Adjustment to the SNAP Interview Requirement Waived for Applications filed in October 2020, November 2020 and December 2020

Illinois Department of Human Services Logo

10/26/2020

Policy Memo

Summary

  • As a continuous resolution to helping States cope with the effects of COVID-19 and its impact on the application process, Food and Nutrition Services (FNS) is allowing States the option to extend SNAP certifications under the Code of Federal Regulations as was allowed by the Family First Coronavirus Response Act (FFCRA).
  • Illinois Department of Human Service's (IDHS) has opted to adjust the requirement for a SNAP household to have an interview prior to the issuance of SNAP benefits for initial applications, including expedited applications for all initial applications, including expedited filed in the months of October 2020, November 2020 and December 2020.
  • FNS' initial waiver approval authorized under Section 2302 of the Families First Coronavirus Response Act (P.L. 116-127) allowed IDHS to adjust the interview requirement from March 1, 2020 through May 31, 2020. Subsequent waiver approvals were granted for the months of June, July and August.
  • IDHS did not have FNS' approval to waive the interview requirement for applications filed in September 2020. The Family Community Resource Center (FCRC) must conduct an interview for all SNAP applications filed in the month of September 2020. See Policy Memo, SNAP Interview Required for all Initial Applications filed in September 2020, dated 09/03/2020.
  • Starting with initial SNAP applications filed October 1, 2020 and continuing with applications filed in November 2020 and December 2020, an interview is not required for expedited and non-expedited SNAP households whose identity is verified and all mandatory verifications that are needed to establish eligibility are provided with the application.
  • A SNAP household whose identity cannot be verified, and/or mandatory verifications to establish eligibility are not provided with the application does not qualify for the adjustment and must have an interview. This includes when there is questionable information. Follow regular SNAP application processing procedures. Complete data collection and schedule an interview for the customer.

COVID - 19 Waiver Approval Overview

Food and Nutrition Services (FNS) initial waiver approval authorized under Section 2302 of the Families First Coronavirus Response Act (P.L. 116-127), allowed the Illinois Department of Human Services (IDHS) to adjust the interview requirement from March 1, 2020 through May 31, 2020 and subsequent waiver approvals allowed the adjustment through August 2020.

An Interview is Required for all September SNAP Applications

  • IDHS did not have a waiver for applications filed in the month of September 2020. The Family Community Resource Center (FCRC) is required to interview all applicants and customers who file an initial SNAP application or REDE in the month of September 2020. Regular SNAP application processing procedures should be followed for applications filed in the month of September. See Policy Memo, SNAP Interview Required for all Initial Applications filed in September 2020, dated 09/03/2020.

Initial Applications filed in October, November and December 

  • As a continuous resolution to helping States cope with the effects of COVID-19 and its impact on the application process, Food and Nutrition Services (FNS) is allowing States the option to extend SNAP certifications under the Code of Federal Regulations as was allowed by the Family First Coronavirus Response Act (FFCRA). IDHS has opted to allow SNAP benefits to be issued prior to having an interview for initial applications, including expedited applications when the SNAP household has verified identity and provided all mandatory verifications with the application to establish their eligibility.
  • Starting with initial SNAP applications filed October 1, 2020 and for applications filed in November and December, an interview is not required for expedited and non-expedited SNAP households whose identity is verified and all mandatory verifications that are needed to establish eligibility are provided with the application.
  • A SNAP household whose identity cannot be verified, and/or mandatory verifications have not been provided with the application to establish eligibility, or there is questionable information is required to have an interview.

The following sections only apply to initial SNAP applications filed in the months of October 2020, November 2020 and December 2020.

Face-to-Face Interview

  • If a customer requests a face-to-face interview, the FCRC should explain that in lieu of a face-to-face, the interview will be conducted by telephone. This is necessary to protect the health and safety of the customer and FCRC staff during the COVID-19 pandemic.
  • Send the customer an Appointment Notice (Form 267T) with the scheduled interview date and time. If the interview is missed, IES will generate the Notice of Missed Interview (Form 267L) the following day of when the requested interview is missed. The Notice of Missed Interview informs the client that they need to complete the interview by the 30th day following the date of application.
  • IES generates Notice of Decision on SNAP Application - Missed Interview (Form 360R) to deny applicants who receive a Notice of Missed Interview and fail to complete the interview by the 30th day.

Expedited Households

  • A SNAP household that qualifies for expedited service is not required to complete an interview prior to approval when identity and all mandatory verifications are provided with the application to establish eligibility. If all eligibility factors are verified to determine eligibility for SNAP, issue expedited benefits, run eligibility and certify ongoing benefits.
  • When the applicant qualifies for expedited service but:
    • identity is not verified; and/or
    • other verifications have not been verified to determine eligibility; or the information is questionable.
  • First, attempt to call the client to conduct an interview and obtain verifications. If the client cannot be reached by phone, send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications, if needed to establish eligibility.
  • If the interview is held and identity can be verified, but other verifications are postponed, issue benefits within the expedited timeframes. Issue 1 or 2 months of benefits based on when the application is filed (before or on the 15th of the month or after the 15th of the month). 
  • Whenever possible use electronic sources, such as SOLQ to establish identity.

