal Agreement
6. Dependent Care Costs
   1. An Attendant Care Expense may be allowed as a Dependent Care Deduction or as a Medical Deduction
   2. Activity Fees/Transportation Costs
7. Payments Received for Children with Spina Bifida
8. Act on Mid-Point Report Within 10 days
9. Act on Reported Changes
   1. Reported Changes in General
   2. Reported Changes with Unclear Information
      1. Information Verified Upon Receipt/Additional Information Needed
   3. Information Verified Upon Receipt/No Additional Information is Needed
10. When to Act on Unclear Information Received from Data Crossmatches
    1. Unclear Information Fewer Than 60 Days Old
    2. Information Conflicts with What Was Reported at Application
    3. Unclear Information More than 60 Days Old
    4. Determining When to Act on Unclear Information Received from a Data Crossmatch
    5. 267 VCL/360C Notices
11. Procedures for Acting on Unclear Information from a Prisoner or Death Match
    1. Death Data Crossmatch
12. Manual Revisions
13. Forms Referenced:

Introduction

This manual release revises certain PM/WAG sections of the policy manual to comply with the final rule changes made to provisions of the Food, Conservation and Energy Act of 2008 to amend certain SNAP regulations affecting applicants and recipients participating in the Supplemental Nutrition Assistance Program (SNAP).

The SNAP policy references identified below affect eligibility determinations and participation. These sections are revised to clarify the policy and may include additional information that was not previously in the section. FCRC staff should review the policy sections and apply the changes to all initial applications, REDEs, case changes and program adds, if applicable to the SNAP household.

Provide a Copy of SNAP Application

Regardless of the method by which a SNAP household applies, the FCRC is required to offer the household a copy of its completed application. This includes an application completed for other program benefits that includes a request for SNAP. SNAP households that choose to request a copy of their completed application may select the format of the copy (paper or electronic). The FCRC must provide the copy in the format that the SNAP household requests. If the SNAP household completed a paper application, but requests the copy in electronic format, the FCRC must provide the copy in electronic format. Policy is added to PM 02-04-00 to comply with this requirement. Until IES is programmed, document in the Case Comments that the customer was offered a copy of their application and include the format in which it was provided. Also indicate in Case Comments when a customer declines the offer.

Exempt Burial Needs of SNAP Member

Clarifies in PM 07-04-13  to exempt one burial plot per SNAP household member and the value of one funeral agreement per SNAP household member. This exemption includes all revocable and irrevocable prepaid burial contracts and contracts funded by a life insurance policy.

NOTE: Assets are only considered for non-categorically eligible SNAP households (PM 05-07-02).

Military Combat Pay Exclusion

Clarifies policy in PM 08-04-04-v to state that the amount of the combat pay received by military personnel for serving in a combat zone must be verified before allowing as an exemption from income. To verify combat pay, request the SNAP household provide a copy of the:

Telephonic Signatures- Audio Recording of Verbal Agreement

A general clarification was also added to PM 02-04-00 regarding Illinois' compliance in the use of the telephonic signature and the audio recording of the household's verbal agreement which includes a summary of the information to which the households agreed, when completing an application through the ABE Customer Call Center.

Dependent Care Costs

• A dependent care deduction may be allowed for a child under the age of 18 or an incapacitated person of any age (PM 13-01-06). This is a change in previous policy which stated to allow the cost for the care of a child or disabled adult. Incapacitation is: 
  • any permanent or temporary condition that prevents an individual from participating fully in normal activities without supervision (including but not limited to work or school); and
  • that requires the care of another person to ensure the health and safety of the individual, or condition or situation that makes a lack of supervision risky to the health and safety of that individual.
• There is no cap to the total monthly dependent care costs that may be deducted.

Note: Do not refer to the Client Assessment Unit (CAU).

An Attendant Care Expense may be allowed as a Dependent Care Deduction or as a Medical Deduction

• Policy and procedure in PM 13-01-05-a, PM 13-01-06, and WAG 13-01-06 is revised to allow a SNAP household with an incapacitated member of any age the option of choosing to use their attendant care costs as either a dependent care deduction or as a medical expense deduction, but not both. This is a change from previous policy which stated to allow attendant care costs as a medical expense deduction only. The FCRC should discuss these options with the customer and allow the deduction that would be most beneficial in determining their benefit amount.

