COVID-19 Suspension of the Audio Recording for a Signature is Extended through October 2020 for SNAP Applications

10/07/2020

Policy Memo

Summary

• This policy memo provides for an extension to suspend audio recording for signature and allows for verbal attestation through October 31, 2020.
• The Illinois Department of Human Services (IDHS) received Food and Nutrition Services (FNS) waiver approval to adjust SNAP regulations which require an audio recording of a telephonic signature. The adjustment is approved under the Families First Coronavirus Response Act and is consistent with what is practicable under actual conditions in areas affected by the COVID-19 Public Health Emergency. The adjustment is for initial applications that are submitted without a signature for a period of 8 months, effective March 01, 2020 through October 31, 2020.
• In addition, Illinois's Executive Order 2020-20 expands further on the telephonic signature system process for all programs and provides that during the Gubernatorial Disaster Proclamation related to COVID-19, the audio recording is suspended, and verbal attestation is acceptable.
• An interview must be conducted for unsigned initial SNAP applications that are received over the phone or by paper application.
• An evaluation and analysis of the estimated number of households affected by this adjustment is required to be reported to FNS. In order to collect this data, FCRC staff are instructed to select "PRS" as the Type of Contact on the Case Comments - Detail screen. To ensure that the data collected is accurate, "PRS" should only be used for this COVID-19 exception.

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Valid Telephonic Signature

Federal regulations require that to constitute a valid telephonic signature, the telephonic signature system must make an audio recording of the household's verbal assent and a summary of the information to which the household assents. The telephonic signature system must provide for linkage from the audio file of the recorded verbal assent to the application so that staff have ready access to the household's entire case file.

COVID-19 Telephonic Signature Process

• The adjustment to the telephonic signature is limited to SNAP households who submit initial applications without signatures over the phone or by paper application
• This adjustment allows customers to call the Family Community Resource Center (FCRC) in the event that there are system issues with the ABE Call Center and a telephonic signature cannot be obtained.
• In addition, community providers can take applications over the phone from applicants and then submit to the FCRC without having to first send to the applicant for signature.

FCRC Required Action

If an initial application is received over the phone or a paper application is submitted without a signature:

1. The HSC must contact the applicant to conduct a telephone interview. If the HSC is able to reach the client by phone, note on the application that verbal attestation of COVID-19.
2. If the applicant cannot be reached by phone, send the Appointment Notice (Form 267T) to schedule the appointment and request any needed verifications. Make every attempt to verify household circumstances through data matching.
3. When conducting the interview, select "PRS" as the Type of Contact on the Case Comments - Detail screen. This selection is necessary to collect the data needed to report to FNS.
4. At the end of the interview, explain to the client the reason for the verbal attestation. Explain the client's rights and responsibilities. Summarize the information to which the client assents and allow a verbal signature from the client.
5. Document the summary in IES Case Comments to demonstrate that the client has signed the application. This establishes the date of application. Include: *the client's name, date and time of application; and

Interview Missed

• If the interview is missed, IES will generate the Notice of Missed Interview (Form 267L) on the first work day following the day that the scheduled 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.
• Document in Case Comments the interview date, time, reason for denial and any other relevant case information.

Other Application Requirements

• FCRC staff must continue to comply with all other applicable interview and signature requirements.
• Paper applications with signatures and online applications with electronic signatures must still be accepted.

[signed copy on file]

Grace B. Hou

Secretary, Illinois Department of Human Services

Forms Reference:

Form 267L

Form 267T

Form 360R