Non-expedited Households

  • For non-expedited households, an interview is not required when identity is verified and all other mandatory verifications, have been provided with the application to determine eligibility. If all eligibility factors are verified to determine ongoing eligibility for SNAP, approve benefits. Run eligibility and certify ongoing benefits.
  • Conduct an interview when identity cannot be verified and/or mandatory verifications have not been provided to establish eligibility or the information is questionable.
  • Send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications, if needed to establish eligibility.

What are Mandatory Verifications?

Any verifications needed to establish eligibility for the case such as residence, income, including self-employment, citizenship.

Rights and Responsibilities and Copies of the Application

Each FCRC has established a procedure to retrieve mail, print documents and other information from the FCRC. Copies of the Rights and Responsibilities and a copy of the application (if a copy is requested) should be mailed to the customer. For FCRCs that remain closed, these documents can be printed in the FCRC and the designated person will pick up the documents from the FCRC for mailing.

Case Comments

The HSC must do a Case Comment entry. Case comments should include an adequate description of the household's circumstances and any adjustments or exceptions made to the eligibility determination and case processing due to COVID-19, including any customer and advocate complaints. Case Comments should also include that the rights and responsibilities, and a copy of the application, if requested and was mailed to the customer.

Evaluation

An evaluation and analysis of the estimated SNAP households that have been impacted by these adjustments is required to be reported to FNS. In order to collect this data, FCRC staff are instructed to select "Home Visit" as the Interview Mode on the Individual Interview/Applicant- Details screen.

Desk Aid

Provides a desk aid for the COVID-19 adjustment to the SNAP interview process.

QUESTION ANSWER
When is a SNAP interview NOT required for expedited service?

At initial application when an applicant qualifies for expedited service PM 02-08-01 and:

  • identity is verified; and
  • all mandatory verifications, such as residence, income, including self-employment income, citizenship have been provided with the application to determine eligibility.

If all eligibility factors are verified to determine eligibility for SNAP, issue expedited benefits, run eligibility and certify ongoing benefits.
When should the applicant who qualifies for expedited service be contacted for an interview?

When the applicant qualifies for expedited service but:

  • identity is not verified; and/or
  • other verifications have not been verified to determine eligibility; or the information is questionable.

Whenever possible use electronic sources, such as SOLQ. Attempt to call the applicant to conduct an interview and obtain verifications.

If unable to reach by phone, send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications, if needed to establish eligibility.

If the interview is held and identity can be verified, but other verifications are postponed, issue benefits within the expedited timeframes.

Issue benefits for:

  • 1 month, if the applicant applies on or before the 15th of the month; or
  • 2 months, if the applicant applies after the 15th of the month.

Do not delay issuing benefits just because all other verification has not been provided at the time of the interview.
VERIFICATIONS
What is meant by mandatory verifications other than identity?
  • Any verifications needed to establish eligibility for the case such as residence, income, including self-employment, citizenship.
If a 267 VCL is needed for any verification, like income, residency, questionable data should the worker (once this is discovered) stop data collection and try and reach the customer for an interview?
  • Yes, if the applicant can't be reached by phone, an interview should be scheduled.
If an interview is required, and the applicant only returns verifications instead of complying with the interview requirement, is the application denied?
  • Yes, if the applicant is required to have an interview, then they must comply with the requirement.
  • The application is denied for missed interview on the 30th day.
NON-EXPEDITED
When is a SNAP interview NOT required for non-expedited households?

When the applicant's:

  • identity is verified; and
  • all other mandatory verifications, such as residence, income including self-employment, citizenship have been provided with the application to determine eligibility.

If all eligibility factors are verified to determine ongoing eligibility for SNAP, approve benefits. Run eligibility and certify ongoing benefits.
When should a non-expedited applicant be contacted for an interview? Conduct an interview when:
  • identity cannot be verified; and/or
  • mandatory verifications have not been provided to determine eligibility; or
  • the information is questionable.
Send Form 267T to schedule the interview appointment and Form 267 VCL to request any verifications, if needed to establish eligibility.
What if the applicant who is required to have an interview only returns verifications and does not respond to the interview request?
  • If the applicant only returns verifications but does not respond to having the interview, the application is denied on the 30th day.
  • If the interview is held and the applicant qualifies for expedited services, begin expedited processing timeframes.
See PM 02-08-02-a, PM 02-08-02-b.
An application submitted and was later denied for missed interview, should it be reopened when or if discovered or questioned by the customer? No, if the application was denied on the 30th day and the applicant did not comply with the interview requirement, a new application is needed.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms Referenced:

Form 267L

Form 267T

Form 267 VCL

Form 360R