Example 1: The SNAP household incurs a $600 monthly expense for an incapacitated member who has an attendant come to their home daily while others in the home are at work. There are no other medical expenses for this individual. The SNAP household has the option of using the expense as a dependent care deduction or as a medical expense deduction. Since the $600 expense is more than the Standard Medical Deduction of $245 the household can choose to use the actual medical expense amount as a medical deduction. However, if allowed as a medical expense deduction the amount used in the SNAP calculation is $565 = (600-35). The entire $600 may be deducted in the SNAP calculation as a dependent care deduction. The HSC discusses these options with the customer.

Example 2:The SNAP household incurs a $35 monthly expense for an incapacitated member who has an attendant come to their home one day a week for a couple of hours while others in the home are at work. There are no other medical expenses. Since the expense does not exceed $35 the individual does not qualify for the medical standard. The entire $35 may be deducted as a dependent care deduction. The HSC discusses this option with the customer during the interview.

Example 3: The SNAP household incurs a $100 monthly expense for an incapacitated member who has an attendant come to their home during the day while others in the home are at work. There are no other medical expenses. Since the $100 exceeds $35 the individual qualifies for the standard medical deduction $245. The amount used as a medical deduction in the SNAP calculation is $210 = (245-35). If this expense is used as a dependent care expense only $100 would be deducted in the SNAP calculation. The HSC discusses these options with the customer during the interview and informs them of the best option.

Example 4: The SNAP household incurs a $500 monthly expense for an incapacitated member who has an attendant come to their home during the day while others in the home are at work. The incapacitated member also has monthly RXs of $50. The household may choose to use all expenses as a medical deduction $515 = (550-35) or the household may choose to use the $500 as a dependent care deduction. Since the $50 RX costs exceed $35 the household qualifies for standard medical deduction $245. The total deduction for the household in the SNAP calculation is $710 (245-35 =210 + 500). The HSC discusses these options with the customer during the interview and informs them of the best option.

Activity Fees/Transportation Costs

Policy is revised to include transportation and activity fees as a dependent care deduction. Allowable dependent care costs include:

• the costs of care given by an individual care provider or care facility;
• transportation costs (See PM 13-01-05-a) to and from the care facility. Verification of transportation costs associated with dependent care is not required, unless questionable;
• an activity or other fees associated with the care provided to the dependent that are necessary for the household to participate in the care. The fees do not have to be mandatory to be allowed. The customer must be specific in identifying the fees, but verification is not required, unless questionable. Examples of activity fees that may be allowed as dependent care costs include the cost of an art class for an after school program or an adult day care program, additional equipment fees charged for attending a sports camp, or the cost of field trips sponsored by summer camps.

Note: Like all dependent care costs, activity fees are allowable if they are necessary for a household member to search for employment, or to accept or continue employment, training or education in preparation for a job. There is no limit on the amount.

Payments Received for Children with Spina Bifida

Exclude from the eligibility determination any benefits paid by the Veteran Administration to the children (including adult children) of Vietnam veterans born with congenital Spina Bifida (PL 104-204). Payments made to any child of a Vietnam veteran for birth defects he or she experiences resulting from the Spina Bifida is exempt. A monthly monetary allowance is paid at a rate that is based on the child's level of disability and is exempt as income and as a resource.

Act on Mid-Point Report Within 10 days

When an eligible Mid-Point Reporting household returns a complete Mid-Point Report (Form 2890) within 10 days of the date of the Mid-Point Report Reminder - Action Required (Form 2891), the FCRC must process Form 2890 within 10 days of the customer's normal issuance date, if it cannot be processed by schedule cut-off.  See Manual Release MR #18.14: Revises Mid-Point Reporting Process- Reminder Notice Required, dated 07/31/18 and PM 19-07-07, WAG 19-07-07.

Act on Reported Changes 

Reported Changes in General

Policy to act on all reported changes in general has not changed. When a SNAP household reports a change, including changes reported at REDE or Mid-Point Report, the FCRC should review the effect of the change on the household's eligibility and benefit amount and take the appropriate action. If additional information is needed to determine eligibility, send a 267 VCL to request verifications.

Reported Changes with Unclear Information

• During the certification period, the FCRC may receive unclear information about changes in the SNAP household's circumstances from which it cannot readily determine the effect on the household's continued eligibility for SNAP. The FCRC may receive unclear information from a third party or from the SNAP household itself.
• Unclear information is:
  • information that is NOT verified; or
  • information that is verified but the FCRC needs additional information to act on the change.
• The FCRC must send a 267 VCL notice to follow-up with the customer when information is received that is unclear. See the section below titled "267 VCL/360C Notice" for notice text. Some examples of when reported information may be unclear and require follow-up are below.

Example 1: Ms. G is active for SNAP in Change Reporting. Ms. G reports on Form 1978, Change Report Form, a friend moved into the household but does not provide any other information about the friend, such as name, date of birth, social security number or income. The HSC needs further information to act on the case appropriately. The HSC sends Ms. G Form 267 VCL to request the information needed to add the individual to SNAP.

Example 2: Mr. T is in Mid-Point Reporting. His Mid-Point Report (Form 2890) was returned by the post office as undeliverable. Mr. T has not reported an address change.  He is not required to report the change since he is in Mid-Point Reporting. Since it is unclear as to whether Mr. T has moved, the FCRC must send a 267 VCL request for contact and allow 10 days for Mr. T to respond before canceling his SNAP case. When mail is returned as undeliverable, send the 267 VCL to the last known address (if there is forwarding information on the returned envelope, send to the forwarding address) before canceling the case. Send Form 360C with the appropriate cancellation reason. See PM 03-02-03-a, PM 18-04-03.

Example 3: Ms. L and her husband are active for SNAP in Change Reporting. Ms. L reports on Form 1978, Change Report Form, that her husband has started a job at ABC Construction. She does not report any information regarding his hours of work or his rate of pay. The HSC needs this information to determine the household's continued eligibility for SNAP. The HSC sends Ms. L a 267 VCL to request the employment information.

Information Verified Upon Receipt/Additional Information Needed

If the information is considered verified upon receipt but additional information is still needed to act on the change appropriately, then the information is considered unclear.

Example: The HSC was notified via the customer's statement that another person joined the household. The person's name, DOB and SSN was provided. The customer's statement is considered verified upon receipt, but the HSC does not know how the household's total monthly income may have been changed with the addition of this new person. The HSC sends a 267 VCL to the household for further information and/or verification from the household to provide paystubs to make the appropriate changes to the case.

Information Verified Upon Receipt/No Additional Information is Needed

The FCRC should take the appropriate action if the information is verified upon receipt and no additional information is needed to act on the change. The information is not considered to be unclear.

Example: The HSC received a data match from the Social Security Administration (SSA) that a SNAP customer's SSA was increased within the last 60 days. The case was excluded from Bendex and was not updated. The HSC takes action to make the appropriate changes to the case since the information is considered verified from SSA and the impact on the household is clear.

When to Act on Unclear Information Received from Data Crossmatches

• The procedure on when to act on unclear information was updated, primarily on data matches because they are not adequately compatible with existing SNAP households' reporting requirements.  The final rule made a change to how States act on unclear information.  As the number of data matches increases containing different degrees of accuracy and frequency, there is also an increase in unclear information received from data matches. This resulted in the need for States to send a request for contact notice to households to clarify information that was either outdated or that the household was not required to report. This created an additional burden for States and a barrier to program participation when eligible households are canceled for failing to respond to the notice.
• Policy and procedure in PM 18-04-03 and WAG 18-04-03 is updated to comply with this change in procedure for data crossmatches. This change in procedure does not include Prisoner or Death Data Matches or information received on undeliverable mail/unreported address changes. FCRCs must continue to act on all information received from a Prisoner or Death Data Crossmatch and information received on undeliverable mail/unreported address changes.
• For all other data crossmatches, the FCRC must follow-up with the customer to clarify and verify (if necessary) unclear information only if it:

Note: This policy change applies to both Change Reporting households and Mid-Point Reporting households.

Unclear Information Fewer Than 60 Days Old

The FCRC must send a 267 VCL to request contact with the customer for clarification and verification (if needed) of the unclear information when it is fewer than 60 days old relative to the current month of participation and it indicates there has been a change in household circumstances that should have been reported according to the household's assigned reporting status (Change Reporting or Mid-Point Reporting).

Example: Mr. B is active for SNAP as a Change Reporter (PM 18-04-00). His recent issuance of SNAP benefits was in June. On June 5, the FCRC receives information from a data crossmatch that is fewer than 60 days old relative to the current month of participation (June) that indicates Mr. B's income had increased by $200 in May. The HSC sends Mr. B a 267 VCL to follow-up because Mr. B was required to report when his income increased by $100 or more. If the information had been older than 60 days relative to the current month of participation (June) the HSC would not send a 267 VCL but instead wait until the next redetermination.

Information Conflicts with What Was Reported at Application

The FCRC must follow-up with the customer when information becomes known that conflicts with what was reported on the application and/or during the interview. 

Example 1: When completing the application and at the interview, Mr. T indicated that he did not have income. The FCRC receives information from a data crossmatch that Mr. T is employed and was working at the time of application and the interview. The HSC sends a 267 VCL to request contact with Mr. T for clarification of his employment status and verification if needed.  The task is marked as complete.

Example 2: Mr. H is in Mid-Point Reporting. He receives SNAP with his wife and two children. Mr. H completed a SNAP REDE on 11/10/18. On the REDE form and at the interview Mr. H stated that the household did not have income. They are unable to pay their shelter expenses. On 03/22/19, the HSC receives a data crossmatch which shows Mr. H has earned income that started in February. This income is under the Gross monthly Income Standard for a household size of 4 and Mr. H is not required to report it. The information does not conflict with what Mr. H reported at REDE as he was not working at that time. The HSC marks the task as complete. Mr. H is required to report his income on his next Mid-Point Report (MPR), unless his gross monthly income exceeds the Gross Monthly Income Standard prior to the receipt of the Mid-Point Report.

Example 3: Ms. Z is in Mid-Point Reporting. She completed a SNAP REDE on 11/10/18. Ms. Z reported no income. and stated during the interview that she did not have income. On 03/27/19, the HSC receives a data crossmatch showing Ms. Z started work in February and her gross income exceeds the Gross Monthly Income Standard for a household size of 1. This information does not conflict with what was reported at REDE as Ms. Z did not have income at that time. However, Ms. Z is required to report that her gross monthly income exceeds the Gross Monthly Income Standard for one person. The HSC sends a 267 VCL to follow-up with Ms. Z on the unreported income and files an overpayment. The task is marked as complete.

If the unclear information indicates that there was a change in household circumstances, but not a change the household was required to report, the FCRC will follow up on the information at the next Change Report household's REDE or Mid-Point Report household's REDE or Mid-Point Report, whichever is earlier. This eliminates the potential for canceling eligible households from SNAP based upon changes they were not required to report and workers will spend less time following up on minor changes. The FCRC may follow-up with a SNAP household to provide information (that it was not required to be reported) on a voluntary basis if that information would result in an increase in benefit, but may not take adverse action if the household does not respond.

Unclear Information More than 60 Days Old

The FCRC will not act on this information or require the household to provide information until the next Change Report household's REDE or the next Mid-Point Report household's REDE or Mid-Point Report (whichever is earlier), if the information:

1. is more than 60 days old relative to the current month of participation and was not required to be reported; or
2. does not present significantly conflicting information from that used at the time of certification

Example: Ms. C is active for SNAP in Mid-Point Reporting. Her most recent SNAP issuance was in the month of June. The FCRC receives information outside of Ms. C's Mid-Point Report that is fewer than 60 days relative to the current month of participation (June) that indicates she received a pay increase effective January but the increase did not result in Ms. C becoming ineligible based upon gross income being over the gross income standard for the household size or the increase is not within 60 days of the current month or participation. The FCRC is not required to send a 267 VCL to follow-up with the customer. The FCRC will address the issue at the next Mid-Point Report or REDE, whichever is earlier.

Determining When to Act on Unclear Information Received from a Data Crossmatch

Follow the procedure below to determine when to act on a Data Crossmatch. This procedure does not apply to Death or Prisoner Data Crossmatches or information received on undeliverable mail/unreported address changes.

Data Match Information	FCRC Action to Take
Step One Does the information received significantly conflict with the information used to approve the application?	If Yes, follow-up with the SNAP household by sending a 267 VCL requesting contact and verifications, if needed. See instructions below under the heading 267 VCL/360c notices. If No, then proceed to Step Two.
Step Two Is the information received something the SNAP household is required to report based on their assigned reporting status?	If Yes, proceed to Step Three. If No, then the FCRC should not act on the information or require the SNAP household to provide information until the next Change Report household's REDE or the next Mid-Point Report household's REDE/Mid-Point Report is due, whichever is earlier.
Step Three Is the information less than 60 days old?	If Yes, follow-up with the SNAP household by sending a 267 VCL to request contact and verifications, if needed. See instructions under the heading 267VCL/360c notices. If No, then the FCRC should not act on the information or require the SNAP household to provide information until the next Change Report household's REDE or the next Mid-Point Report household's REDE/Mid-Point Report is due, whichever is earlier.

Note: The 60 days is not in terms of when the crossmatch is received. The information in the Data Crossmatch cannot be more than 60 days old relative to the current month of SNAP participation.

267 VCL/360C Notices

1. Request proof when it is discovered that the SNAP household did not report a change or if information is unclear. Send the SNAP household a manual 267 VCL to request specific verification. Include the following: 
   • "We have received information that conflicts with information that you have previously provided. You must respond to this notice and provide the information that is requested within 10 days from the date of this notice. If you do not respond and provide the information within 10 days, your SNAP benefits will be discontinued." 
   • "Hemos recibido información que entra en conflicto con la información que nos ha proporcionado con anterioridad. Debe responder a este aviso y proporcionar la información que se solicita dentro de los 10 días siguientes a la fecha de esta notificación. Si usted no responde y proporcionar la información dentro de 10 días, se suspenderán sus beneficios de SNAP".
   1. The 267 VCL notice should inform the SNAP household of the verification it must provide or the actions it must take to clarify its circumstances and the consequences if the household fails to respond.
   2. The notice request allows the household 10 days from the date of the written request to respond and clarify its circumstances either in person, by telephone or through correspondence with the required verifications, if needed.
   3. If the SNAP household responds to the notice request and provides sufficient information, act on the new circumstances within 10 days, as appropriate.
2. If the household does not respond to the 267 VCL notice request, or does respond but refuses to provide sufficient information to clarify its circumstances, complete a manual Notice of Decision (Form 360c). Use the following reason:
   • "Your benefits are being canceled because you failed to provide the information and/or verification as requested in our notice dated" (use the date the 267 VCL was sent to the SNAP household).
   • "Sus beneficios se están cancelando porque no proporcionó la información y / o la verificación según lo solicitado en nuestro notificación de fecha" (use the date the 267 VCL was sent to the SNAP household.

Procedures for Acting on Unclear Information from a Prisoner or Death Match

• The above procedures do not apply to prisoner or death data matches. The FCRC must follow-up on all data matches received on incarcerated or deceased persons. IES receives information about customers who may be deceased or incarcerated. Sometimes, IES is able to confirm exact matches and those cases will auto-process the match. When an exact match cannot be confirmed automatically, worker intervention is required. For SNAP, a 267 VCL must be sent to the customer prior to taking a negative action on the case to ensure that the data source is correct, regardless of the IES exact match. If it is learned that an individual is not deceased or incarcerated, enter the appropriate source of data that was used to make this determination and manually close the task.
• Include the following on the 267 VCL:
  • "We have received information that conflicts with information that you have previously provided. You must respond to this notice and provide the information that is requested within 10 days from the date of this notice. If you do not respond and provide the information within 10 days, your SNAP benefits will be discontinued".
  • "Hemos recibido información que entra en conflicto con la información que nos ha proporcionado  con anterioridad. Debe responder a este aviso y proporcionar la información que se solicita dentro de los 10 días siguientes a la fecha de esta notificación. Si usted no responde y proporcionar la información dentro de 10 días, se suspenderán sus beneficios de SNAP".

• The 267 VCL notice must clearly explain what information the SNAP household must provide and the consequences of failing to respond to the notice.
  • For a household subject to Change Reporting, if the household does not respond to the 267 VCL regarding the crossmatch, or does respond but fails to provide sufficient information to clarify its circumstances, send Form 360c to cancel the entire SNAP case. A Change Reporting household is required to report changes within 10 calendar days of the date they learn of the change (PM 18-04-00).
  • For Mid-Point Reporting households, if the household does not respond to the 267 VCL regarding the crossmatch or does respond but fails to provide sufficient information to clarify its circumstances, remove the individual from SNAP and adjust benefits accordingly. For a single person case, cancel SNAP. Send Form 360c to notify the household of the adverse action. A Mid-Point Reporting household is not required to report when someone leaves the household, therefore adverse action is only taken on the ineligible person listed in the crossmatch. If the ineligible person is the head of household, a new application should be completed for the remaining eligible persons.
• If the household does not respond to the 267 VCL notice request, or does respond but refuses to provide sufficient information to clarify its circumstances, complete a manual Notice of Decision (Form 360c). Use the following reason:
  • "Your benefits are being canceled because you failed to provide the information and/or verification as requested in our notice dated" (use the date the 267 VCL was sent to the SNAP household).
  • Sus beneficios se están cancelando porque no proporcionó la información y / o la verificación según lo solicitado en nuestro notificación de fecha" (use the date the 267 VCL was sent to the SNAP household).
• When the SNAP household has not reported an address change and the 267 VCL is returned as undeliverable mail, send the notice of adverse action to the last known address provided by the household with the appropriate cancellation reason. Do not send a notice of adverse action to a DOC facility. The reason for the cancellation is because the customer cannot be located.

• Example: The FCRC receives a Prisoner Data Match indicating Mr. B is incarcerated. Mr. B is a one person SNAP household in Change Reporting. He has not reported any changes in his circumstances to the FCRC. The FCRC sends Mr. B a 267 VCL notice to his last known address to request contact for clarification and/or verification of the unclear information (PM 18-04-03). The 267 VCL is returned as undeliverable mail. The FCRC sends the notice of adverse action to Mr. B's last known address indicating that his SNAP benefits will be canceled. The case is canceled because the client cannot be located, and eligibility cannot be determined due to the undeliverable mail. The information received from the data match is unclear information since there was no contact with the client to confirm his circumstances. 

• If it is verified that the person is incarcerated, make the appropriate case changes based on the household's reporting status.
  • Example: Ms. K, her husband BJ, and their son T are in Mid-Point Reporting for SNAP. In October, the FCRC receives a Prisoner Data Match indicating BJ is incarcerated. If BJ is incarcerated, the Mid-Point Reporting household is not required to report it. The FCRC is required to act on the data match by sending the household a 267 VCL requesting contact for clarification of the unclear information reported on the data match. It is considered unclear information because the data match indicates a change in household circumstances that the household has not reported and the FCRC does not know if the information is correct. Ms. B responds to the 267 VCL within 10 days and reports that BJ has been incarcerated since August. The FCRC removes BJ from SNAP. Form 360c is sent notifying the SNAP household of the removal of BJ and the reduction in SNAP benefits. There is not an overpayment because the Mid-Point Reporting household was not required to report that the household member left the home, unless the household had income that would exceed the Gross Monthly Income Standard for the household size.

Death Data Crossmatch

• When a Death Data Crossmatch is received on an individual, send a 267 VCL to confirm if the information received on the data match is accurate. If it is verified that the person is deceased, make the appropriate case changes based on the household's reporting status. If the 267 VCL is returned as undeliverable or the household does not respond send Form 360c to the last known address with the appropriate cancellation reason.
  • Example: In October, the FCRC receives a Death Data Crossmatch on a member of Ms. J's household who may have passed away in July.  Ms. J is in Change Reporting status and has not reported any change in household circumstances. The FCRC sends a 267 VCL notice to Ms. J to clarify if the information received in the data match is accurate. Ms. J contacts the FCRC within 10 days and states her son died in July. The FCRC makes the appropriate changes to remove the son from the SNAP case and sends Form 360C notifying the household of the change in benefits due to the removal of a household member. Ms. J was required to report this change within 10 days of the date it became known. The HSC reviews the case to determine if an overpayment has occurred.

Manual Revisions

[signed copy on file]

Grace B. Hou

Secretary Designate, Illinois Department of Human Services

Forms Referenced:

Form 267 VCL

Form 360C

Form 2890

Form 2891

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